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Document of

The World Bank

FOR OFFICIAL USE ONLY

Report No: PAD3473

INTERNATIONAL DEVELOPMENT ASSOCIATION

PROJECT APPRAISAL DOCUMENT

ON A

PROPOSED CREDIT

IN THE AMOUNT OF SDR 16.4 MILLION (US$22.5 MILLION EQUIVALENT)

AND A

PROPOSED GRANT

IN THE AMOUNT OF SDR 16.4 MILLION (US$22.5 MILLION EQUIVALENT)

FROM THE CRISIS RESPONSE WINDOW

TO THE

UNION OF COMOROS

FOR THE

COMOROS POST‐KENNETH RECOVERY AND RESILIENCE PROJECT

December 5, 2019

Urban Resilience and Land Global Practice Africa Region

This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization.

CURRENCY EQUIVALENTS

(Exchange Rate Effective October 31, 2019)

Currency Unit = Comorian Francs (KMF)

US$1 = KMF 441

US$1 = SDR 0.72495813

FISCAL YEAR January 1 ‐ December 31

Regional Vice President: Hafez M. H. Ghanem

Country Director: Mark R. Lundell

Regional Director: Ede Jorge Ijjasz‐Vasquez

Practice Manager: Meskerem Brhane

Task Team Leader: Van Anh Vu Hong

ABBREVIATIONS AND ACRONYMS

ADT Average Daily Traffic

AFD French Development Agency (Agence Française de Développement)

AfDB African Development Bank

ANACEP National Agency for Project Design and Implementation (Agence Nationale de Conception et d’Exécution des Projets)

CADRI Capacity for Disaster Reduction Initiative

CATI Information Analysis and Processing Center

CEDAW Convention on the Elimination of all Forms of Discrimination Against Women

CERC Contingent Emergency Response Component

CERF Central Emergency Response Fund

COSEP Center of Relief Operations and Civil Protection

CPF Country Partnership Framework

CPS Country Partnership Strategy

CRW Crisis Response Window

DA Designated Account

DALYs Disability Adjusted Life Years

DATUH Directorate for Land Use, Urban Planning and Housing

DFIL Disbursement and Financial Information Letter

DGEAT Directorate General for Equipment and Land Use

DGRTR Directorate General for Roads and Land Transportation

DGSC Directorate General for Civil Security

DLI Disbursement‐Linked Indicator

DPM Delegated Project Management

DRM Disaster Risk Management

DRR Disaster Risk Reduction

DTM Technical Directorate of Meteorology (Direction Technique de la Météorologie)

E&S Environmental and Social

EDSC‐MICS Comoros Demographic and Health Survey, Multiple Indicator Cluster Survey (Enquête Démographique et de Santé et à Indicateurs Multiples aux Comores)

EESIC Household Budget Survey (Enquête sur l’Emploi, le Secteur Informel et la Consommation)

EEZ Exclusive Economic Zone

ESA Environmental and Social Assessment

ESCP Environmental and Social Commitment Plan

ESF Environmental and Social Framework

ESIA Environmental and Social Impact Assessment

ESMF Environmental and Social Management Framework

ESMP Environmental and Social Management Plan

ESRS Environmental and Social Review Summary

ESS Environmental and Social Standard

ESSF Environmental and Social Screening Form

EU European Union

FAO Food and Agriculture Organization of the United Nations

FCV Fragile, Conflict and Violence

FM Financial Management

GBV Gender‐based Violence

GDP Gross Domestic Product

GM Grievance Mechanism

GNI Gross National Income

GoC Government of the Comoros

GP Global Practice

GRM Grievance Redress Mechanism

GRS Grievance Redress Service

HDM Highway Development and Management

HIV Human Immunodeficiency Virus

IA Internal Auditor

IBRD International Bank for Reconstruction and Development

IDA International Development Association

IFAC International Federation of Accountants

IFR Interim Financial Report

IFRC International Federation of Red Cross and Red Crescent Societies

IMF International Monetary Fund

IPF Investment Project Financing

IRR Internal Rate of Return

JICA Japan International Cooperation Agency

km Kilometer

KMF Comorian Franc

LMIC Lower‐middle Income Country

LMPs Labor Management Procedures

m meter

M&E Monitoring and Evaluation

MAFE Ministry of Agriculture, Fishery and Environment

MLUUP Ministry of Land‐Use and Urban Planning, in charge of Land Affairs and Land Transport

MMAT Ministry of Maritime and Air Transport

MOD Delegated Project Management (Maîtrise d’Ouvrage Déléguée)

MOIDTA Ministry of Interior, Decentralization and Territorial Administration in Charge of Relationship with Institutions

NGO Non‐governmental Organization

NPDRR National Platform for Disaster Risk Reduction

NPV Net Present Value

NSDRR National Strategy for Disaster Risk Reduction

OCHA Office for the Coordination of Humanitarian Affairs

OHS Occupational Health and Safety

OP Operational Policy

OPCS Operations Policy and Country Services

OVK Karthala Volcanological Observatory

PDO Project Development Objective

PDNR National Master Plan for Road Transportation (Plan Directeur National du Transport Routier)

PEFA Public Expenditure and Financial Accountability

PFM Public Financial Management

PIDC Integrated Development and Competitiveness Project

PIU Project Implementation Unit

POM Project Operations Manual

PPP Purchasing Power Parity

PPSD Project Procurement Strategy for Development

PRGSP Poverty Reduction and Growth Strategy Paper

RF Resettlement Framework

RMF Road Maintenance Fund

RP Resettlement Plan

RUC Road User Cost

SCD Systematic Country Diagnostic

SDR Special Drawing Rights

SEA Sexual Exploitation and Abuse

SEP Stakeholder Engagement Plan

SOE Statement of Expenditures

SP Social Protection

STEP Systematic Tracking of Exchanges in Procurement

TA Technical Assistance

UN United Nations

UNDP United Nations Development Program

UNECA United Nations Commission for Africa

UNFPA United Nations Population Fund

UNICEF United Nations International Children's Emergency Fund

UoC Union of the Comoros

USD or US$ United States Dollar

WB World Bank

WBG World Bank Group

WFP World Food Program

TABLE OF CONTENTS

DATASHEET ............................................................................................................................ 1

I. STRATEGIC CONTEXT ........................................................................................................ 7

A. Country Context ................................................................................................................................ 7

B. Situation of Urgent Need of Assistance ............................................................................................ 8

C. Sectoral and Institutional Context .................................................................................................. 11

D. Relevance to Higher Level Objectives ............................................................................................ 16

II. PROJECT DESCRIPTION ................................................................................................... 17

A. Project Development Objective ..................................................................................................... 17

B. Project Components ....................................................................................................................... 18

C. Project Beneficiaries ....................................................................................................................... 24

D. Results Chain .................................................................................................................................. 27

E. Rationale for World Bank Involvement and Role of Partners ......................................................... 29

F. Lessons Learned and Reflected in the Project Design .................................................................... 29

III. IMPLEMENTATION ARRANGEMENTS .............................................................................. 31

A. Institutional and Implementation Arrangements .......................................................................... 31

B. Results Monitoring and Evaluation Arrangements ......................................................................... 33

C. Sustainability ................................................................................................................................... 33

IV. PROJECT APPRAISAL SUMMARY ..................................................................................... 34

A. Technical, Economic and Financial Analysis (if applicable) ............................................................ 34

B. Fiduciary .......................................................................................................................................... 36

C. Legal Operational Policies ............................................................................................................... 37

D. Environmental and Social ............................................................................................................... 37

V. GRIEVANCE REDRESS SERVICES ....................................................................................... 39

VI. KEY RISKS ....................................................................................................................... 40

VII. RESULTS FRAMEWORK AND MONITORING ..................................................................... 42

ANNEX 1: Implementation Arrangements and Support Plan ........................................... 53

ANNEX 2: Economic Analysis .......................................................................................... 60

List of Figures

Figure 1 – Impact of Cyclone Kenneth (areas affected) .......................................................................... 9 Figure 2 ‐ Estimates Damages and Losses (US$ million) ....................................................................... 10 Figure 3 – Project Theory of Change ........................................................................................................ 28 Figure 4 – Institutional and Implementation Arrangements ................................................................ 32 Figure 2.1 – Total Modeled Losses from Flooding and Tropical Cyclones by Return Period ….......63

List of Tables

Table 1 – Project Components and Estimated Amounts .................................................................... 23 Table 2 – Summary of Economic Efficiency .......................................................................................... 35 Table 1.1 – Project FM Risk Assessment and Mitigation .................................................................... 55 Table 1.2 – Project FM Action Plan ........................................................................................................ 57 Table 1.3 – Procurement Methods ........................................................................................................ 58 Table 1.4 – Procurement Action Plan Corrective Measures .............................................................. 59 Table 1.5 – Thresholds for Procurement of Goods and Non‐Consulting Services and Consulting Services ...................................................................................................................................................... 59 Table 2.1 – Summary of Economic Efficiency ....................................................................................... 60 Table 2.2 ‐ Average Daily Traffic Estimated and Vehicle Type Composition.................................... 64 Table 2.3 – Economic or Financial Unit Costs of Operating Vehicles (US$) ..................................... 64 Table 2.4 ‐ Vehicle Fleet Characteristics ............................................................................................... 64 Table 2.5 – Estimated Road User Costs (US$/vehicle‐km) ................................................................. 65 Table 2.6 – Normal Carbon Dioxide Emissions (g/km) by Vehicle Type ........................................... 65

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DATASHEET

BASIC INFORMATION BASIC INFO TABLE

Country(ies) Project Name

Comoros Comoros Post‐Kenneth Recovery and Resilience Project

Project ID Financing Instrument Environmental and Social Risk Classification

Process

P171361 Investment Project Financing

Substantial Urgent Need or Capacity Constraints (FCC)

Financing & Implementation Modalities

[ ] Multiphase Programmatic Approach (MPA) [✓] Contingent Emergency Response Component (CERC)

[ ] Series of Projects (SOP) [✓] Fragile State(s)[ ] Disbursement‐linked Indicators (DLIs) [✓] Small State(s)

[ ] Financial Intermediaries (FI) [ ] Fragile within a non‐fragile Country

[ ] Project‐Based Guarantee [ ] Conflict

[ ] Deferred Drawdown [✓] Responding to Natural or Man‐made Disaster

[ ] Alternate Procurement Arrangements (APA)

Expected Approval Date Expected Closing Date

18‐Dec‐2019 30‐Nov‐2025

Bank/IFC Collaboration

No

Proposed Development Objective(s)

The Project Development Objective is to support recovery and increase disaster and climate resilience of select public and private infrastructure in the areas affected by Cyclone Kenneth.

Components

Component Name Cost (US$, millions)

The World Bank Comoros Post-Kenneth Recovery and Resilience Project (P171361)

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Component 1: Recovery and Resilience in the Housing Sector 12.30

Component 2: Coastal Resilience and Infrastructure Rehabilitation 23.64

Component 3: Integrated Disaster Risk Management and CERC 6.06

Component 4: Project Management, Risk Management, Monitoring and Evaluation 3.00

Organizations

Borrower: Union of the Comoros

Implementing Agency: Ministry of Land‐Use and Urban Planning, in charge of Land issues and Land Transport

PROJECT FINANCING DATA (US$, Millions)

SUMMARY‐NewFin1

Total Project Cost 45.00

Total Financing 45.00

of which IBRD/IDA 45.00

Financing Gap 0.00

DETAILS‐NewFinEnh1

World Bank Group Financing

International Development Association (IDA) 45.00

IDA Credit 22.50

IDA Grant 22.50

IDA Resources (in US$, Millions)

Credit Amount Grant Amount Guarantee Amount Total Amount

Comoros 22.50 22.50 0.00 45.00

Crisis Response Window (CRW)

22.50 22.50 0.00 45.00

Total 22.50 22.50 0.00 45.00


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Expected Disbursements (in US$, Millions)

WB Fiscal Year 2020 2021 2022 2023 2024 2025 2026

Annual 6.50 6.50 8.00 8.00 8.00 6.50 1.50

Cumulative 6.50 13.00 21.00 29.00 37.00 43.50 45.00

INSTITUTIONAL DATA

Practice Area (Lead) Contributing Practice Areas

Urban, Resilience and Land Transport

Climate Change and Disaster Screening

This operation has been screened for short and long‐term climate change and disaster risks

Gender Tag

Does the project plan to undertake any of the following?

a. Analysis to identify Project‐relevant gaps between males and females, especially in light of country gaps identified through SCD and CPF

Yes

b. Specific action(s) to address the gender gaps identified in (a) and/or to improve women or men's empowerment

Yes

c. Include Indicators in results framework to monitor outcomes from actions identified in (b) Yes

SYSTEMATIC OPERATIONS RISK‐RATING TOOL (SORT)

Risk Category Rating

1. Political and Governance High

2. Macroeconomic Substantial

3. Sector Strategies and Policies Moderate

4. Technical Design of Project or Program Substantial

5. Institutional Capacity for Implementation and Sustainability High

6. Fiduciary Substantial


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7. Environment and Social Substantial

8. Stakeholders Substantial

9. Other

10. Overall Substantial

COMPLIANCE

Policy Does the project depart from the CPF in content or in other significant respects?

[ ] Yes [✓] No

Does the project require any waivers of Bank policies?

[ ] Yes [✓] No


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Environmental and Social Standards Relevance Given its Context at the Time of Appraisal

E & S Standards Relevance

Assessment and Management of Environmental and Social Risks and Impacts Relevant

Stakeholder Engagement and Information Disclosure Relevant

Labor and Working Conditions Relevant

Resource Efficiency and Pollution Prevention and Management Relevant

Community Health and Safety Relevant

Land Acquisition, Restrictions on Land Use and Involuntary Resettlement Relevant

Biodiversity Conservation and Sustainable Management of Living Natural

Resources

Relevant

Indigenous Peoples/Sub‐Saharan African Historically Underserved Traditional

Local Communities

Not Currently Relevant

Cultural Heritage Not Currently Relevant

Financial Intermediaries Not Currently Relevant

NOTE: For further information regarding the World Bank’s due diligence assessment of the Project’s potential environmental and social risks and impacts, please refer to the Project’s Appraisal Environmental and Social Review Summary (ESRS).

Legal Covenants

Sections and Description Section I.D.2 of Schedule 2: The Recipient shall, throughout the duration of the Project, carry out the Routine Maintenance to the rehabilitated road section under Part 2.1 of the Project, by ensuring that such road section is periodically included on the list ofeligible roads maintenance under the Recipient’s Road Fund.

Sections and Description Section I.D.1 of Schedule 2: The Recipient shall refrain from releasing funds for the implementation of works under Part 2.1 of the Project until and unless the ESMF and RF are prepared, finalized, adopted, and disclosed by the Recipient in form and substance satisfactory to the Association.

Sections and Description Section I.A.1 of Schedule 2: The Recipient shall: (A) carry out the Project through MLUUP, and shall cause MLUUP to, not later than three (3) months after the


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Effectiveness Date, create through a Ministerial Order and thereafter maintain throughout Project implementation, a PIU within DATUH, to be responsible for the management, coordination, supervision, and monitoring of Project activities; (B) no later than three (3) months after the Effectiveness Date or such later date as agreed in writing by the Bank, cause the PIU to appoint and hire, and thereafter maintain, throughout Project implementation key staff i.e.: (i) a Project coordinator, (ii) an environmental specialist, (iii) a social specialist, (iv) a financial management specialist, (v) an accountant, (vi) a procurement specialist, and (vii) an M&E specialist, and thereafter maintain, until completion of the Project, a structure, responsibilities, and such key staff with functions, experience, responsibilities and qualifications acceptable to the Association and described in the POM; (C) no later than six (6) months after the Effectiveness Date, or such later date as agreed by the Bank, cause the PIU to appoint and hire an internal auditor, and thereafter maintain an internal auditor for the Project, throughout Project implementation. Sections and Description Section I.A.2 of Schedule 2: The Recipient shall establish a Project Steering Committee, no later than three (3) months after the Effectiveness date to be chaired by a representative of the Minister of MLUUP and comprised, inter alia, of a representative of the Ministry of Finance, Budget, and Banking Sector, ANACEP, DGSC, MAFE, the Ministry of Health, Solidarity, Social Protection and Gender Promotion, municipalities, associations and women’s groups, key stakeholders involved in the construction sector, with functions, personnel and resources satisfactory to the Association, and thereafter maintain said Project Steering Committee. Sections and Description Section I.B.1 of Schedule 2: The Recipient, through MLUUP, shall no later than thirty (30) days after the Effective Date: (a) prepare and thereafter carry out the Project in accordance with the POM; and (b) except as the Association shall otherwise agree, the Recipient, through MLUUP, shall not amend, waive or fail to enforce the POM, or any provisions thereof. Conditions Type Description

Disbursement No withdrawal shall be made under Category (2) unless: (i) the ESMF and RF are prepared,

finalized, adopted, and disclosed in form and substance satisfactory to the Association; (ii)

the Recipient has adopted the Housing Reconstruction Manual in a manner satisfactory to

the Association.


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I. STRATEGIC CONTEXT

A. Country Context 1. The Union of Comoros (UoC) is a small volcanic archipelago in the Indian Ocean off the coasts of Mozambique and Madagascar. The UoC has about 1,800 square kilometers of land, 340 kilometers of coastline, and a maritime Exclusive Economic Zone (EEZ) 70 times the size of its land area. The UoC is home to one of the most diverse coral reefs in the world. About half of its 800,000 population lives on Ngazidja (or Grande Comore), which is the largest island where the capital city Moroni is located. The population is growing rapidly (2.9 percent a year) and is forecasted to reach 1 million by 2028 and more than double by 2050. 2. The UoC has experienced recurrent political crises and conflict between its islands since its independence in 1975. Although political instability decreased after the adoption of the Fomboni Agreement in 2001, socio‐political tensions remain an issue. A constitutional referendum held on July 30, 2018, introduced changes to the Presidential rotation system between the country’s three main islands, shifting from a federal to a unitary system. Political instability has constrained private sector‐led‐growth and limited fiscal capacity for infrastructure and social sector investment, contributing to low real income per capita growth. The World Bank classifies the UoC as a country affected by fragility, conflict and violence (FCV).1

3. Although its economic growth remained steady at 2.8 percent in 2018, the country still faces significant impediments to sustainable economic growth and development. The UoC gross national income was US$1,280 per capita in 2017,2 and the country became a lower middle‐income country (LMIC) in July 2019. The UoC achieved a reduction in poverty rates that compares well with those of other LMICs. Nevertheless, the 2018 World Bank Human Capital Index ranks the UoC 123 out of 157 countries.3 More than 40 percent of the population remains below the national poverty line,4 and more than 38 percent remains below the international poverty line,5 a rate that is below the average for LMICs and Sub‐saharan African countries. The decline in poverty is due largely to an increase in diaspora remittances, as about 40 percent of households in the UoC receive remittances.6 Households without access to diaspora remittances are on average 11 percent more likely to be poor, which contributes to inequality – the UoC GINI index was 45 as of 2014.7 Other barriers to sustainable economic growth and development include: low institutional capacity and fiscal constraints, limited physical infrastructure and maintenance, a challenging business environment, geographic remoteness, a small and fragmented domestic market, and high exposure and vulnerability to recurrent natural and climate related disasters. 4. The UoC is prone to natural disasters and one of the most vulnerable countries to climate change, which adversely affects its development and exacerbates existing social and economic vulnerabilities. The UoC is exposed to tsunamis, cyclones, floods and droughts, and seismic and volcanic activity. The 2018 World Risk Index ranks the UoC

1 World Bank (2019). Harmonized list of fragile situations 2 Atlas method 3 https://www.worldbank.org/en/publication/human‐capital 4 Comoros Poverty Assessment, World Bank, 2017: Household Budget Survey EESIC 2014 (Enquête sur l’Emploi, le Secteur Informel et la Consommation) with a referential national poverty line at KMF 25,341 per capita per month. 5 US$3.2 per capita per day for LMIC. 6 World Bank (2018). Comoros Poverty Assessment. Washington, DC: World Bank. 7 World Bank (2019). Towards a more United and Prosperous UoC. Systematic Country Diagnostic (SCD). Washington, DC: World Bank.


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51 out of 172 countries in terms of risk to natural disasters, and 59 in terms of lack of adaptative capacities.8 In the last 40 years, the UoC was hit by eighteen adverse natural events that affected close to 500,000 individuals.9 Average losses due to flooding alone amount to about US$2.0 million per year.10 Climatologists forecast an increase in average temperature, a decrease in annual precipitation, an increase in the number of dry years, and rising sea level in the next 30 years. A 20 centimeters rise in sea level by 2050 would displace at least 10 percent of the UoC population.11 The UoC is especially vulnerable to climate change because of its dependence on agriculture and natural resources – which include vanilla, clove, ylang ylang, and fisheries, a rapid and largely unregulated urban expansion, high poverty and unemployment, and rapid environmental degradation including coastal erosion. The high frequency of natural and climate‐related disasters and the country’s limited capacity to manage these disasters increase the population and infrastructure’s vulnerability to natural and climate related disasters risks.

5. The Government of the Comoros (GoC) is committed to strengthening the country’s resilience to natural andclimate‐related disasters. The GoC’s medium‐term development strategy is outlined in the National Development Policyprogram for 2018‐2021 adopted in 2018, which includes sustainable management of natural resources as a keyobjective.12 The GoC strengthened its commitment to strengthen the country’s resilience to natural and climate‐relateddisasters in the aftermath of tropical Cyclone Kenneth and as part of its 2030 Emergence Plan.13

B. Situation of Urgent Need of Assistance

6. On April 24, 2019 the UoC was struck by Cyclone Kenneth, which is one of the most devastating tropical cyclonesin the country’s history. Kenneth was a Category 3 cyclone with strong winds, torrential rains and high waves thatdestroyed houses, crops, businesses and core infrastructure.14 On April 24, 2019, the GoC declared a Red alert in theNorth of Grande Comore and an Orange alert in the rest of the archipelago. These alerts activated a number of emergencyprocedures and measures, including a coordinated effort by the Centre for Relief and Civil Protection Operations (COSEP)and the municipalities to evacuate individuals anticipated to be on the Cyclone’s trajectory and a ban on trips out at sea.These initial emergency procedures and measures were effective in lowering the adverse impact of the Cyclone on thepopulation. The community associations playing an important role in the community’s life and management in normaltimes provided community areas as temporary shelters and schools. Women groups came together to organize cleaningcampaigns. Within the two days that followed the Cyclone, the GoC, with the support from the United Nations (UN) andleadership from the General Directorate for Civil Security (DGSC) conducted a fast‐track evaluation to identify the mostpressing humanitarian aid needs and the sectors requiring a more in‐depth assessment. The GoC’s response facilitatedthe relatively fast distribution of kits for hygiene and sanitation, and education to some affected households. However,the post‐Cyclone recovery and reconstruction resources needed by the country surpass the GoC’s financial, human,technical and material capacity.

8 The World Risk Index is calculated based on exposure to five types of natural hazards (Earthquakes, cyclones, floods, droughts, and sea‐level rise); vulnerability on the basis of infrastructure/food supply/economic conditions as well as coping and adaptive capacities, which depend on governance, preparedness/early warnings, healthcare, social and material security. https://weltrisikobericht.de/wp‐content/uploads/2019/03/190318_WRR_2018_EN_RZonline_1.pdf 9 EM‐DAT: The Emergency Events Database – Université Catholique de Louvain (UCL) ‐ CRED, D. Guha‐Sapir ‐ www.emdat.be, Brussels, Belgium 10 World Bank, (2016). Comoros Disaster Risk Profile, 2016. 11 World Bank (2019). Country Partnership Framework (CPF) FY20‐24, 2019. (to be approved). Washington, DC: World Bank. 12 Stratégie de Croissance Accélérée pour le Développement Durable – SCA2D 2018‐2021. 13 Document under development, to be presented at a Donor conference in Paris in December 2019. 14 Category 3 on the Saffir Simpson scale.


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7. The GoC declared a nationwide state of emergency on May 9, 2019, 15 and conducted a damage Assessment and developed a Recovery and Reconstruction Plan in June 2019 (henceforth the “Damage Assessment”). The GoC established an Inter‐ministerial committee attached to the Ministry of Economy and Investment Planning to manage the post‐disaster Kenneth situation.16 This committee coordinated the Damage Assessment, with support from the Cabinet of the President in charge of Defense and the DGSC, which falls under the Ministry of Interior, Decentralization and Territorial Administration in charge of relations with Institutions (MOIDTA). To conduct the Damage Assessment, the GoC also requested support from the UN – with the United Nations Development Programme (UNDP) as the lead agency, the World Bank and the International Federation of Red Cross and Red Crescent Societies (IFRC). The Damage Assessment focused on the nine priority sectors identified in the fast‐track evaluation and depicted on Figure 2 below. 8. More than 40 percent of the population, or 345,131 individuals across the three islands, were affected by Cyclone Kenneth. The affected people include 185,879 in need of humanitarian aid,17 153 injured, 11,969 displaced, and 6 fatalities. As shown in Figure 1, the impact of the Cyclone was concentrated in Grande Comore island, where most prefectures were classified as priority zones of intervention by the Damage Assessment with damages and needs across multiple sectors. The Southern island of Mohéli and the Southeastern island of Anjouan were also impacted with one prefecture classified as a priority zone in Mohéli.

Figure 1 – Impact of Cyclone Kenneth (areas affected)

Source: Directorate General for Civil Security, June 2019.

15 Decree N°19‐048 of May 9, 2019. 16 Decree N°19‐047 of May 8, 2019. 17 Rapid needs evaluation in Grande Comore, Anjouan and Mohélia, May 1, 2019, report from the GoC with support from the United Nations Office for the Coordination of Humanitarian Affairs (OCHA).


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9. Cyclone Kenneth caused US$185.4 million in damages and losses and disrupted key public services.18 As shown in Figure 2 below, the Damage Assessment identified that damages and losses are concentrated in the housing sector (US$67.5 million), agriculture, livestock and fisheries sector (US$53.0 million), and infrastructure and transport sector (US$21.1 million). This estimate reflects the damage to about 11,900 houses, 60 percent of subsistence crops (mainly banana, manioc) and 30 percent of cash crops (vanilla, ylang ylang, clove), 13,500 in livestock losses (mainly poultry), and significant disruption of schools and health facilities. In addition, the Cyclone damaged a significant share of the country’s core infrastructure, including roads, ports and airports, dykes, and water and electricity networks. Moreover, the coastline was flooded because of extraordinary storm surge and lack of adequate coastal defense infrastructure.

Figure 2 - Estimates Damages and Losses (US$ million)

Source: Damage Assessment and Recovery and Reconstruction Plan, June 2019.

10. Cyclone Kenneth is affecting people’s lives and livelihoods and is likely to contribute to widening inequality in the country – a fragile small island economy with limited response capacity from its formal institutions and governance structures. Preliminary gross domestic product (GDP) growth estimates for 2019 were revised down from 3.1 to 1.3 percent to account for the effect of the Cyclone.18 This slower economic growth could widen inequality by amplifying increasing differences in education and employment, as well as socio‐economic conditions in local communities and access to diaspora remittances.19 Individuals whose consumption level is just above the poverty line are vulnerable to falling back into poverty. Consumption levels among the poorest are likely to decrease which would contribute to the rising poverty levels. Of the 11,900 houses that were damaged by the Cyclone, 4,854 houses were destroyed. In addition to losing their homes and living in fear of the next cyclone season, those households that temporarily relocated with less affected family members and neighbors tended to lose access to their regular sources of income and schools which imposed additional burdens on their host families.

11. The GoC responded to the humanitarian emergency with national budget and donor support, but still faced a US$227.2 million financing gap to meet the estimated US$277.5 million recovery and reconstruction needs of the nine

18 Government of the Union of the Comoros (2019) Damage Assessment of Cyclone Kenneth & Recovery and Reconstruction Plan. 19 World Bank (2017). Comoros Poverty Assessment. Washington, DC, World Bank.


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priority sectors identified in the Damage Assessment. In addition to the national budget available, the GoC raised US$650,000 in emergency funding by temporarily retaining a share of the civil service monthly wage bill to finance first aid for the Cyclone’s victims.20 First, the Government activated procedures and measures to evacuate people, clear access roads, and issue a ban on trips out to sea, as soon as the Cyclone’s category and trajectory were confirmed. After the Cyclone hit, the Government continued providing first aid and response, for instance, by ensuring the continuity of services in hospitals which lost power, access roads, safety vis‐à‐vis hanging trees or electric poles, etc. It also undertook urgent repairs including of airport radiocommunication systems to reopen services. In addition, it received support from the UN Central Emergency Response Fund (CERF) to provide life‐saving food, shelter, health water and sanitation assistance to affected people, as well as from the United Nations International Children’s Emergency Fund (UNICEF), the World Food Program (WFP) and non‐governmental organizations (NGOs) such as the IFRC. However, the Cyclone highlighted the GoC’s lack of capacity and structured approach to respond to large‐scale disasters and provide adequate assistance to the most affected and most vulnerable households, in terms of financial and technical resources.

12. The Comoros Post‐Kenneth Recovery and Resilience Project is part of the overall World Bank response toaddress the Cyclone’s impacts. Given the extraordinary scale, the World Bank’s response combines the strategic use ofIDA resources of US$73 million and proposes: (a) using up to US$18 million of Comoros’ uncommitted IDA18 nationalallocation through the emergency component of the Social Safety Net Project (P150754) to channel additional financingto support recovery grants and livelihood support services for poor households in disaster affected communities, as wellas the rehabilitation of selected small community‐based infrastructure; (b) using up to US$10 million from activeoperations of the portfolio within their respective envelopes, especially the two investment projects supporting theagriculture and fishery sectors (the Integrated Development and Competitiveness Project (PIDC, P164584) and the SouthWest Indian Ocean Fisheries Project (SWIOFish 1, P132123)); and (c) a Crisis Response Window (CRW) allocation ofUS$45 million to support this proposed project.

13. The proposed project complements ongoing Government operations and programs, focusing on the mostheavily impacted sectors where there is no or limited donor support and where the World Bank has added value. Theproposed project and selection of sectors and activities build on (a) the results from the Damage Assessment; (b) theanalytical work supported by the World Bank particularly on agriculture and transport connectivity;21 (c) the ongoingGovernment operations including World Bank‐financed ones; and (d) active coordination with development partners.The multi‐sectoral recovery project focuses on addressing recovery and reconstruction needs in the housing andinfrastructure sectors which are the first and third most impacted sectors.22 The design process was done in coordinationwith different Global Practices (GPs) (Urban, Transport, Housing, Social Protection, Health, Agriculture, Finance andCompetitiveness and Innovation, Fishery, Energy) – and the project includes a transversal Disaster Risk Management(DRM) component with a cross‐cutting agenda to support climate change adaptation. The proposed project complementsthe overall World Bank lending and technical assistance (TA) program in the UoC.

C. Sectoral and Institutional Context

C.1. Housing

20 Decree N°19‐045 of April 27, 2019 (Mécanisme de financement pour la réparation des dommages causés par le passage aux Comores du Cyclone Kenneth) 21 Comoros Agriculture Sector Review (164195); Comoros: Spatial analysis of the transport connectivity and growth potential (P167706); as well as World Bank, Comoros Poverty Assessment 2018; Comoros Risk and Resilience Assessment, 2018. 22 The agriculture sector (second most impacted sector) has access to significant support from the PIDC and other donor support such as AFD and Food and Agriculture Organization of the United Nations (FAO).


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14. The housing sector in the UoC, in particular on the coastline, is highly exposed to natural and climate‐related disaster risks. It is estimated that the residential sector alone absorbs 80 percent of the combined losses from earthquakes, floods, and tropical cyclones.10 The high cost of construction materials and the low quality of construction techniques are a serious threat to resilient housing whereby the construction of a house in the UoC can take many years to complete. Typically, housing construction is done by local masons (fundi)23 with help from the community in most cases. In the absence of urban planning and management tools and the challenges municipalities are facing to fulfil their urban management functions, more and more households have settled in informal settlements and in high‐risk areas. 15. The UoC has a fragile and challenging housing sector compounded by a nascent and weak institutional framework. There is no housing policy and no land management policy in the UoC. A National Housing Agency, attached to the line Ministry of Land‐Use and Urban Planning, in charge of Land issues and Land Transport (MLUUP) was established in August 2009,24 with the overall objective of improving the quality and affordability of housing. In recent years, recognizing bottlenecks and weaknesses in the housing and land management system, the Government started revising the agency’s mandate and operating model and commissioned in 2018 a study supporting the development of a National Land Strategy. The aim was to foster policies on land management and improve associated governance.25 One of the key recommendations of the study was to carry out a full inventory and mapping of public land in the country. To that end, the Government created a National Committee,26 which however is not yet effective. The UoC has a complex land tenure system where customary, Islamic, and civil law, inspired by modern French law, coexist, but with the first two coming into play most prominently.27 In addition, in rural areas, most housing construction belongs to the land owners, whereas in urban areas, a significant share of households rent a piece of land, lacking basic services, to build what then becomes their own house. Land ownership can be at the state, community, religious, family and individual levels. These five modes tend to overlap; thus, a large part of public lands or large private estates are considered by certain villages to be part of customary use or occupied by individuals according to the principle of “vivification” (de‐facto acquisition). Finally, there are various rights governing the transfer of land ownership most of which are governed (explicitly or implicitly) by religious or customary laws, practices and codes: e.g., inheritance, sale, donation, or de‐facto acquisition.28

16. In terms of land‐use planning and management, the country relies on two main laws: the Decentralization Law promulgated in 2011 and the Urban Planning and Construction Code, promulgated in 2012.29 Nevertheless, accompanying measures were not put in place to support local authorities in playing their roles, and practices remain largely informal. Furthermore, key priority planning instruments such as Master Plans for the development of each island or Urban Development Plans (for each commune) do not exist or are unavailable.30 Urban management tools are outdated or non‐existent; the legal or formal framework governing municipal own revenues is incomplete. The roles and responsibilities of the various stakeholders in the construction of public buildings (schools, agricultural / fishing infrastructure, etc.) are unclear and coordination / support to other sectors (education, agriculture, etc.) and regional directorates and municipalities is weak or missing. Finally, there is no housing finance mechanism despite the existence of four commercial banks, three micro‐credit institutions and one postal bank that could potentially be used to target

23 Fundi stands for master and here refers to master craftsman. 24 Decree N°09‐102. 25 PRCI II document ‐ Projet de Renforcement des Capacités Institutionnelles (PRCI) Phase II, financed by the African Development Bank (AfDB). 26 Ministerial Order of November 21, 2018. 27 Union of the Comoros: National Program for the registration for constructed and non‐constructed properties. 28 Compiled from Rapport de Mission, Juin 2012, Transfert de propriété « Uniformisation » et Consolidation des trois régimes fonciers (Said Mahamoud) through an assistance to the GoC by the International Finance Corporation for its Doing Business evaluation; and Rapport sur la Stratégie Nationale Foncière, Projet de Renforcement des Capacités Institutionnelles (PRCI) Phase II (January 2019, financed by the AfDB). 29 Decentralization law N°11‐OO5/AU and decree No. 11‐147/PR; and 2011 Urban planning and construction code N°11‐026/AU. 30 The first Master Plan for Mohéli should be developed in the coming months with financing from the French development agency AFD.


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the low‐income and vulnerable segments of the population.

17. Cyclone Kenneth in April 2019 damaged a total of 11,867 houses including 4,854 houses made of sheet‐metaland/or straw that were destroyed and 7,013 concrete houses that were partially damaged. The impacts demonstratedthat the housing sector is highly vulnerable to natural hazards, especially cyclones and floods. Vulnerability can beexplained by (i) the limitations or lack of territorial/urban management and planning tools; (ii) a major number of housesmade of precarious materials; and (iii) the absence of resources and mechanisms to enforce the construction‐relatedcodes. It is estimated that 50 percent of the population live in precarious housing which corelates with the poverty rateof the country.31 The Cyclone‐induced damages were caused by strong winds and flooding to houses mostly built withlittle or no safety or quality standards for construction. According to the post‐Kenneth Damage Assessment, the share ofrecovery and reconstruction needs is the largest in the housing sector, amounting a total of US$87.6 million.18

18. Without a robust institutional, regulatory and governance framework for the housing sector, it was challengingfor the Government to develop a housing reconstruction strategy right away and provide immediate assistance to thefamilies who lost their homes. Most affected households were observing Ramadan when the Cyclone hit, and theirpriority, was to rebuild as fast as possible, regardless of cost or quality. This was often done with second‐hand materialand using the same or worse building techniques and mobilizing resources from their own savings or from the diaspora.A remarkable display of solidarity was partially a reflection of a low level of expectations for assistance from the system.This has its limitations and risks, highlighting (i) the need to support households who may have been left aside, livingbelow the poverty line and/or not benefitting from any external support; (ii) the potential long‐term impacts onhouseholds even if they received some help from their communities; and (iii) the need for resilient reconstruction ofhousing. In addition, since the Comorian social system is matriarchal (the man joins his wife's home after marriage), mostof the destroyed houses belong to women, even as women may have fewer rights given the patchwork of land ownershiplaws under the religious, civil and customary codes.

C.2. Critical Public Infrastructure

19. “Infrastructure” in the UoC and according to the division of responsibilities of line ministries, refers to criticalpublic infrastructure associated with transport and public works. MLUUP is responsible for the construction and qualityof transport infrastructure and more broadly of public works. These include public buildings, dykes and coastal protectioninfrastructure. It is also responsible for developing and ensuring application of construction codes and norms.

20. Cyclone Kenneth exposed the vulnerabilities of critical public infrastructure, especially that located on thecoastline and exposed to sea‐level rise and coastal erosion. The infrastructure sector – one of the most vulnerablesectors in the country – was the third most‐affected. Most assets and national roads, in particular, are concentratedalong the coasts and are continually eroded and subject to storm surges and marine intrusion. Additionally, insufficientdrainage of road surfaces and poor overall maintenance cause accelerated degradation. The risks of climate change werenot generally integrated in the selection of construction materials and techniques, design and geographic location of theinfrastructure in the GoC’s development programs, including for dykes. Damages and losses are estimated atUS$21.1 million and recovery and reconstruction needs at US$34.1 million. Cyclone Kenneth has served to raiseawareness and the country is committed to introducing a climate‐resilient approach.32 Restoring and strengthening thiscritical infrastructure is key because of (i) the potential destruction and irreversible loss of some stretches of thecoastline, which is an imminent threat that the 3 islands are facing; (ii) the UoC economic activity and population is

31 Global Climate Change Alliance. 2018. Evaluation of the economic impact of climate change on the Union of the Comoros. 32 A resilient approach will most likely increase the reconstruction needs looking at the issue in a systemic and multi‐dimension way.


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concentrated along the coast; and (iii) the UoC economy is dependent on transport connectivity. In addition, the analytical work conducted as part of the preparation of the PIDC project highlights the need to complement PIDC localized investments on the regional and rural road network with major rehabilitation works of the primary road network to ensure the flow of agriculture produces – which is the source of employment for 38 percent of total population and represents 36 percent of GDP.21

Coastal Protection Systems

21. The densely populated coastlines of the UoC are threatened by storm surge and coastal erosion and the generalthreat of land loss due to long‐term coastline retreat associated with sea level rise. Climate change influences the returnperiod of high swell events which is reducing and becoming more frequent, and also induces a sea level rise. As a result,coastal erosion — already an ongoing phenomenon in the UoC — is likely to increase in the coming years. In addition,the activities of coastal communities are increasing the vulnerability of the seashore to coastal erosion and itsdeterioration, for instance, the extraction and use of sea sand especially in Anjouan and Mohéli.

22. Cyclone Kenneth also destroyed dykes and coastal protection systems across the three islands. The Cycloneeroded and washed away various stretches of the coastline, destroying roads and dykes and flooding the inhabitants andcommunity buildings (e.g., hospitals, schools) of those affected areas. These include Djoezi in Mohéli, Foumbouni andBandamaji in Grande Comore, and Paje in Anjouan. In some areas, the flooding caused the disruption of clean watersupply because of the contamination of the aquifers, the contamination of the rainwater tanks, and/or the damage tothe pumping systems. in Anjouan, there were major traffic interruptions lasting about a week because of the destructionof a retaining wall along the Mutsamudu‐Sima road (high traffic road between the two largest cities in Anjouan) over a10‐meter section. While the retaining walls and dykes started deteriorating over the last years, mainly due to storm surgeas well as inadequate construction and maintenance, they were not able to withstand the intensity of Cyclone Kennethwhich directly aggravated the conditions of the infrastructure. In some areas, the Cyclone caused full deterioration of theinfrastructure and the environment – endangering some stretches of the coastline and severely affecting in the longterm, the population, economy and environment of the UoC.

23. Rebuilding and strengthening coastal defense systems is key for the archipelago of the UoC in order tostrengthen its resilience to future similar events and against continuous erosion and sea level rise. Cyclone Kennethraised awareness and is introducing a climate resilient approach relying on strong analytics and looking at the issue in amore systemic and multi‐dimension way to provide sustainable solutions. It is fundamental for the Government to adoptthis approach in any infrastructure project on or near the coastline and to prevent poor construction practices andmaterials.

Transport Infrastructure

24. Transport connectivity and infrastructure is critical for the UoC’s social and economic growth and the mainchallenges are the provision of multi‐modal transport services and the need for increased maintenance. The UoC relieson a road network of 815 km including 404 km of national roads, 296 km of regional roads, 61 km of rural roads(unclassified) and 54 km of urban roads. It has three airports (one on each island), three ports (one on each island),several beaches that serve as access points for small boats. The transport responsibilities are split between MLUUP forthe design and construction of the infrastructure, and the Ministry of Maritime and Air Transport (MMAT) for port andairport regulations and operations (land transportation regulations and operations responsibilities remain with MLUUP).The World Bank recently completed a “Spatial analysis of transport connectivity and economic growth potential in the


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Comoros” (June 2019) in collaboration with MLUUP and MMAT and concluded it was critical for the Government to integrate the different modes of transport into a unified system to increase economic efficiency and support the poor.

25. In terms of road maintenance, despite the Government’s efforts since the 1980s to secure dedicated funds in aRoad Fund, maintenance needs are still not being met. The Government made significant road investments during the1980s and 1990s with support from different development partners. It established a Road Maintenance Fund (RMF) in1981 as a revolving fund financed by hydrocarbon product taxes. However, in the early 2000s, the RMF was no longerbeing replenished and the road network deteriorated significantly for the next ten years due to a lack of routine andperiodic maintenance. In 2012, a second generation RMF was set up with the main resources made up of royalty of useon petroleum products which was calculated to provide on average about US$1.7 million per year. However, this amountgradually decreased year by year and in 2014, about 60 percent of the total road network was found to be in poorcondition.33 In 2019, a Road Fund was established to replace the RMF with the objective of expanding its functions toinclude dedicated funds for rehabilitation and construction.34

26. Cyclone Kenneth in April 2019 affected all three transport subsectors, impeding commuting, freight movementand economic recovery. The Cyclone affected about 62 km of the primary road network, 16 km of regional roads and12 km of rural roads, primarily in Grande Comore and Anjouan. On the coastline, parts of the roads network remainhardly accessible. Port facilities were affected in all three islands. Mohéli’s “maritime access” was heavily damagedwhereby the swell destroyed the concrete‐block arrangement (weighing 2.5 tons each) protecting the wharf. In Moroniin Grande Comore, the concrete anchor blocks for oil tankers were dismantled and pilot boats destroyed. In Anjouan,the oil wharf of the National Oil Company was also severely damaged. Airport infrastructure and equipment weredamaged due to strong winds and/or flooding, leading to the disruption of the airport communication systems and thesuspension of the air traffic in Grande Comore for a few days switching to alternative, less sophisticated systems. InAnjouan the baggage control system was damaged. Recovery and reconstruction needs for the rehabilitation of transportinfrastructure were estimated at US$29 million.

27. The road network on some key sections has been heavily disrupted by Cyclone Kenneth, if not destroyed,isolating affected people from their sources of revenue and from public services such as health. Some of the priorityroads of the primary network of the National Master Plan for Road Transportation (Plan Directeur National du TransportRoutier, PDNR 2015‐2025) suffered severe deterioration since Kenneth and now require full rehabilitation. TheGovernment has not secured any financing for these, nor for the sections that were already under rehabilitation prior toCyclone Kenneth which now need further upgrades to strengthen the design and resilience to extreme climate events.For the latter, the Government is in discussion with the donors involved to try to secure increased aid. For the former,they are short of financing for: (i) Mtsangadjou‐Ouroveni in Grand Comore (approximately 26 km with the Mtsangadjou‐Mohoro section in critical conditions); and (ii) Mremani‐Domoni in Anjouan (approximately 13 km).

C.3. Emergency Management and Disaster Risk Management

28. Despite progress over the last ten years in strengthening the national DRM system, there are still someinstitutional capacity challenges that translate into a risk management approach that is more focused on emergencymanagement rather than on an integrated risk management in the territorial and sectoral development. DRM in theUoC is currently institutionalized under the National Platform for Disaster Risk Reduction (NPDRR) that was created in2010. The DGSC under MOIDTA is recognized as the main governmental body in charge of disaster management. Its

33 Government of the Union of the Comoros (2015) National Master Plan for Road Transportation. 34 Decree N°19‐025 of January 31, 2019 on the creation, organization and operation of the Road Fund.


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operational arm is the COSEP which is instrumental in the coordination and management of the emergency response down to the local level. The Technical Directorate of Meteorology (Direction Technique de la Météorologie, DTM) provides climatic meteorological data and the Karthala Volcanological Observatory (OVK) is responsible for monitoring volcanic activity. However, due to financial and operational capacity constraints, these institutions including the policy framework under the National Strategy for Disaster Risk Reduction (NSDRR, developed and adopted in 2015) are not fully functional or operational.

29. DRM financing mechanisms are not providing adequate support in due time. The annual budget allocated toDGSC is limited and cannot cover emergency response expenses across the three islands (let alone risk reduction andpreparedness activities). Often, disaster response is financed using national budget available at the time of the disaster– with no pre‐planning, and thus limited and to the detriment of other needs, or special budget lines or ex‐post financingoptions.35 Furthermore, the disbursement procedures are found to be too rigid and not adapted to manage emergencysituations, from the perspective of the authorities responsible for emergency interventions.

30. Cyclone Kenneth in April 2019 demonstrated the strengths and weaknesses of the DRM system and the needfor a comprehensive and integrated management of natural disaster and climate related risks. The Government’sactions in view of the Category 3 cyclone forecasts and associated risks were effective and key to limiting the humanimpacts. Information was widely circulated, and evacuation was organized in all three islands. In the aftermath, thenetwork of Government officials and volunteers was active and supported an initial rapid impact assessment. However,these critical actions were insufficient as a basis for longer‐term recovery planning. For example, the data remains limited,processes and structures described in the National multi‐risk Contingency Plan were not fully followed. The Governmentdid not use the NPDRR but rather established an Interministerial committee for disaster management associated withCyclone Kenneth.16 With Comoros’ level of exposure and the increase of the frequency and intensity of natural disasters,the effects of the Cyclone made it clear that the country needs to address DRM in a holistic manner by establishingadequate institutional framework for DRM, proactively managing and reducing existing disaster risks as well aspreventing the creation of new ones through disaster risk‐informed planning and investments. The GoC is committed toimproving its capacity for disaster preparedness, response and recovery.

C.4. Institutional Framework

31. MLUUP is responsible for the housing sector, land use and urban planning, and land management, as well asland transport and flood protection infrastructure. The Ministry has the mandate over Housing and Infrastructuresectors which are the most and third most affected sectors according to the post‐Kenneth Damage Assessment.

32. DGSC under MOIDTA is the key authority responsible for DRM. DGSC and its operational arm COSEP havepresence on the ground and the capacity to coordinate and mainstream DRM in the sectors. They have the mostsophisticated and operational data analysis and GIS center dedicated to risk management and hazard mapping in thecountry, housed in the Information Analysis and Processing Center (CATI).

D. Relevance to Higher Level Objectives

33. The proposed project is aligned with the World Bank Group (WBG)'s Comoros Country Partnership Strategy

35 Such as the line dedicated to natural risk reduction funds in the national budget for 2019 (Loi des Finances 2019, Ordonnance No. 19‐001/PR), or exceptional measure for ex‐post financing such as under Footnote No 20.


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(CPS) for FY14‐19.36 First, this project supports both pillars of the CPS: (i) Pillar 1: increased public service capacity, through the capacity building activities especially in housing and urban planning and in DRM; and (ii) Pillar 2: shared growth and increased employment, through the rehabilitation works especially associated with road rehabilitation and coastal defense systems that will benefit entire communities (not just those directly affected by the Cyclone) and create job opportunities. These strategic priorities are aligned with the Government’s Poverty Reduction and Growth Strategy Paper (PRGSP) and contribute directly to the objectives of reducing extreme poverty and increasing shared prosperity in Comoros. Secondly, the project will contribute to Objective 5 which seeks to improve effectiveness of social safety net and active labor market programs, enhancing, in particular, resilience of the most vulnerable segment of population to shocks. Lastly, activities supporting the improvement of DRM framework and capacity will contribute directly to Objective 6 which seeks to improve the knowledge base and management of natural hazards, disasters and climate risks.

34. The proposed operation is aligned with the WBG’s twin goals of poverty reduction and shared prosperity, the Africa Regional Strategy for Human Capital and Climate Resilience, and the WBG Climate Change Action Plan (2016‐2020). First, the project promotes the achievement of the WBG twin goals by providing support to the poorest and most vulnerable segments of the population and by supporting sustainable and resilient reconstruction maximizing the development impacts and contributing to boosting shared prosperity. Second, the essence of the project is about ensuring social resilience and physical resilience of critical public infrastructure, thereby (i) reducing the poverty impacts of disasters at the household level by reducing losses following a disaster and increasing resilience, including addressing the potential increased risk of gender‐based violence (GBV) in the post disaster setting;37 (ii) ensuring infrastructure resilience and continuity of services therefore reducing disruptions in jobs and productivity; and (iii) saving lives and mitigating the impact of future disasters. Lastly, the project directly addresses climate risks and considers climate change adaptation measures throughout all components, thereby contributing to the WBG Climate Change Action Plan.

II. PROJECT DESCRIPTION

A. Project Development Objective

35. The Project Development Objective (PDO) is to support recovery and increase disaster and climate resilience of select public and private infrastructure in the areas affected by Cyclone Kenneth.

PDO Level Indicators

36. The proposed key results indicators that will be used to measure the achievement of the PDO are:

• Number of people benefitting from houses rebuilt with resilient standards (of which women are heads of household)

• Number of people benefitting from housing reconstruction assistance activities and neighborhood improvements (of which percentage of women)

• Number of people protected with resilient coastal defense system (of which percentage of women) • Number of people benefitting from primary/main road rehabilitation works (of which percentage of women)

36 The CPS FY14‐FY17 was extended to cover FY14‐FY‐19 by Performance and learning review (PLR, Report No. 82054‐KM). 37 A series of studies by the IFRC such as the Global Study “Unseen, unheard: Gender‐based violence in disasters” (2015), “The responsibility to prevent and respond to sexual and gender‐based violence in disasters and crises” (2018), shows risk of GBV rises after disasters, mainly due to a combination of personal loss, loss of social network, loss of livelihoods and limited resources, cramped life of displaced persons living with other family members in limited spaces, increase in alcohol consumption – all of which were identified during the rapid GBV assessment as part of project preparation and could be aggravating factors.


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B. Project Components 37. The proposed project addresses part of the reconstruction needs in the housing and infrastructure sector with the aim to strengthen long‐term resilience of selected affected areas. In addition, the project will strengthen DRM capacities. The project will support interventions in selected areas affected by Cyclone Kenneth across the three islands. The proposed interventions support the priority sectors identified in the post‐Kenneth Damage Assessment that received limited pledges or that no other ongoing development programs can immediately address, and where the World Bank has added‐value. It would particularly support: (1) recovery and resilience in the housing sector; (2) coastal resilience and infrastructure rehabilitation; and (3) integrated DRM. Component 1: Recovery and Resilience in the Housing Sector (US$12.30 million equivalent) 38. This component aims to support the development and implementation of a national housing reconstruction program for the most vulnerable Cyclone‐affected households and the reconstruction of 1,000 houses across the three islands. This includes: a transparent beneficiary selection and prioritization process; large training and dissemination programs promoting safe building standards and practices including resilient housing construction techniques across the three islands, development of resilient housing typology designs, supply of construction materials, TA in construction, supervision, quality control ensured through an inspection/certification process at each stage, securing permits and land titles, and incentives for contributions from households (e.g. unskilled labor). These activities require identifying short‐term solutions such as development of technical guidelines for resilient housing construction and creation of Housing Committees who will play a critical role in expressing the voice of the community. In parallel, the component will also support institutional strengthening (e.g. preparation of urban development and housing policies, legislation and regulations) to develop longer term resilience in the housing sector. Under this programmatic approach, the Government would be able to continue implementing the housing reconstruction program for more vulnerable households affected by Cyclone Kenneth as additional sources of financing are secured (beyond WB project funds).

Subcomponent 1.1: Supporting housing reconstruction (US$11.60 million) 39. This intervention aims to support the recovery of selected vulnerable communities affected by Cyclone Kenneth through the resilient reconstruction of houses and small community‐based infrastructure. This component will support the financing of the reconstruction of 1,000 housing units for an estimated 6,100 Cyclone‐affected beneficiaries,38 with a resilient reconstruction approach, a strong community engagement and mobilization with a comprehensive communication strategy, a technical training program and dissemination strategy reaching over 75,600 people, as well as relevant TA activities to ensure transparency and fairness in the process, quality control, adequate environmental and social (E&S) management, and support to community planning. Government will define and provide a Housing “assistance package” to eligible homeowners for reconstruction. It will involve inter alia material and provision of construction firm services. The process will be designed to support the most vulnerable households and include as many beneficiaries as possible in the housing reconstruction program. A Housing construction manual will be developed to describe the approach, the selection process, the reconstruction process, all related procedures and implementing arrangements. 40. The beneficiary selection process will be designed to support the most vulnerable households. Drawing on

38 Based on a household average size of 6.12 (World Bank, 2017, Comoros Poverty Assessment)


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existing data and a preliminary set of criteria developed by MLUUP, the project will target households with owner‐occupied homes,39 built of precarious materials and destroyed by the Cyclone. Households who have been displaced and/or led by a woman, or those households with elderly or disabled persons or children under 5 will be prioritized. The Government is setting up an inclusive mechanism to strengthen and validate the data and selection criteria to arrive at a prioritized list of beneficiaries. This mechanism will integrate the voice of the local community through the participation of the Housing Committees and the strategic principles of the reconstruction program such as rebuilding houses on all three islands, concentrating investments in a given location rather than dispersing them (across an island), coordinating with the Social Safety Net Project.40 The PIU will update and maintain the database accordingly and will develop a prioritized list of beneficiaries with close support and advice from the Housing Committees throughout the process. MLUUP will validate the final list. Finally, the project will not finance reconstruction in high risk areas (e.g., flood prone area) or requiring involuntary resettlement.

41. The construction would be implemented through a hybrid approach involving community‐based constructionas well as technical support from a Delegated Project Management Entity or “Maître D’Ouvrage Délégué” (MOD orDPM), NGOs, UN agencies, and/or consultants. The MOD would be in charge of the coordination and implementation ofreconstruction subprojects and associated contract supervision and management, communication and outreach, qualitycontrol including compliance with E&S management framework, support to beneficiaries and community planning,housing assistance packages delivery to beneficiaries. In addition, to ensure beneficiary ownership in the reconstructionprocess, beneficiaries will provide in‐kind contributions either in cash or labor or materials, post‐constructionmaintenance, etc. (to be defined). Where a vulnerable household may not have financial means nor the physical capacityfor manual work, the Housing Committee would work with the community to support these members. Where non‐beneficiary households have the resources to build their own core safe house, and where beneficiary households havethe resources to build beyond the core safe house during project implementation, they could have access to TA to do sousing resilient construction techniques.

42. More specifically, this subcomponent will provide:41

(A) support to the Recipient and MOD for the reconstruction of housing units through:(i) relevant TA activities to ensure that the reconstructed house is more resilient and designed to be climate andearthquake resilient inter alia: (a) surveys and technical studies to help validate and finalize the housing database;(b) definition of selection criteria and procedures; (c) communication and outreach; (d) design of a core safe housetypology, which would also consider resource‐efficiency aspects (e.g., energy‐efficient); (e) strengthening of riskunderstanding and general guidance on resettlement needs; (f) training of builders including engineers of theMinistry and municipalities, community members and Beneficiaries on the content and use of safe constructionstandards and practices and associated technical guidelines; (g) implementation of the E&S managementframework including identified safeguard mitigation measures and the creation and implementation of conflict‐resolution mechanisms related to housing reconstruction activities; (h) quality control and supervision of housingreconstruction activities; (i) support to community planning activities; and (j) technical studies;

(ii) Housing assistance package to selected Cyclone‐affected Beneficiaries through the provision of materials andthe hiring of contractors under the supervision of MOD;

(B) support for the rehabilitation or construction of community infrastructure within the selected communessupporting neighborhood improvements including inter alia small roads/walkways and associated drainage, public

39 From the existing data on households whose houses were destroyed, the ratio of owner‐renter is estimated at about 90‐10. 40 Additional financing to the Social Safety Net Project P150754 financed by the World Bank (additional financing to be approved on December 18, 2019). 41 With indicative envelopes of approximately US$9.30 million for the reconstruction/construction works and US$2.30 million for all supporting activities.


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spaces (e.g. parks), small recreational infrastructure (e.g. sport), and solar panels. They will be selected based on the community development planning work supported by the MOD. They are expected to benefit over 127,800 people and to be built in an inclusive manner;

(C) support to the establishment of the Housing Committees: the Government prepared terms of reference that define

the tasks of the Housing Committees (through MLUUP ministerial order) to support implementation of a housing reconstruction program. The Committees will be represented in each commune of intervention and be composed of municipal staff, community representatives ensuring inclusion of women, vulnerable groups’, as well as religious and local leaders. The Committees will serve as a consultative platform and will play a central role in community mobilization and engagement in project activities’ implementation, including on beneficiary selection criteria, support to community mapping and planning for neighborhood improvements and infrastructure maintenance plan, support to land ownership formalization processes. The project will finance the operational costs associated with the facilitation work conducted by the Committees.

Subcomponent 1.2: Strengthening the urban system and construction standards (US$0.70 million) 43. This subcomponent aims to strengthen and develop territorial and urban planning and management tools tackling neighborhood development, housing, land, zoning and construction. TA and support will be provided primarily to MLUUP and relevant Government officials to strengthen the country’s capacity in territorial planning and management including on natural and climate disaster risks and enforcement of existing urban legislation. This TA is critical to address in the long‐term structural issues that influence the vulnerability of the population and physical assets, and that usually hold up quick housing recovery following a natural disaster. Centered around reducing vulnerability, increasing resilience, and creating an enabling environment for housing programs, support could include inter alia: (i) review and drafting of regulations (e.g. housing related), ministerial strategies, planning instruments (e.g. master regional development plan, urban development plan at the municipal level), with due consideration to gender dynamics and GBV concerns in any work supporting housing, land and property policies; (ii) strengthening of institutional, technical and operational capacities in territorial/urban planning and management and enforcement of urban legislation, including construction standards; and (iii) support to the mapping units and laboratory of building and public works attached to MLUUP. Component 2: Coastal Resilience and Infrastructure Rehabilitation (US$23.64 million equivalent) 44. The Cyclone highlighted the vulnerability of infrastructure and settlements to coastal erosion and flood risks and more broadly to natural and climate disaster risks. This component aims to strengthen coastal defense in selected vulnerable stretches of the coastline affected by the Cyclone, e.g. in Foumbouni in Grande Comore; and rehabilitate critical sections of the primary road section going through Foumbouni. It also includes a TA component to introduce accompanying measures to the investments to increase resilience and road safety.

Subcomponent 2.1: Coastal resilience and infrastructure rehabilitation (US$23.24 million)

45. This subcomponent will finance resilient coastal defense works in selected areas affected by the Cyclone (indicative envelope of approximately US$15.14 million). Various stretches of the coastline were eroded and washed away by the Cyclone, putting at risk over 25,800 local residents, their houses, and critical public infrastructure including hospitals and national roads. These include for instance Foumbouni in Grande Comore; Djoezi, Fomboni and Nioumachoua in Mohéli; and Pajé in Anjouan. These sites are highly populated, economically active and located along national roads which in some cases such as in Anjouan, are built against the mountains, leaving no room to be shifted


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inland. The objective is to identify the most affected stretches of the coastline that are subject to potential irreversible loss of land and where there are engineering solutions that can protect efficiently and in the long term the population and infrastructure. The project will finance: (a) a comprehensive detailed diagnostic study to better understand the flood risks and erosion phenomenon on the

three islands, assess the feasibility and cost for undertaking coastal defense works, propose resilient and efficientsolutions including nature‐based solutions along with multi‐criteria decision‐making tools for MATU to select priorityinvestments. Preliminary estimates indicate that the project could finance coastal protection works for up to 2.5‐3 km total of linear of coastline;

(b) detailed design studies for the selected investments;(c) works and associated supervision services. The works could include a mix of infrastructure combining rehabilitation

or construction of retaining structures, barriers, drainage systems, breakwaters, hydraulic structures such as groins,etc. and other nature‐based techniques such as beach reprofiling.

46. This subcomponent will also support the rehabilitation of selected sections of the primary road betweenMtsangadjou and Ouroveni going through Foumbouni in Grande Comore (indicative envelope of approximatelyUS$8.10 million). This 26 km road, stretching across the two national roads RN2 and RN3, was damaged by the Cyclonewith the most severe impact and deteriorated conditions on the RN2 section between Mtsangadjou and Mohoro (about13 km). The project will finance the rehabilitation works on this RN2 section, but it will provide technical studies for the26 km road with proposals to prioritize and do rehabilitation works on the most deteriorated sections between Mohoroand Ouroveni within the budget available. Preliminary estimates indicate that about 14 km total of road could berehabilitated, benefiting over 6,800 residents. All road works will be designed and done in a climate resilient manner totake the increasing frequency and severity of cyclones and rainfall conditions into account. Interventions will include,inter alia, resilient rehabilitation or reconstruction of hydraulic structures, rehabilitation of pavement, drainage system,and road safety measures.

Subcomponent 2.2: Technical assistance (US$0.40 million)

47. This subcomponent aims to strengthen resilience in planning and building of infrastructure. It will financeactivities towards: (i) support to implement non‐structural measures identified in the diagnostic study carried underSubcomponent 2.1; (ii) assessment and strengthening of the institutional framework around integrated coastalmanagement; (iii) support for improving budget planning and financial resources mobilization for routine, periodic, andemergency road maintenance; (iv) road safety assessment and support to implement associated measures on projectroad works site; and/or (v) awareness raising and educational campaigns to promote inter alia good practicescontributing to making coastlines more resilient to disasters and climate change, road safety.

Component 3: Integrated Disaster Risk Management and CERC (US$6.06 million equivalent)

Subcomponent 3.1: Supporting emergency response (US$5.00 million)

48. This subcomponent aims to support the Government’s response to Cyclone Kenneth including the rescueprevention measures and early recovery of key economic sectors from the impact of the Cyclone, through the provisionof goods, technical advisory services and emergency operating costs. It will finance expenditures incurred by theGovernment as preparation (for the imminent threat of the Cyclone) and response to the Cyclone. Emergency operatingcosts would include, inter alia transportation costs (e.g., gasoline and use of other transportation) associated with pre‐Kenneth preparation and post‐Kenneth response coordination, rental of equipment (e.g., lights and generators to ensure


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continuity of critical services such as hospitals and schools that lost power and/or were flooded) and machines (e.g., to clear access roads, remove trees, debris, electric poles, evacuate people), urgent communication system repair. The funds under this subcomponent will allow the GoC to recover expenditures incurred in the preparation and following the disaster. Goods, services and operating costs under this subcomponent will be financed retroactively and the eligibility of the expenditures will be determined based on review of satisfactory supporting documentation presented by the Government, including adherence to appropriate procurement practices where applicable. All supporting documents for such expenditures will be verified by the Project Implementation Unit (PIU), certifying that the expenditures were incurred for the intended purpose and to enable a fast and effective recovery of the country post‐Cyclone Kenneth.

Subcomponent 3.2: Strengthening integrated DRM (US$1.06 million)

49. This subcomponent will strengthen the capacity of the Government to manage and respond to disasters throughthe following. A total of 1,200 people across the three islands are expected to be trained in Disaster Risk Reduction (DRR).Specifically, assistance will be provided in the following areas:(a) Improving governance in DRR, primarily through supporting the implementation of the Government’s DRM

framework (e.g. implementation of the Action Plan of the National Strategy for DRR, focusing on DRR training anddisseminating the National Strategy for DRR to key national and subnational stakeholders, communities, womengroups and youth; strengthening the National Platform for DRR in terms of logistics, training and establishment ofprofessional networks), and through a better understanding and consideration of GBV and sexual exploitation andabuse risks and sectors concerned in emergency and post‐disaster situations;

(b) Improving emergency preparedness capacity, mainly enhancing DRR operational and technical capacities of DGSCand other key institutional stakeholders (e.g. updating emergency response plans, communal safety plans, andevacuation plans, educating institutional stakeholders, harmonizing multi‐sectorial damage and loss evaluationmethods);

(c) Improving understanding of hazards and risks (e.g., updating multi‐risks georeferenced databases, coordinatingstudies to inform land use planning and DRR activities supporting the objectives of Components 1 and 2, traininglocal stakeholders in associated risk assessment methods).

50. Activities will complement existing initiatives supporting DRM in the UoC, especially the on‐going UNDP DRMprogram.42 It will also build on the lessons learned from the post‐Kenneth Damage Assessment, as well as on the Capacityfor Disaster Reduction Initiative (CADRI) review which consisted in a DRM capacity assessment in UoC, identifying thegaps in the legal and institutional framework, as well as the gaps in terms of human resources, technical and operationalcapacities.

Subcomponent 3.3: Contingent Emergency Response Component CERC (US$0.00 million)

51. The CERC is a zero‐dollar subcomponent that can provide immediate response to an eligible crisis or emergency.It remains dormant until formal activation. Once activated, this component will allow redistribution of uncommitted andundisbursed funds from one of the project components to this subcomponent to finance emergency/recovery needs incase of an eligible crisis or emergency. Specific details around this subcomponent (including activation criteria, eligibleexpenditure, and specific implementation arrangements) will be defined in a CERC Operational Manual that will requireno‐objection from the World Bank and adoption by the Government before it can be activated.

42 “Strengthening Comoros Resilience against climate Change and Variability Related Disaster” project, implemented by DGSC under MOIDTA with Green Climate Fund (GCF) financing.


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52. The main Government counterpart for Component 3 is DGSC.

Component 4: Project Management, Risk Management and Monitoring and Evaluation (US$3.00 million equivalent) 53. This component will support the implementation of all project activities. It will finance the establishment and capacity building of the PIU within the implementing agency, covering project management, technical, fiduciary (procurement and financial management (FM)), E&S capacities. It will support consulting and non‐consulting service costs, training, operational costs, limited goods and small works, as well as resettlement planning and implementation, and community development initiatives. project management, monitoring and evaluation (M&E) entails inter alia preparation of project reports, including for project mid‐term review and project completion, baseline studies, audits (financial and technical, environmental, social as needed). This component will support tailored training and capacity building activities in order to strengthen the implementation of all components. 54. Part of the E&S responsibilities will include: (i) assessment and M&E of the potential social impact of the reconstruction activities on tenure rights, and (ii) ensuring adequate resources to ensure gender mainstreaming in the annual workplan and budget, regular monitoring of sex‐disaggregated data, citizen engagement including inclusive participation of women and vulnerable groups. Recognizing that there is a moderate risk of GBV in the project areas, the project will develop an approach based on the World Bank’s ‘Good Practice Note for Addressing GBV in Investment Project Financing (IPF) involving Major Civil Works’. The project will carry out an assessment of GBV risks and groups at risk and development/implementation/monitoring of activities to prevent and mitigate GBV including Sexual Exploitation and Abuse (SEA) risks linked to post‐disaster situations potentially,37 and to project civil works sites (more details can be found in Section C). The activities under (ii) and supporting GBV/SEA prevention and response would be implemented with support from specialized NGO(s) with experience in working on GBV matters in the UoC.

Table 1 – Project Components and Estimated Amounts

Component Cost (US$ million) Share between IDA grant and credit

Component 1: Recovery and Resilience in the Housing Sector 12.30 50‐50

Subcomponent 1.1 Supporting housing reconstruction 11.60 50‐50

Subcomponent 1.2 Strengthening the urban system and construction standards 0.70 50‐50

Component 2: Coastal Resilience and Infrastructure Rehabilitation 23.64 50‐50

Subcomponent 2.1 Coastal resilience and infrastructure rehabilitation 23.24 50‐50

Subcomponent 2.2 Technical assistance 0.40 50‐50

Component 3: Integrated DRM and CERC 6.06 50‐50

Subcomponent 3.1 Supporting emergency response 5.00 50‐50

Subcomponent 3.1 Strengthening integrated DRM 1.06 50‐50

Subcomponent 3.2 CERC 0.00 50‐50

Component 4: Project Management, Risk Management and M&E 3.00 50‐50

TOTAL 45.00 50‐50


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C. Project Beneficiaries

55. The proposed investments and activities will target vulnerable populations in selected areas affected by CycloneKenneth. The proposed project components are designed to target some of the most vulnerable households, affected asa result of flooding from both torrential rains and storm surge, and cyclone winds, and who lost their homes inland andalong the coast for some. Beyond the individual households, the project will benefit the communities where investmentsare made, through the community‐based infrastructure, coastal defense measures, the road rehabilitation works. Theproject also finances capacity building activities carried out at both the central and local level, which will benefitGovernment officials, civil servants, local technicians, masons, carpenters, builders, engineers, architects, andcommunities. All the activities will be carried out with the objective of increasing the resilience of communities againstcyclones and natural disasters. In total, the project will target 243,300 direct beneficiaries. In addition, an estimated300,000 people will indirectly benefit from project investments through the reinforcement of coastal defense systems ineach island and the links of critical road sections to Chindini’s maritime access in Grande Comore (connecting passengersand goods to/from Mohéli). Finally, the impact of the project could be leveraged to reach additional direct beneficiariesif the Government can attract additional financing from development partners and scale up the investments followingthe housing reconstruction framework and the investment plan for coastal defense, both supported by the project.

Considerations on bridging the gender gap

56. The project will contribute to closing the gender gaps identified during the rapid screening that was carried outduring project preparation. It will also build on the existing strengths of women groups and leverage those strengths.The rapid screening identified a gap in participation in the public sphere and decision‐making processes when it comesto project planning and implementation and in income generating opportunities; and the need to protect women’s rightssuch as land tenure and usufruct rights, and from gender‐based violence. The following actions are considered – andwould be strengthened by the results and recommendations from a more substantial gender gap assessment focused ondisaster and recovery.

57. Enhancing women’s participation in the public sphere and planning for reconstruction and recovery. In the UoC,women hold informal power within communities and are at the forefront of social change. For example, in the aftermathof the Cyclone, more than 800 women had mobilized to organize cleaning campaigns in Mohéli.43 However, thetraditional system tends to exclude women from formal decision‐making processes and women are not allowed to accessthe public squares where men make decisions on village affairs. Despite having ratified the Convention on the Eliminationof all Forms of Discrimination against Women, the UoC continues to suffer from underrepresentation of women in allspheres of political and socio‐economic activities. Heads of villages positions are traditionally held by men. Currently,mayor positions are held by men at a 90 percent ratio. Female representation in national‐level politics remains very lowas well. Women hold only two parliamentary seats despite increasing numbers of female candidates and the country isranked 179 out of 190 for female representation in government by the Inter‐Parliamentary Union.44 The project will workto increase representation and participation of women in post‐disaster activities by: (i) involving women’s groups in theproject to ensure women’s feedback and concerns are reflected in the decision‐making process for the reconstructionand recovery activities (e.g., beneficiary selection criteria, housing design and construction, community planning andselection of priority community infrastructures for neighborhood improvements such as street lighting which wouldincrease security level especially for women at night, road rehabilitation, dykes, etc.); (ii) ensuring the membership ofHousing Committees include female representatives of the local women’s groups so that women are meaningfully

43 Government of the Comoros. Lessons Learned from cyclone Kenneth, 2019. 44 Inter‐Parliamentary Union, Women in Politics, 2019.


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represented in the consultation and decision‐making processes; (iii) giving dedicated DRR training to women to strengthen emergency preparedness capacity. The project will use two intermediate results indicators to monitor (a) the percentage of female representatives in the Housing Committee participating in the project; and (b) the number of women trained in DRR.

58. Enhancing women’s income generating opportunities. There are gender differences in labor market participationrates, the nature of employment, as well as in education in the UoC, that the project will intentionally aim to reducethroughout implementation. According to the Comoros Poverty Assessment (2018), only one‐third of women are in thelabor force, compared to an activity rate of 57 percent for men. There are also relatively large disparities between menand women in education, with 47 percent of women in the uneducated labor force compared to only 36 percent of men.Women also seem to be over‐represented compared to men in self‐employment and informal trade activities, while thelatter seem to have better access to wage employment. In addition, data show that women’s wages seem to suffer froma “marriage penalty”. For married men, the average wage increases from US$1.67 (average wage for single men) to 1.73.By contrast, married women earn on average US$1.45 versus 1.64 for single women.7 The project will intentionallypromote women’s participation in infrastructure rehabilitation and construction activities (housing, communitiesinfrastructure, roads, dykes, etc.), through gender sensitization of contractors and of the PIU, outreach activitiesregarding reconstruction job opportunities and trainings that target women (e.g., through local women’s networks andevents) and by requiring a quota for women in the bidding documents for contractors (while ensuring women areprotected from harassment and exploitation on the jobsite). The project will provide skill trainings for prospective womenin operation and administration located in the intervention areas of the project. The project will use an intermediateresults indicator to monitor the number of local job opportunities created by the project of which women arebeneficiaries, fostering their participation and leadership as much as possible and at all levels.

59. Targeting female‐headed households under the housing component and improving land tenure security. Thenumber of female‐headed households has increased in the UoC: from 21.5 percent in 2004 to 27.8 in 2014.7 Female‐headed households comprise an average of 3.9 dependent individuals whereas male‐headed households have an averageof 3.4 dependent individuals. Many female‐headed households rely on remittances as the only source of income.Additionally, the percentage of number of households headed by a single woman (single, divorced or widow) is40.2 percent compared to 2.8 percent of households headed by a single man.45 The 2012 Demographic and Health Surveyshowed that 59 percent of women own land, compared to 42 percent of men.46 Although women generally inherit landand houses according to custom, they do not always have usufruct rights, which tend to go to their husbands, maternaluncles, or brothers. In post‐disaster contexts, housing reconstruction, land titling and ownership claims bear importantgender dimensions. The legal ownership, affordability, accessibility and security of land for women will be prioritizedunder the housing component of the project which also has as part of its selection criteria support to female‐headedhouseholds. The project will maximize women’s access to land tenure rights by: (i) establishing procedures for priorregistration of houses and land ownership that considers both male and female owners while helping the reconstructionprocess; (ii) improving women’s awareness about the benefits of registering a land title; (iii) setting up an accessiblefeedback and grievance redress mechanism to address land‐titling processes. The project will use an intermediateindicator to monitor the number of female‐headed households who rebuilt their houses (baseline of 0 and target of 400).All of these women are expected to have security of tenure through obtaining a land title certificate at the end of theprocess. While the baseline value is the same for male‐headed households, this intervention will prioritize female‐headedhouseholds and improve land‐tenure for female‐headed households given the fact that a transparent andnondiscriminatory gender provision for the beneficiary selection processes will be put in place.

45 Green Climate Fund, Gender Assessment FPO94: Ensuring climate resilient water supplies in the Comoros Islands, 10 January 2019. 46 UNECA (2017). Comoros Country Profile. Addis Ababa, Ethiopia: UNECA (United Nations Economic Commission for Africa).


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60. Improving GBV prevention and response. The project used the GBV risk assessment tool to evaluate the level of associated risks which has been classified as Moderate. The tool takes into account both (i) the context, and (ii) project‐related GBV risk factors. To complement the data presented hereafter and identify existing gaps in more details with additional recommendations to address the issues, a more in‐depth GBV/SEA risk assessment will be undertaken. The UoC shows moderate prevalence rates of sexual and physical violence, except for child marriage, which is of 32 percent according to UNICEF global databases (2018). The 2012 EDSC‐MICS survey showed that about 11 percent of women aged 15‐49 years had experienced physical abuse, 3 percent of women had experienced sexual abuse, 3 percent of women had suffered sexual violence and physical abuse, and 17 percent of women had suffered at least one form of violence (sexual or physical).47 Although the legal framework to protect women and girls from violence is quite developed, the enforcement of such laws remains an issue. The 2012 Convention on the Elimination of all Forms of Discrimination Against Women (CEDAW) report highlighted the absence of accurate and updated data on reported cases of GBV, as well as at the lack of information on the number of investigations, prosecutions and punishment of perpetrators of violence against women, including domestic and sexual violence. Violence against women is taboo and therefore a culture of silence prevails. An informal national‐level referral pathway was put in place for GBV/SEA victims with support of UNICEF and United Nations Population Fund (UNFPA), consisting of four call‐centers for victims as well as ad‐hoc medical, legal and psychological support. However, there are persistent funding issues and challenges to ensure that qualified staff are servicing the call‐centers and providing adequate medical and psycho‐social support. There is no safe house and a lack of trained personnel on GBV/SEA cases in the judiciary system. The project intends to address potential gaps by providing training, sensitization and monitoring of GBV/SEA in collaboration with other development and humanitarian partners. The project will also address the specific project related GBV risks. Literature shows that natural disasters can exacerbate conflicts around housing, land and property issues and increase GBV.37 Personal loss, loss of social network, loss of livelihoods and limited resources, cramped life of displaced persons living with other family members in limited spaces, increase in alcohol consumption, may contribute to sexual assault, exploitation and violent domestic situations – all of which were identified during the GBV risk assessment and could be aggravating factors. The project will address the specific risks for women on work sites by including specific mitigation measures as part of the site specific Environmental and Social Management Plans (ESMPs) and Labor Management Procedures (LMPs), as experience has shown that the influx of workers can increase GBV risks for communities where civil works are carried out, such as increasing the rates of SEA due to the changing (power) dynamics in communities that may exacerbate already existing harmful gender norms and behaviors including at the workplace. The project will address the increased risk of GBV, specifically SEA; sexual harassment in the workplace; and human immunodeficiency virus (HIV) that may arise from the presence of the project and temporary workers in the project areas.

61. The project will design, implement and monitor mitigation and response measures for potential GBV survivors based on the risk level, including: (a) GBV risk assessment as part of an overall gender gap assessment, and mapping of service providers for survivors of GBV, including formal and informal resources (medical, psychosocial, legal and justice, safety and security, and livelihood opportunities) – the assessment will identify gaps in the existing referral pathway and recommendations to bridge these gaps, which the project could use selectively; (b) operationalization of a grievance mechanism (GM) for registering inter alia GBV cases and providing referrals with a survivor‐centered approach and different entry points to the survivors; (c) training for PIU and other relevant stakeholders to sensitize them on gender and GBV risk prevention and mitigation; (d) sensitization of project workers and community awareness on SEA, GBV, referral pathway, code of conduct, and entry points for reporting; and (e) oversight through third party monitoring.

47 2012 Comoros Demographic and Health Survey, Multiple Indicator Cluster Survey, (Enquête Démographique et de Santé et à Indicateurs Multiples aux Comores, EDSC‐MICS).


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62. The project will collect gender‐disaggregated data to design and enhance social benefits or mitigate negativegender impacts where required. Throughout project implementation and typically during the consultation phase and thecivil works, the project will ensure the needs of women are specifically addressed (e.g. safety, hygiene, employmentopportunities for female‐headed households, etc.).

Considerations on Citizen engagement

63. During implementation, the project will use an inclusive and participatory approach, involving stakeholders indesign and planning for implementation. In addition to the gender dimension, vulnerability issues will be factored intothe design and the project will pay particular attention to addressing the needs of vulnerable and disadvantaged groupsin the areas of intervention (such as children, orphans, disabled and/or elderly people). These vulnerable groups areknown to be disproportionally affected by the impact of disasters. Drawing on the data that COSEP/DGSC collected duringthe post‐Kenneth Damage Assessment, as well as following the World Bank’s Disability strategy, the project will ensurethat all the financed public infrastructure are, for instance, accessible to people with disabilities. During projectpreparation, the Government prepared, in consultation with the World Bank, a Stakeholder Engagement Plan (SEP)proportional to the nature and scale of the project and associated risks and impacts which are currently classified asSubstantial. Stakeholder engagement is a critical tool for E&S risk management, project sustainability and success. TheGovernment will seek stakeholder feedback and opportunities for proposed future engagement, ensuring that allconsultations are inclusive and accessible (both in format and location) and through channels that are suitable in thelocal context. The SEP was developed through community consultations and is disclosed in‐country and on the WorldBank website.

64. The SEP establishes a clear roadmap for stakeholder analysis, engagement, participation planning andmonitoring. Preparation of the SEP involved initial consultations with the communities and different groups who couldpotentially be impacted by the project (including women’s groups, people living with disabilities), institutionalstakeholders such as governmental and international organizations’ representatives, as well as non‐governmentalorganizations’ representatives. These included women’s groups working on GBV and gender issues in general. The SEPitself depicts a stakeholder analysis addressing different themes such as gender dimensions, vulnerable groups,stakeholder engagement planning, resources required and implementation responsibilities, GM, and participationmonitoring. SEP planning requires the identification of project staff responsible for stakeholder engagement, capacity‐strengthening activities, engagement, information‐sharing and consultation methodologies, participation schedule, andconsultation feedback.

65. More specifically the project will support citizen engagement activities, including: (i) developing detailedprocedures for management of grievances through a project GM (including incidents of GBV and SEA), awarenesscampaigns as part of the stakeholder engagement activities for sensitizing the general public on the opportunity forregistering grievances; and (ii) developing gender sensitive citizen monitoring committees to assist with receivingcomplaints from the communities.

D. Results Chain

66. The proposed Theory of Change is as follows:


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Figure 3 – Project Theory of Change


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E. Rationale for World Bank Involvement and Role of Partners

67. Recovery and reconstruction needs associated with Cyclone Kenneth far exceed the Government’s ability torespond and the financing gap to date remains substantial. The post‐Kenneth Damage Assessment estimated recoveryand reconstruction needs at US$277.5 million and identified a financing gap of US$227.2 million, after deduction ofcommitment from the national budget, other development partners, contributions from households and from the privatesector. Cyclone Kenneth exhausted very rapidly the limited annual budget allocation for contingent expenditures, forcingthe Government to adopt exceptional ex‐post financing options such as retaining civil servants’ share of salaries for themonths following the Cyclone. The proposed IDA response totals US$73 million including a CRW allocation ofUS$45 million to support the proposed project, and up to US$28 million from ongoing IDA operations and uncommittedIDA18 performance‐based allocations supporting the agriculture, fishery, social protection, nutrition and health sectors.The proposed project is critical in the overall Government’s response to the disaster towards the population. It is also thefirst investment project of this scale in the housing sector as well as for coastal protection in the UoC.

68. Through this engagement in the Comoros, the value added of the World Bank is threefold. First, it provides amuch‐needed financing to critical sectors in selected areas affected by the Cyclone while strengthening DRM and urbanresilience at the national and local level. Second, the World Bank can leverage additional financing by supporting aframework approach (e.g. housing reconstruction program, coastal defense investment plan) and by using its conveningpower and facilitating the sharing of knowledge and solutions to the benefit of the UoC. Third, financial assistance fromthe World Bank comes with TA through the project directly and also through intensive implementation support to helpthe Government achieve the PDOs.

69. The project requires close and sustained collaboration with donors and development partners. The proposedproject is designed based on extensive collaboration and constant consultation with development partners who areactive in the UoC. It is a multi‐sector project that addresses the Government’s priorities and aims to complement otherexisting initiatives and programs and to provide support in complex areas where the financing gap is close to 100 percent(e.g. housing requiring US$87.6 million). The project will continue coordinating with the development partners and workon areas of collaboration, to ensure alignment, complementarities and synergies. They include (i) the UN agencies inparticular United Nationals Development Programme (UNDP) and UN‐Habitat, especially on the housing and DRMcomponents; (ii) the AfDB, the delegation of the European Union (EU), and other bilateral agencies, on the roadcomponent; (iii) the French Development Agency (Agence Française de Développement, AFD) especially on the urbanplanning aspects. It will also coordinate with the different regional initiatives such as the Indian Ocean ones, CADRI andthe Japan International Cooperation Agency (JICA) financed ones, focused on DRM and essential public services (wastemanagement, health, education).

F. Lessons Learned and Reflected in the Project Design

70. The project design draws on key lessons learned from previous World Bank and donor financed operationsworldwide, particularly in the realm of FCV,48 and emergency contexts.

71. Simple design and streamlined implementation arrangements need to be privileged especially in lowimplementation capacity contexts. Lessons learned from previous operations especially in FCV recommend keepingdesign and implementation arrangements as simple as possible. In addition, implementation capacity can be

48 World Bank. WBG Assistance to Low‐Income Fragile and Conflict‐Affected States. An Independent Evaluation. 2014.


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strengthened by using MODs for the implementation of infrastructure subprojects. This implementation approach, which combines oversight through a Government agency with on the ground implementation by MODs, combined with community outreach efforts during implementation has proven to be a realistic and effective way of delivering results in a challenging environment. MODs have been successful in complementing the technical capacity of Government implementing agencies and can provide a more hands‐on approach to project communication and outreach and citizen engagement. 72. Using a programmatic approach effectively prioritizing actions and sequencing interventions contributes to ensuring the development of a sustainable state structure. This approach maximizes efficiency and development impacts. In a context of FCV situation, interventions need to put greater emphasis on understanding the contextual realities and paces the Project realistically. In parallel, the provision of TA can strengthen capacities for long‐lasting impacts, contributing to the development of knowledge and its operationalization, as well as to speeding up project implementation. 73. Promoting community‐based approaches and inclusive community participation is essential for an effective reconstruction process and for sustainability. The World Bank has in various instances financed projects engaging directly community‐based organizations promoting a culture of learning by doing in providing skills trainings improving collective actions beyond the life of the project. Integrating customary practices and community engagement and mobilization can reduce conflict, confusion and cost. Past experience including in Nepal, Indonesia and Haiti after mega‐disasters demonstrates how essential and effective community organizing and participation is in reconstruction processes. Additionally, the participation, engagement and role of women particularly stood out in these instances, in project design and implementation and as beneficiaries. An effective communication strategy is key to manage expectations and ensure a broad outreach to expected beneficiaries.

74. The use of non‐traditional structures is an effective way to deliver social services in countries with weak Governmental capacity, as is the provision of intensive community support during the design, selection, construction and maintenance of community infrastructure, especially for the sustainability of the investments. The project draws lessons from the Comoros Services Support Project (P084315, P100804, P114740). The “non‐traditional” structures considered under the proposed Project to support the implementation of the housing reconstruction program are the Housing Committees and the MODs. The approach is a hybrid approach involving community‐based construction as well with significant training and capacity‐building activities. The project would also benefit from technical support from UN organizations and/or specialized NGOs.

75. Key lessons learned from housing reconstruction programs worldwide were captured into a Handbook published by the World Bank and applied to the Project.49 The guiding principles for housing reconstruction after natural disasters are: (1) a good reconstruction policy helps reactivate communities and empowers people to rebuild their housing, their lives, and their livelihoods; (2) reconstruction begins the day of the disaster; (3) community members should be partners in policy making and leaders of local implementation; (4) reconstruction policy and plans should be financially realistic but ambitious with respect to DRR; (5) institutions matter and coordination among them improves outcomes; (6) reconstruction is an opportunity to plan for the future and to conserve the past; (7) relocation disrupts lives and should be kept to a minimum; (8) civil society and the private sector are important parts of the solution; (9) assessment and monitoring can improve reconstruction outcomes and (10) to contribute to long‐term development, reconstruction must be sustainable.

49 Safer Homes, Stronger Communities. A Handbook for Reconstructing after Natural Disaster. The World Bank. 2010.


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76. Reinforcing linkages, coordination and synergies across sectors is essential to strategic and optimizedinvestments. Instances of collaboration across the different GPs within the World Bank showed that synergies can benefitstrategic investment in other sectors. In the example of Comoros’s portfolio, the PIDC project was developed acrossmultiple GPs (notably Agriculture, Transport and Digital Development, Macroeconomics, Trade and Investment, andSocial Protection). The proposed project was developed in close coordination with the different GPs and particularlyinclude a transport subcomponent.

77. The strategic use of retroactive financing can bring quick results on the ground and supports effective projectpreparation/implementation and commitment. The World Bank’s recent experiences in complex emergencies and FCVsituations highlight the benefits of using retroactive and advance financing as tools to immediately contribute towardsongoing crises by making this modality available to Borrowers/ Recipients. In some cases, this supported the scale‐up ofearly and medium‐term recovery interventions with immediate integration of the building back better approach. The useof retroactive financing, as allowed under World Bank policies, can make a significant difference in complex emergencysituations. It requires detailed discussions with the counterparts on the selection of activities, the modalities and risks(to be accepted by the Government), then comprehensive retroactive financing reviews verifying the eligibility ofexpenditures submitted. These reviews are technical (including safeguards due diligence reviews) and fiduciary and canrequire post‐audits. In this case, given the limited advance it can engage pending Board approval of the project, theGovernment is prioritizing the urgent needs for effective response to the Cyclone (as soon as the alerts were triggered atthe imminent arrival of the Cyclone) as well as the requirements for project preparation, such as preparation of safeguarddocuments and studies, preparatory studies and surveys to support component design and/or expedite projectimplementation.

III. IMPLEMENTATION ARRANGEMENTS

A. Institutional and Implementation Arrangements

78. The project will be implemented by the MLUUP, 50 through a dedicated PIU to be established by Ministerial Orderwithin the Directorate General for Equipment and Land Use (DGEAT) in charge of project management, coordination,fiduciary, safeguards management and M&E, as well as coordination among the key stakeholders involved in projectimplementation. For Component 1, the PIU will work closely with the Directorate for Land Use Planning, Urban Planningand Housing (DATUH). As part of this component, an MOD will be hired to facilitate the implementation of the housingreconstruction program (transfer of some management responsibilities under Subcomponent 1.1). For Component 2, thePIU will work closely with DGEAT and the Directorate General for Roads and Land Transportation (DGRTR). ForComponent 3, the PIU will work in close collaboration with DGSC/COSEP under the Ministry of Interior, Decentralizationand Territorial Administration in charge of relations with Institutions (MOIDTA) who will provide technical inputs andcontribute to the implementation, M&E of the DRM component. There will be standard coordination with the Ministryof Agriculture, Fishery and Environment (MAFE) for consultation on environmental issues and on coastal managementissues and climate change data. The PIU’s minimum staffing will consist of a project coordinator, an environmentalspecialist, a social specialist, an FM specialist, an accountant, a procurement specialist, an M&E and an internal auditor(IA). They will be recruited or assigned on a competitive basis and report to MLUUP. Additional staff will be hired as needbe. The project will finance consulting services (which may include consulting firms, individual consultants, NGOs, UN‐Agencies, architecture firms, etc.), non‐consulting services, goods, works, training, and operational costs.

50 The Ministry has experience in managing EU and AfDB projects and is well placed to facilitate the coordination with and delivery of implementation support for the housing and transport sectors, which is in line with its mandate.


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Figure 4 – Institutional and Implementation Arrangements

79. Project activities will be implemented across the three islands. The Regional Directorates of MLUUP will beinvolved in the implementation of the project to achieve the objectives of the project. Mechanisms to facilitate projectexecution on the three islands will be established.

80. A project Steering Committee will be set up to ensure consultation and coordination between the differentproject stakeholders. It will be chaired by MLUUP and composed of inter alia representatives of the Ministry of Finance,Budget and Banking Sector, the National Agency for Design and Implementation of Projects (Agence Nationale deConception et d’Exécution des Projets, ANACEP), MOIDTA/DGSC, MAFE, the Ministry of Health, Solidarity, SocialProtection and Gender Promotion, municipalities, associations and women’s groups, key stakeholders involved in theconstruction sector. The Steering Committee will have a core body and can extend invitations to other parties dependingon the agenda of the meeting. The project Steering Committee will meet twice a year and organize extraordinary sessionsif necessary, to provide overall strategic, oversight and guidance on project implementation, facilitate adequatecoordination with relevant stakeholders, review annual work plans, monitor the progress of project implementation onthe basis of supervision and audit reports, validate or make recommendations to improve the implementation and takemeasures to this effect – in compliance with the Project Operations Manual (POM).

81. Fiduciary Arrangements. An assessment of procurement, FM capacity was undertaken during preparation, toinform fiduciary arrangements, funds flow and contract staffing needs for the Project. Adequate internal controls will beestablished in keeping with the Public Finance Law, IAs will be in place, annual audits of the Project will be undertaken,


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and reports published.

82. Environmental and Social Risk Management. A capacity assessment was conducted during project preparation to inform the E&S management arrangements. E&S risk management capacities will need to strengthened to ensure appropriate implementation of the Environmental and Social Framework (ESF), through (i) the development and implementation of comprehensive E&S risk management procedures in line with international best practice standards; and (ii) the establishment of an E&S risk management team within the PIU, composed of one environmental specialist and one social development specialist at least, in charge of all E&S management procedures related to the reconstruction and rehabilitation works, including the integration of E&S mitigation measures in the bidding documents of all planned civil works, and supervision and monitoring of E&S risk management activities. The E&S team will oversee the preparation of the E&S instruments to be elaborated during implementation. In addition, community liaison officers will be mobilized at the local level to support the implementation and monitoring of the SEP. Any capacity gaps/strengthening measures will be captured in the project Environmental and Social Management Framework (ESMF),51 and reflected in the Environmental and Social Commitment Plan (ESCP) that was prepared and disclosed on November 12 and 14, 2019 respectively on the World Bank website and in‐country.

B. Results Monitoring and Evaluation Arrangements 83. MLUUP will be responsible for the overall project M&E and reporting. A dedicated PIU M&E specialist will lead the effort to collect, consolidate, analyze and report on project performance data including gender disaggregated data as well as to provide periodic information on intermediate project‐wide results and progress towards higher level outcomes. Reliable project data will be critical for the mid‐term review of the project as well as end indicators. For Component 1.1, the Delegated Project Management entity facilitating the implementation of the housing reconstruction program will play a critical role in providing outputs and outcomes that would be consolidated by the PIU. For Component 2, the PIU will rely on the construction supervision firms to report on the implementation of the activities. For Component 3, DGSC will play a critical role, responsible for timely reporting the same information associated to the DRM subcomponent, to the PIU. The PIU will have the overall responsibility to prepare a consolidated progress report on a semi‐annual basis. 84. The project outcomes and impacts will be evaluated through the PDO and intermediate level indicators that are defined in the results framework (Section VII).

C. Sustainability 85. The proposed program is aligned with the recovery plan principles presented in the Damage Assessment endorsed by the Council of Ministers in July 2019. It emphasizes that a reconstruction program should be multisectoral to create synergies between the interventions, encourage public and private sectors’ involvement, civil society, local authorities, affected communities, NGOs and international organizations, and be guided by the Build back better approach. Housing, flood mitigation and transport infrastructure will be rebuilt/rehabilitated in accordance with climate resilient design. 86. On the housing component: the TA provided under Subcomponent 1.2 will contribute to strengthening the capacity of MLUUP and ensuring the sustainability of the actions initiated in Subcomponent 1.1. The sustainability is

51 Under preparation and to be finalized within the first four weeks after project Effectiveness.


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reinforced by the social mobilization activities and household/community participation in reconstruction activities and decision‐making on community infrastructure investments.

87. On the coastal resilience and infrastructure rehabilitation component: to ensure the sustainability of roadinvestments and given the maintenance capacity challenges, there will be a legal covenant requiring the Government tosecure and make available a dedicated budget to ensure road maintenance on the road section subject ofComponent 2.1, especially between Mohoro and Ouroveni in Grande Comore, for the duration of projectimplementation.

88. The interventions in integrated DRM will be implemented with a long‐term and sustainable perspective andwould become central pillars to strengthen the Government capacities to be better prepared for and recover fromdisaster.

IV. PROJECT APPRAISAL SUMMARY

A. Technical, Economic and Financial Analysis (if applicable)

89. Cyclone Kenneth destroyed housing; agricultural crops, livestock and fishery equipment; coastal defense androad infrastructure. The disaster caused widespread damage and recovery needs across sectors, particularly for thesethree most impacted sectors. It highlighted that investments in climate resilient measures especially in the public andprivate infrastructure are urgently needed to reduce future disaster impacts. The recovery and resilience of the housingsector, the rehabilitation and resilience of coastal protection and road infrastructure, as well as the strengthening of DRMcapacities are priorities for the disaster recovery and reconstruction process according to the Government’s DamageAssessment. They are areas where the Government has no or limited access to financing and that are critical to increasethe resilience of the country against natural and climate disasters. The agriculture, livestock and fishery sectors would besupported through other ongoing and additional Government programs (including with World Bank financing).

90. The project components are designed to address some of the most urgent needs for recovery andreconstruction, while investing in long‐term resilience to natural and climate disasters in preparation of future events.The project components have been designed to balance rapid recovery of housing and infrastructure with longer terminvestments to increase their resilience and overall the resilience of the country to natural and climate disasters.

91. The areas of intervention fall under the mandate of MLUUP who has technical teams in place and experiencewith implementation of large infrastructure projects financed by the AfDB and the EU especially in the transport sector.The project will rely on existing capacity which will be strengthened to support project implementation and successfulachievement of PDO. The project also aims to strengthen DRM in the UoC which today is institutionalized under DGSC ofMOIDTA. The project will rely on and strengthen the institutional, technical and operational capacity of DGSC to addressand mainstream DRM across sectors. DGSC is the entry point to strengthen DRM which is until now more focused onresponse than on preparedness. DGSC will participate in project implementation through strategic and technical inputs,and with MLUUP as the implementing agency and one of the key line ministries who have direct influence on riskreduction and infrastructure resilience, the project is an appropriate vector to promote DRM as the responsibility of allsectors.


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Economic Justification

92. The economic assessment indicates that the proposed interventions are economically viable and beneficial. Theresults of the economic analysis conducted during project preparation are summarized per component in Table 2. Theyapply a 4 percent discount rate as recommended by Berrada, Mahul and Gollier (2017) for IDA countries,52 but also showvaluation at 6 percent for which most scenarios are still economically viable, except for the road investments. For these,the results are relatively modest but can be considered to be sufficient with the rural nature of the project area, wheretraffic is low relative to investment costs. Economic benefits should be considered over the long term. The detailedeconomic analysis is presented in Annex 2.

93. Due to the urgent nature of the operation, the estimations are based on a simplified and preliminary economicanalysis of the project.

Table 2 – Summary of Economic Efficiency

Rationale for public sector engagement and World Bank Comparative advantage

94. There is a clear rationale for public intervention in the aftermath of a disaster. Roads, coastal protection andcommunity infrastructure as well as strengthening DRM and the institutional and operational capacity to respond in caseof emergency are clear examples of interventions with benefits showing important spillovers and that are difficult torestrict to only those who pay. Some interventions are focused on housing reconstruction, a private good, but theeconomic and social benefits of housing justify Government involvement, especially for poor households which have noaccess to insurance or other means for recovery. The rehabilitation/reconstruction services will be financed by theGovernment but will be implemented through the private sector and seek to employ local labor leading to widereconomic benefits for communities.

52 Risk‐Adjusted Discount Rates in Economic Analysis of Investment Projects. World Bank: Washington, DC.


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95. The World Bank has extensive international experience in interventions areas such as resilient housing, transport infrastructure and coastal resilience. Rapid financial and technical support will provide the Government with the required resources to undertake resilient rehabilitation and reconstruction. The project will help build the capacity of the Government to manage disaster risks and enhance disaster preparedness. The Bank is supporting similar programs worldwide and is thus able to provide added value to the implementation of resilient housing and other infrastructure based on international experience and global knowledge in DRM.

B. Fiduciary

(i) Financial Management 96. The conclusion of the assessment is that subject to the proposed mitigation measures identified during project appraisal, the FM arrangements within the PIU are acceptable and satisfy the World Bank’s minimum requirements as per World Bank Directive and guidance. The overall FM risk was assessed as High due in part to country risk, capacity issues in the country, as well as the risk related to the funds flow given the decentralization and the nature of activities to be financed across the three islands. Once the mitigation measures are implemented, they shall bring the residual risk to Substantial.

97. The FM assessment was carried out in accordance with the Directives and Policy for IPF, the World Bank Guidance on FM in World Bank IPF Operations issued on February 28, 2017, Guidance Note on FM in Rapid Response to Crises and Emergencies issued by Operations Policy and Country Services (OPCS) on November 1, 2015 and updated on June 1, 2015. The project requires the establishment of a new implementation unit within MLUUP. Despite its limited experience with World Bank funded projects management, MLUUP has extensive experience in managing other donors‐funded projects. The FM arrangements and measures to be put in place are detailed in Annex 1 and summarized below:

The preparation of a FM procedures manual that will describe the policies governing the budgeting, accounting, reporting, auditing procedures (and procedures themselves) as well as the flow of funds applicable to the project;

The PIU will prepare quarterly un‐audited Interim Financial Reports (IFRs) for the project, following a format agreed with the World Bank. These IFRs will be submitted to the World Bank within 45 days after the end of the quarter to which they relate;

The project accounts will be audited annually, and the audit report will be submitted to the World Bank no later than 6 months after the end of each financial year;

The PIU will recruit FM staff with qualifications and experience acceptable to carry out the FM activities of the project. The staff will include a FM Specialist and an Accountant. The PIU will be supported by an IA recruited on a contractual basis.

98. The Designated Account (DA) is denominated in local currency KMF (Comorian Franc) to receive funds from the World Bank. This account will be opened at an acceptable commercial bank to enable payment of eligible expenditures. Transaction‐based disbursements will be used for this project. The retroactive financing requested by the Government will fund preparatory activities as well as selected expenditures incurred by the Government in response to the Cyclone in accordance with IPF procedures. The expenditures to be retro‐financed are described under Subcomponent 3.3 and will be framed in more details in the POM. The eligibility date is April 1, 2019.


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(ii) Procurement

99. A procurement assessment was conducted to evaluate the procurement capacities of MLUUP as theimplementing agency in light of the proposed project and implementation arrangements (dedicated PIU within DGEAT).Similarly to the FM assessment conclusions, though MLUUP has never implemented a World Bank‐financed project, ithas experience with other donors. However, the risk associated with procurement is rated as High because MLUUP is notfamiliar yet with the requirements of the World Bank Procurement Regulations for IPF Borrowers. The risk will bemitigated through regular reporting on the progress and implementation of fiduciary activities by MLUUP, World Banksupervision, World Bank procurement team hands‐on support when required, and further capacity building.Procurement under the proposed operation will be guided by the following documents: (a) the ‘World Bank ProcurementRegulations for IPF Borrowers’ dated July 1, 2016, revised in November 2017 and August 2018 (Procurement Regulations);and (b) the World Bank’s Anticorruption guidelines ‘Guidelines on Preventing and Combatting Fraud and Corruption’,revised July 1, 2016. The POM will be drafted in accordance with these documents and detailed procedures foradministration and handling of procurement‐related complaints. As required by the procurement regulations, a ProjectProcurement Strategy for Development (PPSD) was developed, and a Procurement Plan covering the first 18 months ofimplementation was submitted and approved by the World Bank.

100. The project will use the World Bank’s online procurement planning and tracking tools to carry out allprocurement transactions. The Systematic Tracking of Exchanges in Procurement (STEP) will be used for submission,clearance, and update of the Procurement Plan. To this end the team of MLUUP in charge of the project preparation willattend the training provided by the World Bank in Comoros and additional training will be given once the dedicated staffare hired and as needed throughout project implementation.

All goods, works and non‐consulting services will be procured in accordance with the requirements set forth orreferred to in Section VI of the procurement regulations.

Approved Selection Methods: Consulting services will be procured in accordance with the requirements set forthor referred to in Section VII of the procurement regulations.

101. The UoC has a procurement regulatory framework, but most ministries do not systematically follow the nationalprocurement procedures. The Government has proposed the use of World Bank’s procedures and documents for thisproject. The proposed project has complex procurement that will challenge the Recipient capacity. Procurementactivities will be closely followed up by the World Bank team and dedicated consultants.

C. Legal Operational Policies . .

Triggered?

Projects on International Waterways OP 7.50 No

Projects in Disputed Areas OP 7.60 No .

D. Environmental and Social

102. The E&S risk classification for the project is expected to be Substantial as the project activities entail constructionor rehabilitation of public infrastructure (for instance, roads, dykes, houses) and strengthening of institutional andregulatory capacities on land‐use planning and DRM. These activities are considered medium to large by E&S scale and it


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the probability of adverse effects to human health and/or the environment as a result of the project activities is expected to be low to medium. The potential risks and impacts identified at this stage are related to institutional E&S risk management capacity, labor influx and employment expectations; stakeholder engagement and communication (e.g. exclusion of certain groups); labor and working conditions; waste management and pollution prevention and control; community health and safety (including potential risks of GBV/SEA and road safety); displacement impact (economic and physical); potential impacts on natural habitats; as well as potential Chance Find discoveries.

103. The preliminary E&S review concluded that the Government’s E&S management system needs to be enhancedto comply with the ESF. The project will address the identified gaps in the ESCP that was prepared jointly between MLUUPand the World Bank during project appraisal. The ESCP was developed based on the preparation of initial versions of theproject ESMF and Resettlement Framework (RF),51 as well as on the SEP. It is disclosed on the World Bank website andin‐country (as of November 12 and 14, 2019 respectively).

104. Environmental and Social Assessment. As the project exact locations are not all clearly defined during the projectpreparation phase, an ESMF was deemed as the most appropriate E&S risks assessment instrument for the project. TheESMF will define the methodology and procedures for conducting E&S screening once the different works sites areconfirmed to ensure that they are environmentally and socially sound and sustainably implementable. The Environmentaland Social Impact Assessment (ESIA) will be carried in line with the World Bank ESF and national laws and regulations.The ESMF instrument will define or guide the definition of mitigation measures for construction and operational phases,roles, and responsibilities, time and costs for each mitigation measure recommended, including potential site specificESIAs and ESMPs requirements and contents. The ESMF will outline the importance of developing an operational GMwhich will capture and address environmental, social, governance, and other grievances and negative impacts of theproject. Prior to its commencement, and as soon as the implementation sites are identified, each subproject/activity willbe screened per the Environmental and Social Screening Form (ESSF) procedures that will be detailed in the ESMF. Thescreening outcomes will determine the need to prepare an ESIA, ESMP, Resettlement Plan (RP) or any other relevantenvironmental and social assessment (ESA) instrument. The RF will guide the preparation of a site‐specific RPs. The RFwill establish resettlement principles, organizational arrangements, and design criteria to be applied to subprojects orproject components requiring land acquisition to be prepared during project implementation. The ESMF will be finalized,adopted and disclosed within the first four weeks of project effectiveness. The preparation of the ESIAs/ESMPs will beinitiated upon the conclusion of the feasibility studies and preliminary engineering designs and will be submitted forWorld Bank's review and clearance before launching the bidding process for the respective subproject. The approvedESMP with the E&S clauses will be included in the civil works Bidding Documents and Enterprises contracts to allow thelatter to prepare the specific contractor ESMP before to commencement of civil works.

105. Involuntary resettlement and land acquisition. The project may require formal, traditional or not recognized landor usufructuary rights acquisition. The breadth and variety of the infrastructure works foreseen by the project mayinvolve physical and economic resettlement impacts, both temporary and permanent. The level of impact is not exactlyknown at this time but is expected to be moderate due mainly to the road rehabilitation works, which would take placein populated areas passing through villages and potentially impacting houses and businesses. The RF will establishresettlement principles, organizational arrangements, and design criteria to be applied to subprojects or projectcomponents potentially requiring land acquisition. Once the subproject or individual project components are definedand the necessary information becomes available, such a framework will be expanded into a specific plan proportionateto potential risks and impacts. Project activities that will cause physical and/or economic displacement will not commenceuntil such specific plans are finalized and approved by the World Bank.


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106. Land use planning and housing frameworks. In case the project were to support the issuance or amendment ofthe institutional, legislative and regulatory land‐use and housing sectors frameworks, the Government will conduct asocial, legal and institutional assessment in order to identify potential economic and social risks and impacts of suchactivities, along with appropriate measures to minimize and mitigate them, in particular, those that affect poor andvulnerable groups. For instance, despite gender equality being enshrined in the Constitution and women inheriting landand houses according to custom, they may not always have usufruct rights, which could be with their husbands, maternaluncles or brothers.

107. Work force and community safety. Through the civil works, the project will most likely require a significantamount of labor (potentially up to 300). Besides the local hiring of the workforce required to construct or rehabilitate thediverse civil works, in some contexts, as rural settings, short‐term labor from outside of the locality may be required andsmall construction labor camps are therefore anticipated. Experience indicates that the influx of workers and followersinto a project area can lead to adverse social impacts such as GBV, sexual exploitation and communicable diseases forlocal communities, especially if the communities are rural, remote or small as they may be for some of the project sites.Other potential risks are those related to labor conditions (working hours, wages, etc.), Occupational Health and Safety(OHS) and code of conduct of workers. The project will develop LMPs that will include a Code of Conduct which willinclude clear language on expected behavior of workers with community members as well as any punitive measures fornon‐compliance. A standalone OHS Management Plan and Labor Management Plan will be prepared by the contractorsas well as a worker’s GM. A Labor Camp Management Plan will be required in the event of use of Labor Camps.

108. Management of contractors. All construction contractors will have the contractual obligation to implement andcomply with the ESMP, including preparing construction management plans consistent with the specific managementplans provided in the ESMP, as those related to labor conditions in form of a LMPs and GBV/SEA in form of a GBV ActionPlan.

109. Environmental and social capacity building. In addition to the mitigation measures identified during projectappraisal (hiring of qualified E&S staff and allocating resources to support management of E&S risks), the ESMF willpropose capacity building activities and trainings targeting both men and women, and recommendations to ensureadequate M&E of the E&S aspects of the project and resources needed.

V. GRIEVANCE REDRESS SERVICES

110. Communities and individuals who believe that they are adversely affected by a World Bank (WB) supportedproject may submit complaints to existing project‐level grievance redress mechanisms or the WB’s Grievance RedressService (GRS). The GRS ensures that complaints received are promptly reviewed in order to address project‐relatedconcerns. Project affected communities and individuals may submit their complaint to the WB’s independent InspectionPanel which determines whether harm occurred, or could occur, as a result of WB non‐compliance with its policies andprocedures. Complaints may be submitted at any time after concerns have been brought directly to the World Bank'sattention, and Bank Management has been given an opportunity to respond. For information on how to submitcomplaints to the World Bank’s corporate Grievance Redress Service (GRS), please visithttp://www.worldbank.org/en/projects‐operations/products‐and‐services/grievance‐redress‐service. For informationon how to submit complaints to the World Bank Inspection Panel, please visit www.inspectionpanel.org.


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VI. KEY RISKS

111. The overall risk is rated Substantial. The key risks that could affect the achievement of the PDO and proposedmitigation measures are described in the following paragraphs.

112. Political and governance risk is High. Comoros remains exposed to socio‐political tensions, especially after theconstitutional referendum held on July 30, 2018, altering the Presidential rotation system between the country’s threemain islands shifting from a federal to a unitary system. Additionally, the project will involve several public or privatestakeholders (existing and new) in a context that will require transparent and accountable mechanisms. The risk will bemitigated through the implementation of activities across the three islands, the presence of the World Bank on theground (office in Moroni) with access to the technical and fiduciary teams based in regional country offices, and regularand on‐demand missions from the task team.

113. Macroeconomic risk is Substantial. There are five main sources of macroeconomic risk facing Comoros: a) itsdependency on external financing; b) debt sustainability; c) a business environment unfavorable to the development ofthe private sector, depriving the State of tax revenues for public services; d) the quasi‐bankrupt state of the energy utility;and e) its dependence on imports. The WBG is mitigating these risks by working closely with the Government as well asother Development Partners including the International Monetary Fund (IMF) to maximize efficiency, strengthening theregulatory environment required for private investment, and helping to promote export sectors.

114. Sector strategies and policies related risk is Moderate. The strategic importance of investing in resilient housing,resilient coastal protection and road infrastructure, and DRM is well acknowledged by the key members of theGovernment, MLUUP and DGSC, as well as development partners. The Damage Assessment clearly highlights it. Inaddition, it is also part of the 2030 Emergence vision from the Government with commitment at the highest level.

115. The risk related to technical design of project is Substantial. The project will support investments in areas where(i) fundamental changes in the approach and methodology will be introduced; and (ii) there has never been financialsupport of that scale (housing sector and coastal protection). In that sense, the project will bring in experience andtechnologies that exist at the international level and have proven successful, and that are relevant to the context of theUoC. The technical design remains simple, and with an adequate balance between investments and TA, and betweenshort‐term and long‐term objectives. It was also done in coordination with the other sectors especially the Social Safetynet additional financing project (P171633) and the PIDC Project. it will build on targeting mechanisms already establishedunder the Social Safety Net Project (P150754) and the referenced database and knowledge of the road networkdeveloped through PIDC and the analytical piece on Transport Connectivity. It will also build on relevant initiativesfinanced by other donors (such as mapping exercises, capacity assessment). A strong M&E framework is developed tocapture the results of the project and identify bottlenecks.

116. Institutional capacity for implementation and sustainability is rated as High. Though MLUUP has experience inmanaging large infrastructure projects financed by other development partners such as EU or AfDB, it has no previousexperience in managing World Bank‐financed operations. As such, preliminary risk classification is High. For the project,the MLUUP will establish a new PIU overseen by DGEAT, which has years of experience in managing other partnersprojects but will need specific World Bank policies and procedures trainings and capacity building activities. Duringproject preparation, with no project preparation advance, MLUUP through DGEAT showed serious efforts to ensuretimely and solid project design. The same applies to DGSC. Project preparation teams will continue being involved andbe they will be strengthened. Component 1 activities will require important social, technical and coordination efforts


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bringing the MLUUP to use a Delegated Project Management entity (or MOD), which could create potential tensions associated with the hiring of external consultants to work with Government officials. The use of MOD will be streamlined to involve local human resources and maximize a learning‐by‐doing approach with all stakeholders (including MLUUP staff, PIU staff, municipal staff, community organizations, Housing Committees) and a transfer of know‐how. In terms of Sustainability of project activities, all of the following contribute to it: the programmatic approaches, the resilient design against natural and climate disasters, the TA accompanying the investments and focused on strengthening institutional/technical/operational/financial capacities of the entities involved, social mobilization and active participation of the communities. Specifically, on the road maintenance: a legal covenant is included, requiring the Government to secure sufficient budget to maintain the road sections considered under the project for the project implementation duration.

117. The fiduciary risk is Substantial. The project will build fiduciary capacity in the PIU, develop the procurement andFM procedures and processes as part of the POM, and implement an adequate accounting and tracking system.

118. The E&S risks are Substantial. The potential adverse social and environmental impacts are likely to be site‐specific,mostly temporary, predictable and/or reversible and known mitigation measures are readily available. However, somerisks and impacts may be significant. The adverse risks and impacts are mainly connected to the proposedrehabilitation/reconstruction works and are captured under Section D of this document. Committed to comply withWorld Bank policies and procedures, the Government explicitly requested access to retroactive financing to cover interalia the services of consultants to support the preparation of E&S risk assessment documents and the assessment ofspecific personnel and capacity needs to ensure that all gaps identified in the ESCP and mitigation measures proposed inthe ESMF can be effectively implemented. Site specific screening will be undertaken to identified risks and impactsassociated with the subproject activities and to determine appropriate ESA instruments to manage such risks andimpacts, such as site‐specific ESIAs, ESMPs and RPs. A grievance redress mechanism (GRM) will be established for theproject taking into consideration existing local grievance structures and relevant stakeholders, including those consideredvulnerable.

119. Stakeholders risks are rated Substantial. Due to the cross‐sectoral nature of the project, various stakeholders atthe national, regional and local levels are involved. To mitigate these risks, the project will streamline coordinationthrough existing structures and the creation of effective coordination structure and of a project Steering Committee. Theoverall coordination throughout the national territory will be enhanced by the involvement of Regional Directorates inthe project implementation. Specially for Component 1, Housing Committees will be established to help coordinate thehousing rehabilitation program at the national, regional and local levels and play a central role in land title certification.

.


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VII. RESULTS FRAMEWORK AND MONITORING

Results Framework COUNTRY: Comoros

Comoros Post‐Kenneth Recovery and Resilience Project

Project Development Objectives(s)

The Project Development Objective is to support recovery and increase disaster and climate resilience of select public and private infrastructure in the areas affected by Cyclone Kenneth.

Project Development Objective Indicators

RESULT_FRAME_TBL_PDO

Indicator Name DLI Baseline End Target

Support recovery and increase resilience of select public and private infrastructure

Number of people benefiting from houses rebuilt with resilient standards (Number)

0.00 6,100.00

Of which women are heads of household (Number) 0.00 400.00

Number of people benefiting from housing reconstruction assistance activities and neighborhood improvements (Number)

0.00 209,500.00

of which percentage of women (Number) 0.00 40.00

Number of people trained in resilient construction standards and practices (Number)

0.00 75,600.00

Number of people protected with resilient coastal defense system (Number)

0.00 25,800.00


Number of people benefiting from primary/main road rehabilitation works (Number)

0.00 6,800.00


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RESULT_FRAME_TBL_PDO



PDO Table SPACE

Intermediate Results Indicators by Components

RESULT_FRAME_TBL_IO


Component 1: Recovery and Resilience in the Housing Sector

Number of houses rebuilt with resilient standards and practices (Number) 0.00 1,000.00

of which women of are heads of households (Number) 0.00 400.00

Number of community infrastructures built or rebuilt (Number) 0.00 30.00

Number of strategic and operational Documents or Tools updated or developed supporting urban system enhancement (Number)

0.00 3.00

Component 2: Coastal Resilience and Infrastructure Rehabilitation

Number of km protected with resilient coastal defense system (Kilometers) 0.00 2.50

Number of awareness‐raising/education campaigns contributing to increasing infrastructure resilience and road safety (Number)

0.00 10.00

Roads rehablitated (CRI, Kilometers) 0.00 13.50

Roads rehabilitated ‐ rural (CRI, Kilometers) 0.00 0.00

Roads rehabilitated ‐ non‐rural (CRI, Kilometers) 0.00 13.50

Number of local job opportunities created by the project (Number) 0.00 300.00

of which women are beneficiaries (Number) 0.00 90.00


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RESULT_FRAME_TBL_IO


Component 3: Integrated Disaster Risk Management and CERC

Number of strategic and operational Documents or Tools mainstreamed, updated or developed on Disaster Risk Reduction (Number)

0.00 2.00

Georeferenced database for multi‐risks updated (Yes/No) No Yes

Number of people trained in integrated Disaster Risk Reduction (Number) 0.00 1,200.00


of which percentage of participating women believe they are better prepared to respond to natural and climate disasters (Number)

0.00 80.00

Component 4: Project Management, Risk Management, Monitoring and Evaluation

Number of consultative and dissemination events organized for the communities (Number)

0.00 18.00

Percentage of women representatives in the participating Housing Committees (Percentage) 0.00 30.00

Grievances registered related to project that are actually addressed (Percentage)

0.00 90.00

GBV grievances registered have been referred to GBV service providers (Percentage) 0.00 100.00

Number of training/awareness campaigns provided to relevant ministries and stakeholders on GBV risk management and referral pathway (disaggregated by island) (Number)

0.00 12.00

IO Table SPACE

UL Table SPACE


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Monitoring & Evaluation Plan: PDO Indicators

Indicator Name Definition/Description Frequency Datasource Methodology for Data Collection

Responsibility for Data Collection

Number of people benefiting from houses rebuilt with resilient standards

Number of beneficiaries receiving the Housing assistance package provided under the project to rebuild/rehabilitate their housing units impacted by the Cyclone with resilient building standards and practices (exact number or calculated based on an average household size of 6.1)

semi anual

Implementation report by Delegated Projet Management entity (MOD)

Supervision report and verification in the field

MOD/DATUH/PIU

Of which women are heads of household

Number of female heads of household receiving the Housing assistance package provided under the project to rebuild/rehabilitate their housing units impacted by the Cyclone with resilient building standards and practices

semi annual

Implementation report by MOD


MOD/DATUH/ PIU

Number of people benefiting from housing reconstruction assistance activities and neighborhood improvements

Number of people (i) receiving assistance from the housing reconstruction program supported by the project whether with the housing assistance to rebuild their houses, or

Semi‐annual

Reports from MOD, consulting firms, construction firms

Consolidation of data from all progress reports and verification in the field

MOD/DATUH/PIU


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technical assistance, or training or any associated assistance activities, and (ii) benefiting from the community infrastructure re/built under the project

of which percentage of women

Share of women in the number of people (i) receiving assistance from the housing reconstruction program supported by the project, and (ii) benefiting from the community infrastructure re/built under the project

Reports from MOD, consulting firms, construction firms

Consolidation of data from all progress reports and verification in the field

MOD/DATUH/ PIU

Number of people trained in resilient construction standards and practices

Number of people trained in resilient construction standards and practices through the project. The number includes masons and craftsmen and construction professionals, citizens, members of the communities, Government officials, etc. (all types of profiles)

semi annual

Reports from consulting firms in charge of training

Supervision report and verification in the field with support from MOD

DATUH/PIU

Number of people protected with resilient coastal defense system

Number of people better protected against coastal flooding and erosion, benefiting from investments to rehabilitate and strengthen costal protection

semi annual

Report from the construction and supervision firms


DGEAT/PIU


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infrastructure through civil works and non‐structural measures


Share of women in the number of people better protected against coastal flooding and erosion, benefiting from investments to rehabilitate and strengthen costal protection infrastructure

semi annual

Reports from the construction and supervision firms


DGEAT/PIU

Number of people benefiting from primary/main road rehabilitation works

Number of people benefiting from primary road rehabilitation works under the project

semi annual


supervision report and verification in the field

DGRTR/PIU


Share of women in the number of people benefiting from primary road rehabilitation works under the project

semi annual



DGRTR/PIU

ME PDO Table SPACE


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Monitoring & Evaluation Plan: Intermediate Results Indicators

Indicator Name Definition/Description Frequency Datasource Methodology for Data Collection

Responsibility for Data Collection

Number of houses rebuilt with resilient standards and practices

Housing units rebuilt or rehabilitated under the project with resilient standards and practices

semi annual



MOD/DATUH/ PIU

of which women of are heads of households

Number of housing units rebuilt or rehabilitated with resilient standards and practices headed by a female head of household

semi annual



MOD/DATUH/ PIU

Number of community infrastructures built or rebuilt

Number of community infrastructure rehabilitated, built or rebuilt for neighborhood improvements (e.g., roads, walkways and associated drainage, public spaces, recreational infrastructure, solar panels) under the project in communities affected by the Cyclone

semi annual

implementation report by MOD


MOD/DATUH/ PIU

Number of strategic and operational Documents or Tools updated or developed supporting urban system enhancement

Number of urban planning tools developed or updated under the project to strengthen the urban system. For example, land‐use planning, urban development plan, construction code, etc.

annual

progress report

follow up of associated contracts and outputs

DATUH/PIU


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Number of km protected with resilient coastal defense system

Number of km of coastline better protected with strengthened and resilient coastal defense system

semi annual

report from the construction and supervision firms


DGEAT/PIU

Number of awareness‐raising/education campaigns contributing to increasing infrastructure resilience and road safety

Number of awareness‐raising/education campaigns contributing to increasing infrastructure resilience and road safety (e.g., promotion of good practices contributing to making infrastructure and coastlines less vulnerable and more resilient to natural disasters, erosion and climate change, awareness‐raising and promotion of road safety, etc.)

annual

Implementation and supervision reports


DGEAT/DGRTR/PIU

Roads rehablitated semi annual

Reports from the construction and supervision firms


DGRTR/PIU

Roads rehabilitated ‐ rural n/a

n/a

n/a

DGRTR/PIU

Roads rehabilitated ‐ non‐rural semi annual

Reports from the


DGRTR/PIU


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construction and supervision firms

Number of local job opportunities created by the project

Number of local job opportunities created by the project. This number intends to capture number across all components. The reporting can be disaggregated per component.

semi annual

Implementation reports and supervision reports

Consolidation of information included in MOD reports and works supervision reports, and verification in the field

MOD/DGEAT/DGRTR/PIU

of which women are beneficiaries Number of local job opportunities created by the project occupied by women

semi annual

implementation reports and supervision reports

Consolidation of information included in MOD reports and works supervision reports, and verification in the field

MOD/DGEAT/DGRTR/PIU

Number of strategic and operational Documents or Tools mainstreamed, updated or developed on Disaster Risk Reduction

Number of strategic and operational Documents or Tools mainstreamed, or developed on Disaster Risk Reduction

annual

monitoring report by DGSC

Technical monitoring by DGSC in coordination with PIU

DGSC‐COSEP

Georeferenced database for multi‐risks updated

georeferenced database for multi‐risks is updated measured by yes or no

annual

Monitoring report by DGSC

Technical monitoring by DGSC in coordination with PIU

DGSC‐COSEP

Number of people trained in integrated Disaster Risk Reduction

Number of people, any profile, trained in Disaster Risk Reduction.

semi annual

Implementation and supervision

information consolidated from DGSC, MOD and

DGSC‐COSEP/ PIU


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reports including at DGSC level

training firms and verification in the field

of which percentage of women Share of women in the number of people trained in Disaster Risk Reduction

semi annual

implementation and supervision reports including at DGSC level

information consolidated from DGSC, MOD and training firms and verification in the field

DGSC‐COSEP/ PIU

of which percentage of participating women believe they are better prepared to respond to natural and climate disasters

Percentage of women in the number of participating women who believe they are better prepared to respond to natural and climate disasters

semi annual

Implementation and supervision reports including at DGSC level

information consolidated from DGSC, MOD and training firms and verification in the field

DGSC‐COSEP/ PIU

Number of consultative and dissemination events organized for the communities

Number of events organized in the country to consult communities and disseminate information developed under the project, in a gender sensitive manner ensuring that women's views are heard

annual

Implementation report included DGSC level

Consolidation of information from MOD, DGSC, progress reports

PIU/DGSC‐COSEP

Percentage of women representatives in the participating Housing Committees

Percentage of female members involved in the Housing Committees

semi annual

Implementation reports by MOD and by PIU


MOD/MATU/PIU


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Grievances registered related to project that are actually addressed

Percentage of grievances related to the project sufficiently addressed out of all registered grievances in the GRM

semi annual

Grievance Redress Mechanism, Implementation report

Analysis of Grievance Redress Mechanism data and any other potential sources

PIU

GBV grievances registered have been referred to GBV service providers

Percentage of GBV grievances registered have been referred to GBV service providers

semi annual

Grievance Redress Mechanism, Implementation report

Analysis of Grievance Redress Mechanism data and any other potential sources

PIU

Number of training/awareness campaigns provided to relevant ministries and stakeholders on GBV risk management and referral pathway (disaggregated by island)

Number of training/awareness campaigns organized and provided to relevant ministries and stakeholders on GBV risk management and referral pathway (disaggregated by island)

annual

Implementation report by PIU


PIU

ME IO Table SPACE


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ANNEX 1: Implementation Arrangements and Support Plan

COUNTRY: Comoros


Country Issues 1. The overall country fiduciary risk is High. A Public Expenditure and Fiscal Management Review was finalized in October 2016 and concluded that there had been a degree of improvement in public FM since the previous assessment done in 2007.53 However, the review also identified several critical gaps in the areas of budget credibility, completeness and transparency, execution, and control. The Government has been pursuing a program of public financial management (PFM) reforms since 2010 and the Ministry of Finance, Budget and Banking Sector is committed to modernizing the PFM system through the implementation of the PFM Strategy for 2010‐2019. The PFM Strategy is a comprehensive response by the authorities to address the weaknesses of their PFM system, as identified by the previous Public Expenditure and Financial Accountability (PEFA) assessment and recommendations from development partners, including France, the EU, the IMF and the World Bank. Detailed Financial Management and Disbursement Arrangements for the Project 2. The conclusion of the Assessment is that subject to the proposed mitigation measures, the FM arrangements within the PIU under the MLUUP are acceptable and satisfy the World Bank’s minimum requirements as per World Bank Directive and guidance. 3. Budgeting and planning. Budget arrangements will be described in the FM procedures manual. The PIU will prepare the annual budget which will be approved by MLUUP and reviewed by the project Steering Committee. The periodic variance analysis will enable the timely identification of deviations from the budget. These reports will be part of the unaudited IFRs that will be submitted to the World Bank on a quarterly basis. 4. Accounting. The PIU will acquire an appropriate accounting software for the preparation of the quarterly interim financial reports, the annual financial statements and the daily monitoring of the project financial transactions.

5. Internal controls / FM procedures manual. The FM procedures manual will develop the procedures governing the budgeting, accounting, reporting, auditing procedures, contract management as well as the flow of funds applicable to the project. The PIU will periodically review the manual over the project life to ensure their continuing adequacy and compliance with the requirements set out therein.

6. Internal audit. The PIU will recruit a qualified IA that will continuously review the governance, risk management and control over the project’s activities. A risk‐based audit program will be submitted to the World Bank for review. During project implementation, the IA will prepare after each audit a report to be submitted to the project Steering Committee. The reports will be shared with the World Bank.

53 The review was done following the Public Expenditure and Financial Accountability (PEFA) methodological framework. It was completed in October 2016

and covered the fiscal years 2013, 2014 and 2015.


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7. Financial reporting. The PIU will prepare quarterly un‐audited IFRs for the project, the report format will be agreed with the World Bank. These IFRs will be submitted to the World Bank within 45 days after the end of the quarter to which they relate. The annual financial statements will be prepared using internationally accepted accounting standards. At the end of each fiscal year, the project will prepare annual financial statements which will be subjected to an external audit.

8. Staffing. The PIU will recruit a FM specialist and an Accountant with qualifications and experience acceptable to carry out the FM activities of the project.

9. Flow of funds ‐ Disbursement arrangements. The DA is denominated in local currency KMF (Comorian Franc) to receive funds from the World Bank. This account will be opened at an acceptable commercial bank to enable payment of eligible expenditures. Transaction‐based disbursements will be used for this project. An initial advance up to the ceiling of the DA and representing four months forecasted project expenditures payable through the DA will be made into the DA and subsequent disbursements will be made monthly against submission of the Statement of Expenditures (SOEs) or other documents as specified in the Disbursement and Financial Information Letter (DFIL). The option of disbursing IDA funds through direct payment, reimbursement, and special commitment will also be available. To facilitate the payments of contractors, suppliers, and consultants, a lower minimum threshold for the use of direct payment and reimbursement methods of disbursement will be applied for this operation. The World Bank will issue the DFIL which will specify the additional instructions for withdrawal of the proceeds of the IPF.

10. The Recipient requested retroactive financing to fund project preparatory activities, as well as a range of expenditures incurred by the Recipient as response to the Cyclone. The nature of these expenditures is described under Subcomponent 3.3 and will be framed in detail in the POM. In this context, the Government may make withdrawals up to the approved retroactive financing amount for payments made prior to the date of the Financing Agreement but on or after the retroactive financing date of April 1, 2019, for eligible expenditures under agreed categories. The activities financed by retroactive financing are related to the development objectives and are included in the project description; the payments are for items procured in accordance with the applicable World Bank procurement rules. The proposed retroactive financing date was set taking into account the following (i) the Government started preparing for the cyclone season early April 2019; and (ii) the Government took concrete actions a day before Cyclone Kenneth hit, for instance for the early evacuation of households and public facilities at risk of flooding. The amount to be retroactively financed will not exceed US$7 million total (or SDR 5.1 million). All withdrawal applications for eligible expenditure, including expenditure financed during retroactive funds, should be justified by the adequate supporting documentation. All supporting documents for such expenditures must be verified by the PIU, certifying that the expenditures were incurred for the intended purpose and to address the damage caused by Cyclone Kenneth. 11. External Audit: The project accounts will be audited annually, and the audit report will be submitted to the World Bank no later than six months after the end of each financial year. At present, there is no overdue audit report for the sector. The project will comply with the World Bank disclosure policy on audit reports.

12. Supervision plan: Based on the current overall FM risk, the project will be supervised at least twice a year, in addition to routine desk‐based reviews and FM regular meeting, to ensure that project’s FM arrangements operate as intended and that funds are used efficiently for the intended purposes.


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13. FM Risk assessment and mitigation. The content of these risks is described in the table below:

Table 1.1 – Project FM Risk Assessment and Mitigation

Risk

Risk Rating

Risk Mitigating Measures Incorporated into Project Design

Conditions for Effectiveness

(Y/N)

Residual Risk

Inherent risk H S

Country level: The MLUUP system mirrors the Central level PFM system and its weaknesses resulting in the risk of lack of transparency and accountability in the use of public funds.

H

The GoC is committed to implement further reforms of the country’s PFMs (with support from the development partners)

N H

Entity level: FM requirements not met, weak FM capacity.

H The PIU will recruit FM staff that possesses adequate experience and competence.

N S

Project level: The resources of the project may have been distracted due to weak control environment.

S

The PIU will comply with the internal control processes as set out in the FM procedure manual, part of the project operational manual. The internal audit unit will also continuously review the adequacy of internal controls and make improvement recommendations.

N S

Control Risk

Budgeting: Weak budgetary execution and control leading to budgetary overruns or inappropriate use of project funds.

S

The FM manual part of the project operation manual will spell out the budgeting and budgetary control arrangements to ensure appropriate budgetary oversight. The budget follow‐up will be documented in the quarterly IFR.

N S

Accounting: Reliable and accurate information not provided to inform management decision.

S

The PIU will recruit suitably qualified and experienced FM personnel to ensure appropriate performance of the accounting and FM functions. The financial reporting processes will be facilitated by the utilization of appropriate computerized accounting systems.

N M

Internal Control: Business process, role and responsibilities within the

H

The FM procedures manual will be reviewed to ensure continuing adequacy over the course of the project life.

N S


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Risk

Risk Rating



(Y/N)

Residual Risk

project is not clear leaving to ineffective of control. Delay in the project implementation due to weaknesses in contract management.

The manual will contain all the key internal control processes pertaining to the various project activities. The FM procedures manual will establish robust contract management procedures.

Funds Flow: Inappropriate Funds arrangements may lead to non‐financing of the project activities. Delay (payment and replenishment of funds) due to the lack of experience in managing World Bank financed project.

H

The process leading to payment will be well described in the financial manual and monitored to mitigate the risk of the use of funds for unintended purposes.

N S

Financial Reporting: The project may not be able to produce the financial reports required in a timely manner as required for project monitoring and management.

S

The PIU will recruit qualified FM personnel that possess adequate experience and competence. The PIU will use appropriate computerized accounting that will enable the efficient and timely generation of financial information.

N S

Auditing: Delays in submission of audit reports. Poor quality of audit report.

S

The auditor will be recruited early. The computerized accounting system will lead to timely generation of IFRs and financial statements. The UoC does not have a professional accountancy body recognized by the International Federation of Accountants (IFAC). Hence, the external auditor recruitment will be opened at international level and only qualified external auditors will be short‐listed.

N S

Governance and Accountability: Possibility of corrupt practices including

S

Robust FM arrangements, World Bank FM and procurement supervisions. Effective internal control arrangements.

N S


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Risk

Risk Rating



(Y/N)

Residual Risk

bribes, abuse of administrative & political positions, mis‐procurement and misuse of funds etc., are a critical issue.

Overall FM risk H S

14. FM Action Plan. The FM Action Plan described below has been developed to mitigate the overall FM risks.

Table 1.2 – Project FM Action Plan

Remedial action recommended

Responsible Entity

Completion date

Effectiveness Conditions

Recruit qualified staff including FM specialist and an Accountant

PIU No later than three months after Effectiveness

No

Develop FM procedures manual PIU No later than three months after Effectiveness

No

Purchase adequate accounting software PIU No later than three months after Effectiveness

No

Recruit qualified IA PIU No later than six months after the Effectiveness

No

Procurement

15. The procurement of goods, non‐consulting, and consulting services for the project will be carried out in accordance with the procedures specified in the ‘World Bank Procurement Regulations for IPF Borrowers’ dated July 2016 and revised November 2017 and August 2018 (The Procurement Regulations), and the World Bank’s ‘Guidelines on Preventing and Combating Fraud and Corruption in Projects Financed by IBRD Loans and IDA Credits and Grants’ (dated July 1, 2016), as well as the provisions stipulated in the Financing Agreement. 16. All goods, and non‐consulting services will be procured in accordance with the requirements set forth or referred to in the Section VII. Approved Selection Methods: Goods, Works, and Non‐Consulting Services of the Procurement Regulations, and the consulting services will be procured in accordance with the requirements set forth or referred to in Section VII. Approved Selection Methods: Consulting Services of the Procurement Regulations, the PPSD, and the Procurement Plan approved by the World Bank. 17. A PPSD was prepared with World Bank support to ensure the procurement activities are packaged and prepared in such a way that they expedite implementation taking into account (i) the market analysis and the related procurement trends; and (ii) the procurement risk analysis. This PPSD includes the recommended procurement approaches for the project reflected in the approved Procurement Plan covering the first 18 months


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of the project implementation. The table below summarizes the various procurement methods to be used for main activities financed by the proposed IBRD loan.

Table 1.3 – Procurement Methods

Type of Procurement Selection Methods

Goods, works and Non‐Consulting Services Request for Proposals, Request for Bids, Request for Quotations, and Direct Selection

Consulting Services Quality Cost Based Selection, Least Cost Based Selection, Quality Based Selection, Consultant’s Qualification Based Selection, Direct Selection, and Selection of Individual Consultants.

18. Procurement Plan. The Procurement Plan, including its updates, shall include for each contract (a) a brief description of the activities/contracts; (b) the selection methods to be applied; (c) the cost estimates; (d) time schedules; (e) the World Bank’s review requirements; and (f) any other relevant procurement information. The Procurement Plan covering the first 18 months of the project implementation was prepared with the PPSD and approved by the World Bank. Any updates of the Procurement Plan shall be submitted for World Bank approval. The Recipient shall use the World Bank’s online procurement planning and tracking tools (STEP) to prepare, clear, and update the Procurement Plans and manage all procurement transactions and related documentation. 19. Institutional arrangements for procurement. The dedicated PIU will be responsible for the implementation of the proposed project. It will be staffed with qualified and experienced staff to manage the project. In view of the challenges to be met and to learn to work and comply with the New Procurement Framework, the PIU will benefit from direct and ad‐hoc TA from the World Bank for the implementation of procurement activities. 20. Procurement risk assessment. Given the (a) country context and associated risk; and (b) the fact that this project will be implemented under the World Bank’s New Procurement Framework, the procurement risk is rated High. 21. The prevailing risk can be improved to Substantial if the corrective measures identified in Table 1.4 are implemented.


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Table 1.4 – Procurement Action Plan Corrective Measures

Ref Tasks Responsibility Due Date

1 Recruit at least, one qualified and experienced staff for the

procurement unit within the PIU. PIU

After kick‐off /

Effectiveness or before

if funding is available

2

Train all the procurement staff on the World Bank’s New

Procurement Framework (online courses and face‐to‐face courses)

and on the use of STEP tools, which will be used to manage all

procurement transactions and related documentation.

PIU

Word Bank

Three months after

Effectiveness

3 Organize a “kick‐off” (lancement) workshop involving all

stakeholders. PIU

Three months after

Effectiveness

4

Develop a contract management system to ensure that all

contracts under the project are effectively and efficiently

managed.

PIU Continuously

5 Develop an implementation manual of administrative, FM and

procurement procedures PIU

Three months after

Effectiveness

6 Develop subproject manual as needed (describing specific

implementation arrangements and administrative, FM and

procurement procedures)

PIU Three months after

Effectiveness

22. Procurement Reviews and Thresholds.

Table 1.5 – Thresholds for Procurement of Goods and Non-Consulting Services and Consulting Services

Procurement Type Prior Review Threshold

(US$)

1 Works Above 5,000,000

2 Goods and Non ‐ consultant Services Above 1,500,000

3 Consulting Services firm Above 500,000

4 Individual Consultant Above 200,000

23. Frequency of procurement supervision. In addition to the prior reviews to be carried out by the World Bank, there will be at least two implementation support missions a year, including field visits especially for post review of procurement actions. As agreed with the Government, contracts will be published on the web through STEP. Annual compliance verification monitoring will also be carried out by an independent consultant and will aim to (a) verify that the procurement and contracting procedures and processes followed for the project were in accordance with the Financing Agreement; (b) verify technical compliance, physical completion, and price competitiveness of each contract in the selected representative sample; (c) review and comment on contract administration and management issues as dealt with by the PIU; (d) review capacity of the PIU in handling procurement efficiently; and (e) identify improvements in the procurement process in light of any identified deficiencies. To comply with technical requirements of housing reconstruction, it is recommended to conduct a technical audit for Subcomponent 1.1 after a third of subcomponent amount is engaged (approximately).


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ANNEX 2: Economic Analysis

COUNTRY: Comoros


1. Cyclone Kenneth destroyed housing, road infrastructure and coastal protection. The Damage Assessment shows the highest damages in the housing sector, followed by agriculture, livestock and fisheries, and infrastructure including transport infrastructure. It directly affected over 345,000 people, which represents more than 40 per cent of the total population, and caused direct damages in the order of US$185.4 million, associated with recovery and reconstruction costs in the order US$277.5 million. The widespread damage in housing and road infrastructure shows that investments in resilient housing and coastal protection are urgently needed to reduce future disaster impacts. The project components are designed to address some of the most urgent needs for recovery and reconstruction, while investing in long‐term climate resilience in preparation of future events. The project addresses some of the key Government interventions, while coordinating with other donors, and other World Bank projects. 2. The economic assessment indicates that the proposed interventions are economically viable and beneficial. The results of the economic analysis performed are summarized by component in Table 2.1. They apply a 4 percent discount rate as recommended by Berrada, Mahul and Gollier (2017) for IDA countries,54 but also show valuation at 6 percent, for which most scenarios are still economically viable, except for the road investments. Due to the urgent nature of the operation, the estimations are based on a simplified and preliminary economic analysis of the project.

Table 2.1 – Summary of Economic Efficiency

54 Risk‐Adjusted Discount Rates in Economic Analysis of Investment Projects. World Bank: Washington, DC.


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Component 1: Recovery and Resilience in the housing sector

3. The activities to be financed under this component include the repair and reconstruction of housing for select vulnerable communities affected by Cyclone Kenneth as well as investment in public infrastructure, which the economic analysis will focus on. Another subcomponent will seek to enhance the urban planning and management system as well as construction standards to improve the resilience of the sector. The economic valuation of such support is hardly quantifiable but is expected to increase the overall benefit of the project and its sustainability.

Subcomponent 1.1 Support to housing reconstruction

4. Background. Cyclones Kenneth destroyed at least 4,854 houses in Comoros. Housing recovery in the aftermath of a disaster is a key concern of governments. The loss of a house affects household well‐being, in particular in terms earning capacity and health.

Project life. The works are assumed to be implemented over six years, 5 percent in year 1, 40 percent in years 2 and 3, and 5 percent in the last 3 years, with a project life of 25 years.

Investments costs. The project will finance the reconstruction of at least 1,000 housing units for an estimated 6,100 Cyclone‐affected beneficiaries. The approximate cost of reconstruction is US$7,500 per unit. It will also finance US$800,000 in rehabilitating small infrastructure such as public space or rural roads/paths.

The analysis accounts for implementation costs of approximately 13 percent of the total cost and maintenance costs are set at 5 percent of the cost of construction of a new unit for the remaining 20 years after the implementation ends.

Benefits. Living in a more resilient home boils down to two main benefits: the averted health consequences and rental value of housing. We also account for the wages coming from the small public works. Implementation includes capacity building program and training materials on resilient housing construction techniques which benefits were not accounted but may have long term impacts.

5. To estimate the health benefits, we rely on disability‐adjusted life years associated with the cases of disease that the intervention seeks to avert communicable diseases such as infectious and parasitic diseases, respiratory infection or nutritional deficiencies as well as fires related injuries. We expect the intervention to prevent 50 percent of those, equivalent to discounted value of US$13.9 million (costed at a gross national income (GNI) per capita, Purchasing Power Parity (PPP) constant 2011 international dollars for 25 years and 4 percent discount rate). In the absence of the projects, no new houses will be built. The main benefits of the project can be estimated by the shadow annual rental income from these new houses, estimated from the 2014 EESIC survey at US$289. The discounted benefits of new homes amount to US$3.7 million. Finally, to comply with World Bank requirements, we assign 35 percent of the total investment costs in wages, which amounts to discounted benefits US$300,000 over 6 years. 6. Under the above‐mentioned assumptions, this subcomponent is found economically viable with a baseline internal rates of return (IRR) estimated at 12 percent and a net present value (NPV) of about US$6.4 million at a discount rate of 4 percent. The sensitivity analysis highlights changes when benefits lag by two years, or cost increases. The latter scenario affects the number of beneficiaries as less houses can be built for a fixed envelope. In the scenario where benefits decrease, the analysis assumes the program to be less efficient in terms of preventing health issues (from 50 percent to 40 percent) and decreases the rent by 10 percent.


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Component 2: Coastal Resilience and Infrastructure Rehabilitation Coastal Protection

7. Background. Cyclone Kenneth destroyed dykes and coastal protection systems across the three islands, causing serious flooding affecting roads, houses and/or public buildings such as hospitals which required urgent evacuation. In some areas, the aquifers were contaminated and drinking water supply was disrupted either because the pumping system was damaged or because the rainwater tanks were contaminated.

Project life. The costs will be distributed as 5 percent in year 1 and 20 percent over years 2 to 5 and 15 percent in year 6, with a project life of 50 years.

Investments costs. The costs of coastal resilience are estimated at US$5 million per km of coastline, including implementation, for 1 km of coastal protection in Grand Comores (Foumboni) and Ajouan (to be decided between Paje – Mustamudu – Mirontsi – Ouani or Domoni); and 0.7 km in Mohéli (Nioumachoua, Njoiezi). The total number of residents in these villages weighted by the total coastline rehabilitated is estimated around 26,000. Note that this is conservative as despite only some households directly benefiting from the investments, the entire village will benefit from avoiding losses in key service and road infrastructure.

Maintenance costs are set at 5 percent of the cost of construction for the remaining 45 years after the implementation ends.

Benefits. The benefits are calculated on the basis of the avoided losses (Figure 2.1), with a baseline scenario where coastal protection allows to avert 30 percent of Disability Adjusted Life Years (DALYs) and mitigate damages to 70 percent of what would have happened without any investment based on the Disaster risk Profile of Comoros.55 The return periods associated damages are from floods and cyclones and are weighted by built‐up area affected along the coastline being protected relative to the total built up. This is a conservative scenario as calculation are made based on the damage lost estimation for the entire country, and the project identified areas are the ones that are the most vulnerable. Total discounted benefits are estimated to US$46 million.

8. Under the above‐mentioned assumptions, coastal resilience is likely to be beneficial for the population living in villages that will benefit from these investments. The IRR of this subcomponent is estimated at 16 percent with an NPV of about US$23.8 million at a discount rate of 4 percent. Anjouan is the densest island and is particularly vulnerable to tropical cyclones and floods and will benefit the most.

55 Please refer to the Disaster Risk Profile of Comoros for more details: http://documents.worldbank.org/curated/en/444731492588614935/Disaster‐risk‐profile‐Comoros.


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Figure 2.1 - Total Modeled Losses from Flooding and Tropical Cyclones by Return Period

Source: Disaster Risk Profile of Comoros.

Road Rehabilitation Mtsangadju ‐ Mohoro

9. Background. The Comorian road network is well‐established covering most villages and populated areas but remain poorly maintained and vulnerable to extreme climate events. The country owns about 815 km of roads, which translate into a road density of 43.8 km per 100 km2 of land. Although it is among the highest by African standards (c.f., 28.3 km in Kenya, 10.6 km in Tanzania and 5.4 km in Madagascar), Comoros is still unfavorably compared with its neighboring countries, such as 110 km in Seychelles and 101 km in Mauritius. In addition, Comoros has a significant backlog of road maintenance. Even before Cyclone Kenneth hit the country, only 43 percent of its road network were in good condition. The hurricane severely damaged some 60 km of the national roads, hindering the people’s accessibility to markets and social services furthermore. 10. Evaluation method. The Project aims at rehabilitating one of the severely damaged road sections between Mtsangadju and Ouroveni in Grande Comore, particularly focused on the first section of Mtsangadju‐Mohoro (about 14 km). In the following assessment, a simplified cost‐benefit analysis is carried out to understand the economic viability of rehabilitation works on this section. The conventional consumer surplus approach is used, which compares road rehabilitation and maintenance costs and savings of road user costs (RUC), such as vehicle operating costs and time costs. The underlying assumptions and parameters are estimated largely based on the latest available comprehensive report, i.e., the PDNR 2015‐2025.56 For simplicity purposes, the following assumptions are made:

Project life. The reconstruction works are assumed to be implemented in the first year, with a project life of

following 20 years.

Investment costs. The investment cost is estimated at US$600,000 per km based on recent road works in Comoros.

56 “Etude d’Elaboration du Plan Directeur National du Transport Routier en Union des Comores pour 2015‐2025.”


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Maintenance costs. According to PDNR (2015), the average periodic and route in maintenance costs in Comoros are about US$62,500 and US$1,800 per km, respectively. While routine maintenance is assumed to be carried out every year, periodic maintenance is assumed every seven years, because the current and expected traffic level would likely be relatively modest in the project area.

Traffic. According to PDNR 2015, which is the latest available traffic count data, the average daily traffic (ADT) on Mtsangadju‐Ouroveni was between 117 and 556 in 2013, depending on location. Taking into account an annual average traffic growth rate of 2.23 percent in Grande Comore during the 2000s, it is assumed that the current ADT is 635 vehicles. It is also assumed that the vehicle type composition would not change significantly during the project life (Table 2.2). In each category, traffic is assumed to grow linearly at an annual growth rate of 3 percent.

Table 2.2 - Average Daily Traffic Estimated and Vehicle Type Composition

Passenger

car

4x4

passenger

Light goods

vehicle

Medium

truck

Articulated

truck Minibus

Est. ADT, 2019 336 84 9 46 1 159

Share (%) 53.0 13.3 1.4 7.2 0.1 25.0

Road user benefits. Because of the improved road surface, the Project is expected to contribute to reducing RUC, which vary across types of vehicles. The underlying economic and financial vehicle operating costs were updated based on the Highway Development and Management (HDM)‐4 Road Use Costs Africa model with actual vehicle operating costs in Comoros taken into account, which are reported in PDNR (2015) (Tables 2.3 and 2.4). Due to the Project, RUC are expected to decline by about 25‐40 percent (Table 2.3).

Table 2.3 – Economic or Financial Unit Costs of Operating Vehicles (US$)

Passenger Passenger

New New Lubricating Maintenance Crew Annual Annual Working Non‐Working Cargo

Vehicle Vehicle Tire Fuel Oil Labor Wages Overhead Interest Time Time Time

Description ($/vehicle) ($/tire) ($/liter) ($/liter) ($/hour) ($/hour) ($/year) (%) ($/hour) ($/hour) ($/hour)

Car Medium 17997 88 1.52 4.05 6.48 0.13 63.14 10.5 1.06 0.35 0.00

Four‐Wheel Drive 17097 128 1.52 4.05 8.64 0.69 64.97 10.5 1.06 0.35 0.00

Truck Light 17097 121 1.48 4.05 8.42 0.27 126.29 10.5 0.67 0.19 0.19

Truck Medium 62991 371 1.48 4.05 8.42 0.50 126.29 10.5 0.67 0.19 0.19

Truck Articulated 119682 391 1.48 4.05 10.25 0.92 256.23 10.5 0.67 0.19 0.19

Bus Light 18897 94 1.48 4.05 9.52 0.79 161.98 10.5 0.67 0.19 0.00

Table 2.4 - Vehicle Fleet Characteristics

Annual Annual Number Work Gross

km Working Service Private of Related Vehicle

Vehicle Driven Hours Life Use Passengers Trips Weight

Description (km) (hours) (years) (%) (#) (%) (t)

Car Medium 19705 880 10.3 100 3 75 1.6

Four‐Wheel Drive 32842 1300 10.3 0 3 0 2.3

Truck Light 48442 1500 10.3 0 1 0 4.6

Truck Medium 55011 2200 10.3 0 1 0 13.9

Truck Articulated 53368 2400 10.3 0 1 0 36.5

Bus Light 62400 1800 8.0 0 11 75 2.6


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Table 2.5 – Estimated Road User Costs (US$/vehicle-km)

Passenger

car

4x4

passenger

Light goods

vehicle

Medium

truck

Articulated

truck Minibus

Before 0.55 0.49 0.50 0.96 2.10 0.70

After 0.34 0.31 0.38 0.71 1.56 0.44

Emission reduction. The Project is also expected to contribute to emission reduction, although the magnitude

of the contribution may be small simply because of the relatively low traffic expected on the road. In theory, road improvement can generally help to increase vehicle speed and enhance fuel efficiency, thus reducing carbon emissions. Based on the HDM4 RUC model for African countries, CO2 emission could be reduced by up to 35 percent, depending on types of vehicles (Table 2.6). Although the impact varies depending on not only vehicle type but also vehicle speed and road conditions, this normal emission reduction is linearly applied to the above traffic forecasts by vehicle type. It is estimated that the net reduction by the Project is estimated at about 18.7 tons of CO2 over 20 years, which may be valued at about US$1,430 with carbon prices of US$60‐91 per ton.57 The emission reduction is mainly attributed to increased speed and fuel efficiency, while the overall traffic volume is increased over time. Gross emissions are estimated at 79.8 tons without the project and 61.1 tons with the project.

Table 2.6 – Normal Carbon Dioxide Emissions (g/km) by Vehicle Type

Passenger

car

4x4

passenger

Light goods

vehicle

Medium

truck

Articulated

truck Minibus

Before 318.0 315.5 348.2 551.1 1598.7 302.0

After 208.1 217.3 327.2 539.5 1422.4 280.8

Reduction (%) ‐34.5 ‐31.1 ‐31.1 ‐6.0 ‐2.1 ‐11.0

11. Under the above‐mentioned assumptions, the project investment is found to be broadly economically viable but somewhat sensitive to the future traffic and investment costs. The IRR of this subcomponent is estimated at 6.9 percent with an NPV of about US$2.5 million at a discount rate of 4 percent. The results are relatively modest but can be considered to be sufficient with the rural nature of the project area: Economic benefits should be considered over the long term. The project area is one of the most remote and rural areas in Grande Comore. The modest results are mainly attributed to the traffic assumption and high investment costs. The traffic level is currently low and would likely remain modest in absolute terms, though it may jump somewhat after the project is completed. On the other hand, the investment costs are high. This is mainly because of the country’s high cost structure to import materials and equipment. The sensitivity analysis also reconfirms such risks. Particular attention should be paid to increases in investment costs and/or reductions in expected traffic, which may impair the economic viability of the investment.

57 Average estimates (i.e., US$60 in 2020, US$75 in 2030 and an annual growth rate of 2.25 percent afterward) are used according to World Bank (2017) “Guidance note on shadow price of carbon in economic analysis.”