Input:
**The World Bank**
Municipal Services Improvement Project (P169996)

**C. Rationale for Bank Involvement and Role of Partners**

35. **The Bank has substantial global experience in supporting programs and managing policy dialogue to improve**

**service delivery in situations of urban forced displacement.** The Bank has successfully mobilized new financing to
support situations involving conflict-induced forced displacement and crowded-in funding from other donors, recognizing that forced displacement creates specific vulnerabilities for refugees and internally displaced persons (IDPs), who often lose rights, assets, livelihoods, and social capital when they flee their homes. Bank support has been in the form of financial support, Advisory Services and Analytics (ASA) services, and operational support towards implementation of multi-donor funded programs. Globally, the Bank has supported the preparation of needs assessments for refugee host countries, ASA on affected communities, and implementation of activities for provision and expansion of basic services to accommodate the increased pressure on existing systems due to refugees.

36. **The Bank’s comparative advantage in involvement in interventions in situations of forced displacement also stems**

**from its strong partnerships with a wide range of actors in this space** . The Bank has partnered with various host
states, UN agencies, donor countries, regional organizations and the private sector, providing grant or loan resources to support critical operations in several countries. It has also used its convening power to bring together different stakeholders to share lessons across sectors. As the Bank gets more involved in refugee contexts, it is increasingly supporting the application of development approaches to nationally-led responses such as the proposed. Globally, the Bank has implemented projects tackling socio-economic challenges for very vulnerable populations, as well as displaced and refugee populations, including in Turkey, Romania, Ukraine, Kazakhstan, Bosnia and Herzegovina, Russia, Lebanon, Jordan, Iraq, Afghanistan and Palestine. The Bank is also working in the socio-economic space in countries affected by conflict such as Uganda, Angola, Sierra Leone, Liberia, Congo, Chad, Rwanda, Burundi, Myanmar, Pakistan, Yemen, and West Bank and Gaza. The World Banks’ concessional funding [27] portfolio (of US$7 billion in 2017) targeted to help conflict affected countries with large displaced and refugee populations to tackle the integration of refugees and displaced populations while also benefiting host communities.

37. **In Turkey, the Bank is currently managing a diverse US$4 billion IBRD loan portfolio of investment and ASA work,**

**with strong synergies to the proposed project, and is preparing five other new operations in various sectors**
**including employment, agriculture and social cohesion to be financed under the EU FRIT 2** **[28]** . The Bank intends to
leverage geographical and thematical synergies between these projects to develop an integrative and innovative approach, especially in municipalities which will have interventions from multiple Bank administered FRIT projects.
Some of the relevant activities include: (a) Projects in the municipal sector with a focus on urban sustainability and resilience such as the ongoing Sustainable Cities Series of Projects 1, 2, and the Additional Financing (SCP 1, SCP 2 and SCP1-AF); (b) Analytical Work such as the Turkey Urbanization Review (April 2015), the City Creditworthiness Academy (April 2016), and Sustainable Urban Water Supply and Sanitation (June 2016); (c) the Education Infrastructure for Resilience Project (Euro 150 million) financed under FRIT I, which is working with the construction and real estate department of MoNE to construct and equip schools in provinces with a large presence of Syrian refugees; (d) technical assistance to DG Migration Management, Ministry of Interior (DGMM), on the design and implementation of the harmonization strategy for migrants; preparation of a project concept to establish harmonization centers that can serve as one-stop service centers for Syrian refugees and migrants to access legal 27 International Development Association (IDA) 28 The other four Bank projects that have been approved by the EUD for financing under FRIT II: 1. Financing to enterprises conditional on employment creation for Refugees and Turkish Citizens (P171766); 2. Employment Support and Activation of Work-Able Refugees and Turkish Citizens; 3. Agricultural Employment Support for Refugees and Turkish Citizens through Enhanced Market Linkages (P171543); 4.
Promoting Economic Opportunities and Social Cohesion through Social Enterprises for Refugees and Host Communities (P171456) Page 20 of 94

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Input:
**The World Bank**
Municipal Services Improvement Project (P169996) services and get referrals to other services; and work with DGMM and Turkish Red Crescent to provide inclusion support services targeting the refugees residing in temporary accommodation centers; (e) Bank collaboration with MoFLSS and İŞKUR implementing an EU financed operation (under FRIT I) aimed to improve employment outcomes for Syrian refugees and Turkish Citizens in select localities affected by the influx of Syrian refugees; (f) the Bank’s Social Development and Labor and Skills teams piloting social entrepreneurship as a model to help women who are locality bound but want to be economically active; (g) the Bank’s Finance and Competitiveness team implementing a lending project that facilitates access to credit to enterprises in localities that experienced a large influx of Syrian refugees, to catalyze job creation; and (h) the Bank’s Labor and Skills team working with MoFLSS and İŞKUR on demand-side analytics, to identify critical occupations and skills in demand in the 10 provinces with the largest influx of Syrian refugees.

38. **The Bank has established good collaboration with development partners working in Turkey, including the EU,**

**which is co-financing the current operation, the French Development Agency (AFD), which is preparing to**
**implement similar projects in different affected municipalities, and several international and locally based NGOs,**
**and will work in close collaboration with these partners throughout project implementation.** The EUD has allocated
a total of Euro 6 billion in two tranches over a period of six years (2016-2023) to Turkey to support the country in managing the influx of SUTPs, with about Euro 380 million allocated to improvement of municipal infrastructure services, to be administered by various development partners including the Bank.

**D. Lessons Learned and Reflected in the Project Design**

39. The project will incorporate important lessons captured from the implementation of World Bank-financed projects across the globe and in Turkey. Lessons learned that are reflected in the project design are described in the following paragraphs.

- **Having a strong pre-identified investment pipeline ensures project readiness that is critical for successful**
**implementation.** The project included 15 sub-projects at appraisal stage, for which the majority of the feasibility
studies and technical designs for entire municipal investments were available.

- **An integrated approach that targets both host communities and refugees and combines** _**place-based**_ **and**
_**people-based**_ **methods is critical when designing an emergency response, which in this case spills over into the**
**development stage given increasing integration of refugees with host communities.** Given the integration of
most of the refugees among host communities and the shift in locating refugees from dedicated camps to regular urban settlements, the project has adopted a development-oriented ‘place-based’ response for improving services and infrastructure in the urban areas that are most affected by the forced displacement crisis. Thus, it will specifically identify and prioritize in consultation with municipalities the most affected neighborhoods or settlements, combined with ‘people-facing’ interventions in environmental infrastructure facilities and services that will be identified by host and refugee populations to address the most pressing priorities.

- **Defining the scope of projects clearly while allowing for some flexibility in design by involving stakeholders in**
**decisions concerning their needs has facilitated achievement of better results in implementing local solutions**
**in similar situations.** While the project has a pre-defined scope of activities for the larger environmental
infrastructure based on the municipal investment priorities of participating municipalities, it will include a consultative decision-making approach to identify the specific needs and priorities of host and refugee communities at the neighborhood level, as well as for capacity building activities.

Page 21 of 94

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Input:
**The World Bank**
Municipal Services Improvement Project (P169996)

- **Both quick wins and mid-/long-term improvements are necessary to restore trust and the social contract.** Based
on experience from similar contexts in countries such as Lebanon where there was mounting pressure and perceived competition over resources and services, quick visible improvements in municipal services were critical for building trust in local authorities. On the other hand, mid-size, developmental solutions, though taking longer time to prepare, provided larger, more lasting impacts. The project will seek to adopt this two-pronged approach to improving services combining the larger infrastructure investments with the more immediate people-facing activities identified with municipalities and communities in a participatory manner.

- **Social interventions engaging both host communities and refugees are as important as physical infrastructure**
**interventions for ensuring the socio-economic recovery of communities affected by refugees.** Some social
interventions focusing on behavior change and public education will therefore be included in the project design, along with those targeted at improving service delivery to increase sustainability and reduce social tensions. The project is also exploiting synergies with other FRIT projects that more directly address some of the key drivers of social issues, such as skills training and learning programs that would help in mitigating such tensions.

**IV.** **IMPLEMENTATION ARRANGEMENTS**

**A. Institutional and Implementation Arrangements**

**Project Implementation Arrangements**

40. **ILBANK.** ILBANK is the Borrower for the IBRD loan and intermediary recipient of the grant, and the project implementing agency, serving as a Financial Intermediary to municipalities and SKIs. ILBANK is a state-owned development and investment bank based in _[Ankara](https://en.wikipedia.org/wiki/Ankara)_ [, relevant to the Ministry of Environment and Urbanization](https://en.wikipedia.org/wiki/Ministry_of_Environment_and_Urban_Planning_(Turkey)) _._ The Government of Turkey represented by the Ministry of Treasury and Finance is the guarantor of the loan **.** The project will be implemented by an existing Project Management Unit established under ILBANK’s International Relations Department, as is the case under the ongoing SCP series of projects at the central level, and by Project Implementing Units (PIUs) to be set up within the participating municipalities and/or SKIs at the local level. ILBANK has a long experience with managing implementation of municipal infrastructure investments as a financial intermediary and has demonstrated its capacity for managing World Bank loans through the Municipal Services Project (2004-2016) and the ongoing Sustainable Cities Series of Projects. ILBANK establishes the creditworthiness of all local governments in Turkey, provides loans (or grants for small municipalities and local governments) and guarantees, channels funding from International Finance Institutions (IFI), and carries out all required due diligence. ILBANK’s performance on past and ongoing operations has consistently been rated in the ‘satisfactory’ range by the Bank in its Implementation Status reports (ISRs) and its Implementation Completion Reports (ICRs).

41. ILBANK PMU shall be responsible for day-to-day management and implementation of the Project, in accordance with the provisions of the POM, including the responsibility for financial management, procurement, disbursement, monitoring of environmental and social safeguards, reporting, monitoring and evaluation of the Project activities.
The existing PMU has qualified staff responsible for management of core project management functions, including procurement, financial management, safeguards in line with ESF requirements [29], and M&E. At least one additional 29 Responsibilities for management of safeguards are further outlined in relevant ESF documents, and will also include the municipal level Page 22 of 94

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Input:
**The World Bank**
Municipal Services Improvement Project (P169996) designated individual consultant/staff will be hired by ILBANK to support specific core functions, including procurement and financial management, as well as safeguards given the large portfolio. The PMU will also be supported by several specialized departments in ILBANK including the Project department, Investment Appraisal department, Infrastructure Implementation department, as well as the four regional directorates covering the proposed municipalities. The PMU is led by a department head and unit managers, and it has staff capacity in procurement, financial management, safeguards, and technical sectors such as water supply, wastewater, and transport. ILBANK PMU staff have been beneficiaries of intensive training sessions on World Bank procurement, safeguard implementation and other topics. The experience gained during implementation, together with the efforts of the GoT to reform ILBANK have made it a more attractive institution for other International Financing Institutions (IFIs) and laid the groundwork for harmonizing development financing in the sector.

42. **Municipality Project Implementation Units (PIUs)** . At the local level, the project will be implemented by PIUs at the municipal/utility level to manage subproject implementation. A total of six PIUs will be established for the project at the local level, including PIUs in the Water and Wastewater utilities/SKIs in all five selected municipalities, to be responsible for implementation of the WSS sub-projects at the local level and one PIU in Kahramanmaras Municipality to be responsible for implementation of the solid waste sub-project. The PIUs will be primarily staffed by designated municipal/utility employees with the skills and qualifications to carry out fiduciary functions, as well as technical/contract management supervision with support from the supervision consultants. The local PIUs will have designated staff responsible for the core functions, including procurement, financial management, environmental and social safeguards, with minimum requisite qualifications as will be defined in the POM. In general, municipalities/utilities have staff on hand who can manage all aspects of sub-project implementation, and these may be assigned to the respective PIUs. However, where specific skills are required if not locally available, the PIUs could be supplemented by individual consultants as deemed necessary. The PIU staff will benefit from capacity building activities to enhance relevant skills as deemed necessary.

43. The PIUs, which will be responsible for effective management of the subprojects as described in the various sub project financing agreements, will be established within no later than 30 (thirty) calendar days after the respective municipality or utility has signed its first Sub-financing Agreements with ILBANK. ILBANK PMU will prepare and evaluate the tender documents for the investment and TA components, with representation from the respective municipalities on the evaluation committees. However, the municipalities/utilities will be the contracting authorities for relevant sub-projects. While most of the Metropolitan and many Provincial municipalities in Turkey have experienced and dedicated departments to run capital projects financed by IFIs, institutional capacities for sustaining outcomes through sound operations and maintenance will require further strengthening. The project therefore includes institutional strengthening activities to build their capacity during implementation under Component 2.

44. **Feasibility studies, designs, and construction supervision.** The feasibility reports of the proposed investments will be reviewed and approved by ILBANK and the Strategy and Budgeting Presidency (SBP). Design review and construction supervision will be performed by independent consultancy firms financed through the project. ILBANK’s regional offices will monitor the sub-project implementation progress monthly and will prepare monitoring reports.
Consequently, Regional Directorates will support the PMU by providing relevant information on time and coordinating with the municipalities/ utilities.

45. **Project Operations Manual (POM).** ILBANK will develop by project effectiveness a detailed POM for purposes of project implementation setting out: (i) policies and procedures relating to implementation of project components PIUs and contractors.

Page 23 of 94

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Input:
**The World Bank**
Municipal Services Improvement Project (P169996) and eligibility of sub-projects; (ii) Financial management and procurement arrangements and procedures; and (ii) safeguards obligations and procedures.

**B. Results Monitoring and Evaluation Arrangements**

46. ILBANK PMU will be responsible for Monitoring and Evaluation (M&E) under the project at the central level, and it will coordinate all M&E activities with the PIUs. ILBANK has experience in M&E through the previous and ongoing projects. The ILBANK PMU will collect data on results indicators from the participating municipalities/utilities. Project Progress reports will be prepared and submitted quarterly by ILBANK. M&E activities, including monitoring of implementation progress and results, will be reviewed by the World Bank as part project supervision missions to be carried out at least twice a year. The incremental costs for the project M&E arrangements will be covered under Component 2 Project Management.

47. A mid-term review of the project will be carried out around two years after commencement of the project to assess overall implementation progress and identify and resolve any key issues affecting implementation. An evaluation will also be carried out at the end of the project as an input to the Implementation Completion and Results Report to evaluate final results, assess overall performance, and capture key lessons.

**C. Sustainability**

48. **Sustainability of the municipal investments and service delivery will depend on the utilities ability to mobilize the**

**necessary technical and financial resources to manage the new assets effectively.** The financial sustainability of
utilities and/or municipalities in Turkey is underpinned by their ability to: (a) report positive operating balances (recurring operating revenues – recurring operating expenditures > 0); and (b) fund at least part of their capital expenditure from their own funds (positive operating balance). The four SKIs that will receive loans under the project all reported positive operating margins in FY2018: 15.6 percent for Adana SKI, 32.2 percent for Kahramanmaraş SKI, 33.7 percent for Kayseri SKI, and 20 percent for Osmaniye Municipality. The dialogue concerning SKI or municipality performance and the Performance Improvement Action Plans to be supported through the TA Component of the project will seek to ensure that issues of sustainability, including financial aspects are addressed through specific actions identified by the respective institutions.

49. **Institutionally, sustainability will also be enhanced through implementation of the proposed technical assistance**

**measures aimed at targeted performance improvement for municipalities/utilities under the project.** The TA
component will seek, inter-alia, to: (i) promote more effective and efficient utility management in line with good practices; (ii) provide support to the ILBANK Project Management Unit (PMU) and municipalities/utilities in embedding local-level actions that link with EU policy directives on climate change, energy efficiency, water, solid waste management, and in building awareness on international best practices to promote and implement sustainable utility operations; and (iii) support provision of training and capacity building to municipalities; with an aim to improve operational efficiency, financial sustainability and customer satisfaction. The Bank will also draw upon additional resources in line with initiatives such as the proposed _Utilities for the Future_ Technical Assistance Program financed by GWSP to support utilities in improving their overall performance. Under the proposed project, the participating utilities will attend trainings on utility performance improvement and financial management to improve their knowledge capacity to improve recovery of Operational and Maintenance (O&M) and investment costs.

Page 24 of 94

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Input:
**The World Bank**
Municipal Services Improvement Project (P169996) 50. **Technical sustainability of the physical assets will also depend on quality assurance provided through effective**

**management of the design review taking into account climate change considerations and construction supervision**
**process.** Since all the proposed investments and technical assistance measures have been developed in line with the
relevant national policies and international best practice, expected results of the proposed project will contribute to sustainability of the actions at policy level.

**V.** **PROJECT APPRAISAL SUMMARY**

**A. Technical, Economic and Financial Analysis**

51. **Technical Analysis.** At appraisal stage it was expected that the project will finance a total of fifteen environmental infrastructure sub-projects in the five municipalities, spanning three environmental infrastructure sub-sectors, water supply, wastewater management and solid waste management, in addition to the Technical Assistance activities. A summary of the status of identified sub-project interventions by municipality at appraisal is provided in Table 1 below.
While feasibility studies and technical designs were prepared for nine of the municipal sub-projects identified at appraisal, design studies are ongoing for the additional six subprojects. The scope of investments and respective project footprints may change as part of a design review process to be carried out for all sub-projects prior to bidding for the construction works. The design review will, among other things, ensure that individual infrastructure facilities where appropriate consider adaptive designs that would allow for a scale up or scale down of capacity in the event of changes in the refugee population. The design review will be carried out by independent consultancy firms to be commissioned by ILBANK in each municipality on behalf of the municipalities. The same consultants will also be responsible for preparation of the bidding documents and construction supervision to ensure works quality control.
Most of the available engineering designs have been reviewed and conform to good practice, first by ILBANK and by the World Bank technical team and comments have been provided where gaps have been identified. Terms of reference for the design review and supervision consultants have been prepared by ILBANK and the selection process for the consultants will be initiated as soon as the terms of reference are cleared by the World Bank. Although the consultants will be procured by ILBANK, the respective municipalities shall be invited into the evaluation process and will sign the contracts once the sub-financing agreements are signed between ILBANK and the municipalities/utilities.
A summary of the status of each sub-contract is given below. ILBANK may also request the Bank’s no objection to pre-finance the consultants and be reimbursed through retroactive financing with the World Bank if deemed necessary.

**Table 1. Indicative List of Environmental Infrastructure Sub-Projects identified at appraisal**

**Est. Financing**
**Sub-Project Description**
**Need (m EUR)**

**Target**
**Municipality**

**Sub-Project**

**No.**

**Status of technical**

**designs (at**

**appraisal)**
Adana A.1 Kozan İmamoğlu Yedigöze Drinking Water 21.85 Available with Transmission Line sufficient quality A.1 Kozan İmamoğlu Yedigöze Drinking Water 21.85 Available with Transmission Line sufficient quality A.2 Yedigöze Water Treatment Plant 13.15 Ongoing A.3 Kozan Pınargözü Drinking Water 28.07 Available with Transmission Line and Network sufficient quality B.1 Kahramanmaraş Northern Districts 17.00 Available with Integrated Solid Waste Project sufficient quality B.2 Kahramanmaraş (Centrum) Drinking Water, 17.00 Available with Sewerage and Stormwater Project West Part sufficient quality A.3 Kozan Pınargözü Drinking Water 28.07 Available with Transmission Line and Network sufficient quality Kahramanmaraş B.1 Kahramanmaraş Northern Districts 17.00 Available with Integrated Solid Waste Project sufficient quality 17.00 Available with sufficient quality Page 25 of 94

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Input:
**The World Bank**
Municipal Services Improvement Project (P169996)

**Est. Financing**
**Sub-Project Description**
**Need (m EUR)**

**Target**
**Municipality**

**Sub-Project**

**No.**

**appraisal)**
B.3 Ceyhan Basin Wastewater Treatment Plants 8.40 Available for 3 WWTPs; Ongoing for

**Status of technical**

**designs (at**

1 WWTP B.4 Elbistan Drinking Water Network Project 8.00 Ongoing B.5 Kahramanmaraş (Centrum) Drinking Water, 18.80 Available Sewerage and Stormwater Project East Part with sufficient quality B.6 Elbistan Drinking Water Transmission Line 25.00 Ongoing review Kayseri C.1 Kayseri Wastewater Treatment Plant 25.00 Available Konya D.1 Akşehir Water Supply Project 4.71 Available but needs improvement D.2 Ilgin Wastewater Treatment Plant 3.90 Available and under revision D.3 Cumra Wastewater Treatment Plant 4.56 Available and under revision Osmaniye E.1 Osmaniye (Centrum) Drinking Water Project 27.65 Available with sufficient quality E.2 Osmaniye (Centrum) Sewerage Project 29.91 Ongoing review

**Economic and Financial Analysis**

52. The financial and economic analyses focus on sub-projects in the municipalities that will benefit from the loan proceeds, namely: Adana: for drinking water transmission lines and network; Kahramanmaras solid waste system, wastewater treatment plants (WWTP) and sewerage network projects; Kayseri WWTP project; and Osmaniye drinking water and sewerage network projects. Konya Aksehir water supply project and wastewater treatment plants have been left out as they are to be fully grant financed. The integrated solid waste management (ISWM) project in Kahramanmaras is justified based on financial and economic returns.

53. Financial Internal Rates of Return (FIRR) were estimated for the productive subprojects resulting generally in negative Financial Net Present Values (NPV) thus reflecting non-viability on solely commercial basis. Nonetheless, Component 2, TA component includes capacity building activities to utilities to improve operational efficiency in order to operate and maintain investments and deliver services in a sustainable manner. Such support will create conditions to move towards commercial viability. The Bank will also support the utilities in identifying and implementing performance improvements through other initiatives such as the Utilities for the Future Trust Program financed through a GWSP TF and implemented by the Water Global Practice and the ECA Water team. These types of support will foster better management practices for enhanced performance in the future of these utilities.

54. The economic Net Present Values (NPV) of the entire project’s lifetime is estimated at EUR 19.4 million on the basis of the present values of costs and benefits produced by the project. Economic IRR (E-IRR) was 11 percent with benefits to cost ratio of 1.09 for A) Adana Drinking Water and Transmission Sub-project, 10.4 percent and 1.02 for B) Kahramanmaras Wastewater Treatment Plants and 15.5 percent and 1.56 for Kahramanmaras solid waste, 12.2 percent and 1.64 for C) Kayseri WWTP project 23.82 percent and 9.17 for E) Osmaniye drinking water and sewerage network projects. Although estimated E-IRRs are slightly above the discount rate of 10 percent, they are comfortably Page 26 of 94

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Input:
**The World Bank**
Municipal Services Improvement Project (P169996) above the recommended discount rate of 6 percent per WB guideline [30] .

55. Sensitivity analyses have been carried out measuring change in the E-NPV due to changes in critical parameters including investment costs, personnel costs and power costs. Avoided GHG emissions improving economic benefits to the project due to more efficient wastewater collection, lower energy use for wastewater treatment, shift in solid waste management to a sanitary landfill from current disposal sites and energy efficiency gains from NRW reductions, were also considered as part of economic assessment. The benefits from estimated net emissions of the project based on defined investments at appraisal were estimated at EUR 57.5 million over the 30-year economic lifetime of the project [31] .

56. As the investments will be implemented under affiliated water utilities and/or municipalities, a baseline assessment of their financial position has been carried, to ensure financial sustainability based on 2018 and past three years’ trend data. Financial sustainability of utilities and/or municipalities are underpinned by their ability to: (a) report positive operating balances (recurring operating revenues – recurring operating expenditures > 0); and (b) fund at least part of their capital expenditure from their own funds (positive operating balance as explained above). Current margin reported in FY2018 by Adana SKI was 15.6 percent, 32.2 percent for Kahramanmaras SKI and 33.7 percent for Kayseri SKI. Osmaniye Municipality closed FY2018 with an operating margin of 20 percent. With increased capital investments, utilities are projected to report balanced overall budget results, supported with debt financing and grant contribution as foreseen under the sub-projects. Results of financial baseline assessments are provided in the Annex 3, Financial Estimate section. Detailed financial management and creditworthiness analyses for sub-borrower water utilities and municipalities incorporating projections on fiscal performance, expenditure coverage and indebtedness indicated that sub-borrowers will have capacity to meet their financial commitments while remaining exposed to adverse economic conditions.

**B. Fiduciary**

**Financial Management**

57. The financial management arrangements for the project are satisfactory. The PMU established under the International Relations Department of ILBANK will be responsible for the financial management arrangements for the Project. The PMU has satisfactory arrangements for the Sustainable Cities Project I, II and its AF and the same arrangements will be adopted for Municipal Services Improvement Project in Refugee Affected Areas.

58. ILBANK will on-lend proceeds of the IBRD loan and on-grant the grant proceeds to the participating municipalities/utilities and will provide technical support to these municipalities/utilities in overseeing implementation of the investments. The procurements of the project will be conducted centrally by ILBANK with the participation of the Municipalities/utilities in the bid evaluation committees and concluded contracts will be signed by the relevant Municipalities/utilities. Payments to the suppliers will be registered directly by ILBANK upon submission of acceptable approval documents. The PMU in ILBANK will be responsible for the management of the Designated Accounts and project accounting and reporting. The project accounts will be subject to independent audit on an annual basis by the Treasury Controllers of the Ministry of Treasury and Finance of independent auditors. The 30 Additionally, there are other components that would generate tangible and intangible benefits not measured because of i) inability due to methodological reasons and ii) limited data to estimate benefits at the time of drafting the analysis into the PAD.
31 Using World Bank GHG Accounting Tool for Water sector lending projects average shadow price of carbon converted to Euro using EUR/US$ conversion rate of 0,90 for calculation in monetary terms.

Page 27 of 94

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Input:
**The World Bank**
Municipal Services Improvement Project (P169996) project audit report will be made publicly available according to the World Bank’s Access to Information Policy.

**Procurement**

59. ILBANK as the financial intermediary, as well as the beneficiary municipalities are public entities. Thus, the World Bank Procurement Regulations for IPF Borrowers – July 2016 revised in November 2017 and August 2018 (“Procurement Regulations”) will apply to the proposed Project. The World Bank's Guidelines on Preventing and Combating Fraud and Corruption in Projects Financed by IBRD Loans and IDA Credits and Grants, dated October 15, 2006 and revised in January 2011 and as of July 1, 2016 (“Anti-Corruption Guidelines”) will also apply to the proposed project. A General Procurement Notice will be published on the World Bank’s external website and United Nations Development Business online.

60. A draft Project Procurement Strategy for Development (PPSD) has been prepared by ILBANK as required by the Procurement Regulations to determine the optimum procurement approach to deliver the right procurement result under the proposed project. The PPSD was agreed between ILBANK and the World Bank. The PPSD proposed that all procurements will be conducted by the PMU with the support of ILBANK Investment Coordination Department as needed. The relevant municipalities/utilities will be invited to participate in the bid evaluation committees, sign the contracts and they will be responsible from the contract implementation through their PIUs supported with experts in the procurement and contract management. Considering four years project implementation period, the PPSD proposed to initiate procurements as early as possible for the timely implementation of the contracts.

61. The selection of the “Design Review and Supervision Consultant(s)” has been identified as the strategically important procurement although their contract values are relatively low. It is envisaged that the consultants will support the PMU for the preparation of the bidding documents for the infrastructure investments and consultants’ timely input is very critical for the initiation of the relevant procurements planned in the procurement plan. Following the Bank’s guidance for procurements in situations of urgent need of assistance, the selection of the consultants will be accelerated by adapting fit-for-purpose principle, and accordingly higher thresholds will be applied for the “consultant’s qualification-based selection” method to deliver the project development objectives within the duration of the project. All other infrastructure contracts are “strategic critical” for the municipalities. Hence, the selected consultant will also provide services to relevant municipalities/utilities for the quality assurance of the works and goods and timely completion of the contracts within their original contract prices. More details on the findings of the procurement assessment, the proposed procurement supervision arrangements, risks and relevant mitigation measures to address them are provided in Annex 4.

~~.~~ **C. Legal Operational Policies** .

**Triggered?**

Projects on International Waterways OP 7.50 No Projects in Disputed Areas OP 7.60 No ~~.~~ Page 28 of 94

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**The World Bank**
Municipal Services Improvement Project (P169996)

**D. Environmental and Social**

**Environment**

62. The project is categorized as “ _Substantial Risk_ ” within the World Bank’s Environmental and Social Framework (ESF), given that at appraisal stage it consisted of 15 identified infrastructure investments (subprojects) in 5 municipalities and target provinces which are host to among the largest numbers of refugees in urban settlements. The project is expected to have positive impacts on improving environmental infrastructure and hence, contributing to resilience in communities impacted by refugee influx. It is not expected that sub-projects will have significant adverse effects to human health and/or the environment. The project will not result in significant adverse cumulative and does not include activities that might involve transboundary impacts. Moreover, the areas likely to be affected by the project are not of high value and sensitivity.

63. Environmental and Social Standards (ESS) 1-10, with the exception of ESS 7 (the standard does not apply, as there are no indigenous or SSAHUTLC in Turkey) apply to the Project. The project also does not necessitate the application of OP 7.50: Projects on International Waterways [32] and OP 7.60: Projects in Disputed Areas. However, the urgent need for assistance to support the Government of Turkey's efforts to mitigate rising pressures on service delivery from the continual influx of people across the border and from camps to cities has required the Bank policy OP 10, para 12 – Projects prepared in a Situation of Urgent Need of Assistance or Capacity Constraints to be applied.

64. The water supply subprojects will include the construction of water treatment plants, construction of new and extension of existing water distribution networks and transmission line, expansion of water reservoir capacities, and non-revenue water reduction activities such as installation of SCADA systems and development of water metering areas. Wastewater investments will include construction of new wastewater treatment plants or expanding their capacity, construction of new and extension of existing sewerage collection networks. Solid waste facilities will include new waste collection and transfer equipment, construction of two transfer stations and a landfill (including composting and mechanical separation facilities) in Afsin District of Kahramanmaraş, and rehabilitation or closure of existing dumpsites. These subprojects have potential environmental risks both during construction and operation phases.

65. In line with E&S standards that apply to the project, potential environmental and social risks associated with the construction and operation of the wastewater treatment plants and solid waste landfills are: (i) generation of noise, dust, wastewater, excess material and other waste in the construction phase; (ii) emission of dust, bio-aerosols, odors, and vehicle exhaust during waste collection and transportation; (iii) contaminated runoff, leachate generation and landfill gas emissions; groundwater contamination; (iv) noise and vibration from the operation of waste processing equipment; (v) fire and explosion risks due to landfill gas; (vi) community health and safety impacts such as visual, dust and odor problems, as well as scavenging related impacts and physical, chemical and biological hazards; (vii) occupational health and safety impacts such as accidents and injuries, chemical exposure, noise and vibration exposure and exposure to pathogens and vectors; (viii) closure and post-closure management of the landfills; (ix) discharge of treated wastewater to receiving bodies; (x) sludge and solids generation from wastewater treatment plants; (xi) emissions of hydrogen sulfide, methane, ozone, gaseous or volatile chemicals associated with WWTPs; and (xii) ecological impacts on the nearby receptors. Although ILBANK - the project implementing entity - has extensive experience in applying the Bank’s safeguard policies under MSP 1 and 2 and SCP 1 and 2, it lacks experience in managing complex and substantial-risk projects in Fragility-Conflict-Violence (FCV) contexts.

32 Based on sub-project selection criteria, projects triggering OP 7.50 are not eligible for participation under this project.

Page 29 of 94

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**The World Bank**
Municipal Services Improvement Project (P169996) 66. The World Bank and ILBANK teams have agreed on the environmental and social risk categorization and assessment requirements of each subproject as presented in Table 2 below.

67. ILBANK has prepared an Environmental and Social Management Framework (ESMF) for managing environmental and social impacts and risks of subprojects, and an Environmental and Social Commitment Plan (ESCP). The ESMF was consulted with stakeholders on November 26, 2019 and was disclosed on December 4, 2019. Subproject and sitespecific environmental impacts will be discussed in detail in the subproject specific environmental assessment documents (such as Environmental and Social Impact Assessment (ESIA) and Environmental and Social Management Plan (ESMP)) to be prepared by ILBANK, on behalf of related municipalities, during the project implementation phase.
ILBANK already completed the selection of Environmental and Social Consultancy Company for the preparation of subproject specific environmental and social assessment documents and initiated the preparation of documents accordingly. One of the key actors in the implementation of the ESMF will be ILBANK Project Management Unit (PMU). ILBANK will recruit additional environmental and social specialists (at least one environmental and one social) to increase PMU capacity during project preparation and implementation.

**Table 2. E&S Risk Categorization of Proposed Subprojects**

**E&S** **Risk**
**No** **Subproject**
**Categorization**

**E&S** **Risk** **E&S Assessment Requirements at**
**No** **Subproject**
**Categorization** **appraisal**

1-1 Kozan Imamoglu Yedigoze Drinking Water Substantial ESIA; SEP; Dam safety assessment; ExTransmission Line Post Social Audit for subproject 1-2 1-1 Kozan Imamoglu Yedigoze Drinking Water Substantial ESIA; SEP; Dam safety assessment; ExTransmission Line Post Social Audit for subproject 1-2 1-2 Yedigoze Water Treatment Plant 1-3 Kozan Pinargozu Drinking Water Transmission Line and Network 2-1 Kahramanmaras Northern Districts Integrated Solid Substantial ESIA; SEP; LARAP Waste Project Substantial Substantial ESIA; SEP; LARAP 2-2 Kahramanmaraş (Centrum) Drinking Water, Sewerage and Stormwater Project West Part 2-2 Kahramanmaraş (Centrum) Drinking Water, Moderate ESMP; SEP _(covering subprojects 2-2,_ Sewerage and Stormwater Project West Part _2-3, 2-4, 2-5, and 2-6)*_ ; Ex Post Social 2-3 Kahramanmaraş (Centrum) Drinking Water, Audit for subproject 2-2 Sewerage and Stormwater Project East Part 2-4 Ceyhan Basin Wastewater Treatment Plants Substantial ESIA; SEP _(covering subprojects 2-2,_

- Ekinozu WWTP and Collectors _2-3, 2-4, 2-5, and 2-6)*_ ; LARAP

- Caglayancerit WWTP

- Andirin WWTP and Collectors

- Goksun WWTP and Collectors

2-5 Elbistan Drinking Water Network Project Moderate ESMP; SEP _(covering subprojects 2-2,_ 2-6 Elbistan Drinking Water Transmission Line _2-3, 2-4, 2-5, and 2-6)*_ ; LARAP 3-1 Extension of Kayseri Wastewater Treatment Plant Substantial ESIA; SEP Substantial ESIA; SEP _(covering subprojects 2-2,_ _2-3, 2-4, 2-5, and 2-6)*_ ; LARAP 2-5 Elbistan Drinking Water Network Project Moderate ESMP; SEP _(covering subprojects 2-2,_ 2-6 Elbistan Drinking Water Transmission Line _2-3, 2-4, 2-5, and 2-6)*_ ; LARAP 3-1 Extension of Kayseri Wastewater Treatment Plant Substantial ESIA; SEP 4-1 Aksehir Water Supply Project Moderate ESMP; SEP 4-2 Ilgin Wastewater Treatment Plant _Assessment pending at appraisal_ 4-3 Cumra Wastewater Treatment Plant _Assessment pending at appraisal_ 5-1 Osmaniye (Centrum) Drinking Water Project Moderate ESMP; SEP 5-2 Osmaniye (Centrum) Sewerage Project _* For subprojects in Kahramanmaras, 2 SEPs will be prepared in total; one for No 2-1, and one for No 2-2, 2-3, 2-4, 2-5, and 2-6._ 68. **Safety of Dams.** One sub-project in Adana includes the 34 km long Kozan İmamoğlu Yedigöze Drinking Water Page 30 of 94

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**The World Bank**
Municipal Services Improvement Project (P169996) Transmission Line, which will be fed by the Yedigöze reservoir on the Yedigoze dam/hydropower plant. The Yedigöze hydropower plant was built on the Seyhan River in Adana province between 2006 and 2010. The main purposes of the plant are hydropower and irrigation. It is owned and operated by SANKO, a private Turkish company, under a Build-Operate-Transfer project licensed by the Ministry of Energy and Natural Resources (MENR). The Bank Dam Safety Expert visited Adana to conduct a due diligence on dam safety aspects for Yedigöze dam as part of project preparation. Yedigoze dam and its appurtenant works were built 10 years ago, and they are well operated and maintained by SANKO, which is responsible for the safety of its facilities. Devlet Su Isleri (DSI) the State agency responsible for water resources management and irrigation ensures the state supervision in accordance with the applicable legislation, and was directly involved in all project stages, from the feasibility study to the reservoir impoundment, and it ensures that the operator implements all required safety measures. In this context, DSI examines all reports related to dam operation and safety and carries out regular dam inspections (twice a year).

69. DSI confirmed the sound state and behavior of the dam and its appurtenant structures. Moreover, the board of experts under the Ministry of Agriculture and Forest carried out an inspection in December 2015 and issued a positive opinion regarding the safety conditions of the Yedigöze dam. This report, which confirms the general good conditions and performance of the dam, can be accepted by the WB as previous dam safety assessment, this is in accordance with OP4.37 requirements. SANKO personnel in charge of the surveillance of the dam are well organized and perform daily routine inspections and maintenance checks. The dam and its appurtenant structures are equipped with 272 monitoring instruments divided into 15 different categories; measurements are automatic and/or manual. Analysis and interpretation of the measurements are made by both SANKO and DSI, and dam surveillance reports are issued quarterly. The instrumentation Plan, the Operation & Maintenance Plan and the Emergency Preparedness Plan are regularly updated by SANKO and submitted to DSI for approval. Overall, the Bank expert’s general impression was positive, with both the operator and the state supervisory authority aware of the importance of the safety and the maintenance of its facilities. The project will finance technical assistance under Component 2 to have independent dam safety specialists, including competent dam safety specialists of DSI, acceptable to the Bank carry out a safety inspection of the above-mentioned dams, based on terms of reference acceptable to the Bank, at intervals of not less than once every five years according to Good International Industry Practice, during the implementation and after completion of the Project. The first of said safety inspections shall be carried out not later than December 2020.

**Social**

70. **Social risk is rated as Substantial.** Social risks and impacts intrinsic to the project are comparable to other municipal investments carried out under the Bank financed Sustainable Cities Projects 1 and 2 with ILBANK, which are assessed as Moderate. Contextual risks are rated Substantial because the sub-projects to be financed under the project are designed in such manner to enable broad population to benefit, regardless of their nationality or any vulnerability.
Such approach should allow the management of contextual risks, which may otherwise be considered High. Main social impacts are expected to be manageable and limited to stakeholder engagement with various host communities and refugees, economic displacement with limited livelihood impacts, limited labor influx impacts expected during construction phase, and community health and safety impacts caused by investments in wastewater treatment and solid waste facilities. The ESMF and site – specific ESMPs will address such impacts and propose mitigation measures.
Major civil works are expected in association with the construction of water and solid waste treatment plans, while other investments will mainly include the construction of linear structures. SEA (sexual exploitation and abuse) risks are assessed as Low. The project will carry out a set of training activities on SEA prevention, which will target ILBANK and participating municipalities/utilities staff and civil works construction contractors. Project workers will be subject to the Code of Conduct, which will be included in the contracts for the civil works and project labor management Page 31 of 94

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**The World Bank**
Municipal Services Improvement Project (P169996) procedure. ILBANK prepared a project labor management procedure (LMP), which applies to project workers, including ILBANK staff and workers engaged in sub-projects including civil works contractors. Civil works contractors shall adopt the project LMP, which includes proposed Code of Conduct.

71. ILBANK prepared a Resettlement Framework (RF) as required by ESS5, which was disclosed on November 26, 2019 and consulted in conjunction with the ESMF and SEF on December 2, 2019. The majority of the sub-projects requiring land acquisition have already completed acquisition works. However, designs are currently still under review and revision, and may change the project footprint and thus the scope of land acquisition. Ex-post social audits of previous land acquisitions will identify any gaps with ESS 5 which need to be addressed and will be completed before the start of civil works of relevant sub projects. Resettlement Plans, and any other site-specific E&S documents will be finalized and approved by the Bank and disclosed prior to the beginning of tendering of works of each sub-project.

72. **Stakeholder Engagement and Citizen Engagement:** In line with ESS 10, ILBANK prepared a Stakeholder Engagement Framework, outlining general principles and a collaborative strategy to identify stakeholders and plan for an engagement process in accordance with ESS10. In addition, the SEPs for each municipality will be prepared. The borrowing municipalities and utilities will implement SEPs including timely information disclosure in accessible manner, engaging stakeholders across host and refugee communities in the project areas, with an overall aim to prevent any social tensions and perceptions of unequal access to project benefits. Before project implementation, Municipalities will develop information booklet/leaflets in Turkish and Arabic describing subproject intended outcomes including the need of land expropriation, which will be shared among the project affected parties (PAPs) during resettlement plan preparation work. The SEF/SEP includes a two-level project level Grievance Redress Mechanism (GRM): the first at the municipal level and the second at ILBANK level. Municipalities will ensure that the GRMs are functional and accessible to the refugee and host communities in the languages they speak for any issues that they would like to address. Municipalities will report on the percentage of grievances resolved within a stipulated time frame and the project will utilize Citizen Report Cards at the beginning and end-term to assess if the municipal investments improved the cities’ current infrastructure and addressed the prior needs of both host and refugee communities. Additional citizen engagement activities are described under Component 2 c (ii).

73. **Additionally, citizen engagement activities to facilitate effective two-way engagement among stakeholders,**

**including Turkish citizens and refugees, municipalities, and SKIs, will seek to identify the needs and priorities of**
**beneficiary groups to improve access to effective municipal services.** These activities will be planned and
implemented by ILBANK in a participatory manner with the support of non-governmental organizations (NGO)’s selected by ILBANK. They will be identified through the project and be described in the Project Operations Manual.
The activities will seek to address concerns on issues relating to planning, implementation, and delivery of municipal services, particularly environmental infrastructure services covered under the project, as well as any related issues affecting social cohesion among host and refugee communities. Citizen engagement activities will where possible leverage and be carried out in close collaboration with other World Bank managed activities, such as the proposed _Social Entrepreneurship, Empowerment, and Cohesion Project_ (P171456), which will develop and apply a set of participatory citizen engagement tools to facilitate engagement with host and refugee populations, and the proposed _State Building Fund (SPF) Project’s Information, Counseling and Referral Support Program,_ which will cover, inter-alia, referral to municipality-run support activities, as appropriate. Leveraging of citizen engagement activities with the mentioned activities will be carried out in selected municipalities where there is an overlap between the individual projects, such as Adana, Kahramanmaras, and Osmaniye. Experience from these activities will however help to inform activities in other areas. Activities under the SPF will, inter alia, include information related to municipal services. The specific interactions between these operations will be further defined and agreed in close collaboration with the Page 32 of 94

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**The World Bank**
Municipal Services Improvement Project (P169996) respective projects early during implementation. The Bank will facilitate collaboration on the FRIT projects as possible with the citizen engagement activities of ILBANK.

74. **Gender:** Turkey ranks 130th out of 149 countries in the World Economic Forum’s Global Gender Gap Report [33] . As part of project preparation, gender analysis was undertaken, together with a detailed literature review and focus group discussions with women from both refugee and host communities, to identify specific gender gaps among host and refugee populations in the project areas. While individual living conditions of SUTPs vary with factors such as socioeconomic status and location of settlements, evidence from the analysis suggests that the poor housing conditions, including overcrowding and associated access to services such as safely managed water and sanitation for a large proportion of the lower income refugee communities is an issue.

75. The project scope narrows down to three specific gender gaps that could be addressed through project implementation. First, there is a clear lack of voice for both Turkish and refugee women. Research on women’s representation in local level governance shows one of the lowest rates in the world. In 2014, women constituted 2.8 percent of the Mayors and 10.7 percent of the municipal Councilors. [34] According to the Urban Refugee Network [35], many Syrian refugee women lack a forum to discuss needs, share information and exercise community leadership. A UN Needs Assessment of Syrian women refugees carried out in 2018 found that nearly half of the refugee women in Adana had no social relationships with the Turkish host community due to seclusion (15 percent did not leave their homes), and the lack of social ties was greater for women with less education [36] . Second, refugee women have limited economic opportunities. According to the gender analysis, only 15 percent of refugee women are engaged in income generating jobs [37] . The same assessment indicated that only a small number of women (7 percent) have taken part in vocational training, and when they do take part the most popular areas of study are hairdressing (30 percent) and needlework (27 percent), which are closely related to traditional gender roles and provide limited opportunity for formal employment. And finally, there is lack of access to information that also includes language barriers. While women are mainly responsible for management and use of services such as water, sanitation, hygiene and waste management at the household level, they have limited interaction with host communities if they do not work outside.
From the UN Women’s Needs Assessment, Syrian women are unaware of various support services: for example, 68 percent of women do not know about free legal counselling; 63 percent about home care, 59 percent about psychosocial support and 57 percent about childcare services. This applies to the project areas. In Kahramanmaraş, for example, the Municipality has introduced a subsidized water-use scheme for families in need. However, women seem to have insufficient knowledge and awareness of such schemes, which highlight a need for enhanced communication and information sharing in a manner and language accessible to them.

76. While there are other on-going projects in the country that promote female employment [38], this project will promote three main actions to improve gender outcomes. First, the project will encourage refugee women to engage more actively with host communities and participate in decision-making to identify their priorities for support through the 33 World Economic Forum’s Global Gender Gap Report for 2018. _[http://www3.weforum.org/docs/WEF_GGGR_2018.pdf](http://www3.weforum.org/docs/WEF_GGGR_2018.pdf)_ 34 Savas-Yavuzchere, P. and Cigeroglu-Oztepe, Misra 2016. “the Representation of Women in Turkish Local Governments.
[http://journals.euser.org/files/articles/ejis_jan_apr_16/Pinar.pdf](http://journals.euser.org/files/articles/ejis_jan_apr_16/Pinar.pdf) 35 Urban Refugee Women’s Network – Turkey. _[https://www.refworld.org/pdfid/5a38e20a4.pdf](https://www.refworld.org/pdfid/5a38e20a4.pdf)_ 36 UN Women. 2018 Needs Assessment of Syrian Women and Girls. https://www2.unwomen.org/[/media/field%20office%20eca/attachments/publications/country/turkey/the%20needs%20assessmentengwebcompressed.pdf?la=en&vs=](https://www2.unwomen.org/-/media/field%20office%20eca/attachments/publications/country/turkey/the%20needs%20assessmentengwebcompressed.pdf?la=en&vs=3139)
[3139](https://www2.unwomen.org/-/media/field%20office%20eca/attachments/publications/country/turkey/the%20needs%20assessmentengwebcompressed.pdf?la=en&vs=3139) 37 Source: United Nations Needs Assessment of Syrian Women and Girls under Temporary Protection Status in Turkey, June 2018 38 For example, the Social Entrepreneurship. Empowerment and Cohesion In refugee and Host communities in Turkey Project Page 33 of 94

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**The World Bank**
Municipal Services Improvement Project (P169996) project at the neighborhood level. This will include specific actions to promote women voices and empower them to make decisions concerning their needs and priorities within the scope of the project. The project will specifically encourage adequate women’s representation at the community level decision-making forum under component 2d).
The project will help create a safe space for refugee and host country women to share their views, needs, and suggestions by setting-up of separate meetings for women only to respect existing cultural norms. Decisions made will be recorded and shared with the participating municipalities to be reflected in further planning, decision-making and implementation of the project throughout the project implementation. Staff of the participating municipalities and utilities are trained to be sensitized for existing gender bias and norms, so that they could respond to these gender-disaggregated specific needs and requests from the community level decision-making forums. Second, the project will encourage municipalities to provide information for decision-making on their policies, plans, investments and available services in a format and language (Arabic and Turkish) that is user-friendly and accessible to women and the organizations that represent them. In addition, the project will undertake an education and awareness campaign, support WASH initiatives that are sensitive to household gender inequalities and promote behavior change. Third, the project will support and promote the formation of women-led community level groups, where possible, to manage operation and maintenance for hygiene and sanitation infrastructure at the neighborhood level in the selected low-income communities with significant refugee and host populations, and will provide training to empower them to do so. This will extend women’s household role as water managers to the neighborhood and give them voice. The project will encourage monitoring and management of municipal services to be identified in collaboration with relevant municipalities. Combining Turkish and refugee women on the committees could support social cohesion as well enabling them to better understand each other’s cultures.

77. These actions will be measured through the following indicators: (i) percentage of women’s needs and investment choices that were implemented by selected municipalities and SKIs (baseline 0%; target 70%); and (ii) The satisfaction rate of female users of WSS services and facilities provided by the project and their perception of responsiveness of the project to their needs and preferences (baseline 0%; target 70%). A survey will be conducted for a sample of communities at the baseline stage and at the end of project to assess the satisfaction with project outcomes by host and refugee communities.

**VI.** **GRIEVANCE REDRESS SERVICES**

78. Communities and individuals who believe that they are adversely affected by a World Bank (WB) supported project may submit complaints to existing project-level grievance redress mechanisms or the WB’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed in order to address project-related concerns.
Project affected communities and individuals may submit their complaint to the WB’s independent Inspection Panel which determines whether harm occurred, or could occur, as a result of WB non-compliance with its policies and procedures. Complaints may be submitted at any time after concerns have been brought directly to the World Bank's attention, and Bank Management has been given an opportunity to respond. For information on how to submit complaints to the World Bank’s corporate Grievance Redress Service (GRS), please visit _[http://www.worldbank.org/en/projects-operations/products-and-services/grievance-redress-service](http://www.worldbank.org/en/projects-operations/products-and-services/grievance-redress-service.%20For)_ . For information on how to submit complaints to the World Bank Inspection Panel, please _[visit www.inspectionpanel.org.](http://www.inspectionpanel.org/)_

**VII.** **KEY RISKS**

Page 34 of 94

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**The World Bank**
Municipal Services Improvement Project (P169996) 79. **The overall project risk is rated as Substantial** and risks in this category are briefly described below.

80. **Political and Governance risks are rated Moderate.** These risks are primarily related to the overall political context of the Syrian refugee crisis and its broader implications on stability in Turkey and the broader region. Specific political risks relate to the possibility of changes in the refugee population in form of either further increase or reductions depending on prevailing conditions, and potential impacts on project design. Water and sanitation investments will as far as possible be designed to accommodate different populations using phased or modular systems where appropriate. Further political risks are linked to local political and social cohesion risks associated with the refugee influx and potential implications on support for the project. The project through the citizen engagement component will seek to promote dialogue among host and refugee communities to improve social cohesion.

81. **Macroeconomic risk is rated as Substantial.** The Turkish economy experienced instability between 2018-2019, following a period of growing macro imbalances and economic overheating in 2017-2018. The economy has stabilized more recently thanks to important external adjustments: a reversal in current account imbalances, declining external debt of banks, and a gradual recovery in forex reserves. These have contributed to currency stability. There are a priori three possible macroeconomic risks to the project. The first is currency risk for municipalities. Though the Lira has been more stable recently, uncertainty in global markets, including from the recent Coronavirus outbreak pose risks for all emerging markets. Some of the risk could be offset by trade diversion from China that benefits Turkey.
The second relates to the authorities’ fiscal consolidation path, which assumes a sharp decrease in capital expenditure. This may or may not affect public investment plans under the project as some of this risk may be mitigated by external project financing. Thirdly, the construction sector is among the most severely hit in the current downturn – leverage and exposure to forex debt will affect construction companies’ ability to respond to an increase in specialized construction investment under the project. Some of this risk may be mitigated by the availability of spare capacity in the construction sector, that may allow construction companies to respond quickly.

82. **Technical design of project risk.** There is a moderate potential risk that the implementation of activities financed from one source is given priority by certain municipalities over activities from another source. ILBANK and the selected municipalities will be required to clearly reflect in the Project Implementation Plan the concurrent parallel implementation of project activities financed from both sources, and to report on this aspect of implementation s as part of progress reporting to the Bank, as will be defined in the Project Operations Manual.

83. **Institutional Capacity for Implementation and Sustainability risk:** There is an increased implementation capacity risk given ILBANK’s expanding project portfolio with currently about US$730 million for Sustainable Cities series of project alone. This risk is to be mitigated through strengthening of ILBANK’s PMU capacity with additional staff in accordance with a Staffing Plan proposed by ILBANK. The list of additional staff and timing for their appointments was agreed with the Bank during appraisal and timeframes have been included as effectiveness conditions even though most of the staff are expected to be appointed before this date. ILBANK has requested retroactive financing from the IBRD loan to finance appointment of the additional PMU staff prior to effectiveness.

84. **Stakeholder risk is rated as Substantial.** This risk reflects past history where municipalities/utilities have withdrawn from similar projects either immediately before negotiations or subsequent to loan signing due to internal political and financial considerations. To mitigate this risk, municipalities/utilities are required to provide Municipal Executive Board/Utility Executive Board Decisions in support of their participation in the project and are also required to prepare feasibility studies that include a financial assessment of the sub-project and the municipality. The risk rating also reflects possible community resistance to certain investments. To mitigate this risk, required Environmental and Page 35 of 94

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.

**The World Bank**
Municipal Services Improvement Project (P169996) Social Impact Assessments (ESIAs) or Environmental and Social Management Plans (ESMPs) will be prepared for each sub-project investment and a grievance redressal mechanism will be set up within the project. In addition, other citizen engagement mechanisms will also be exploited during the implementation period.

85. **The project’s Environmental risk has been rated Substantial.** The environmental risk has been downgraded to Substantial following the Concept stage after site visits carried out by Bank team. It is not expected that sub-projects will have significant adverse effects to human health and/or the environment and that the project will not result in transboundary impacts since there are no sub-projects in transboundary basins. Moreover, the areas likely to be affected by the project are not of high value and sensitivity. Appropriate mitigation measures for identified risks are highlighted in the relevant Safeguards documents.

86. **The Social Risk Rating has been rated Substantial.** The project will have overall positive social impacts on improving environmental infrastructure in provinces known to host the largest numbers of refugees in urban settlements. Social risks and impacts intrinsic to the project are comparable to other municipal investment carried out under the Bank financed Sustainable Cities Projects 1 and 2 with ILBANK which are assessed Moderate. Social risks are rated Substantial because the sub projects to be financed under the project are designed to benefit a broad population regardless of nationality or any vulnerability, which is considered to allow management of contextual risks which may otherwise be High. Risks related to the capacity of implementation agency (ILBANK) to manage social impacts is considered Substantial because ILBANK will be applying ESF for the first time. This will be mitigated by the hiring of an additional social specialist in the PMU as well as training of staff on the ESF.

87. **Other risks rated as substantial pertain to the following.** 88. **Timeframe for EU grant approval and associated financing gap.** The signing of the Administrative Agreement (AA) between the World Bank and the EU for the grant is subject to finalization of an update to the 2016 World Bank Group-EU Framework Agreement, which is under discussion by the parties. Accordingly, the project is presented to the Board with a financing gap for the grant, subject to signature of the AA. The European Commission (EC), in May 2019, invited the World Bank to enter into formal discussions with the EU Delegation in Turkey on the project design, to lead to a Contract between the Parties in the form of the AA. The Bank team has conducted such discussions with the EUD throughout the project preparation process and has reflected key aspects in the project design. To mitigate the risk of a potential delay in finalizing the update of the WBG-EU Framework Agreement, Technical Discussions for the grant were conducted along with the negotiations for the IBRD loan, to reduce the timeframe for Grant approval and signature once the Administration Agreement is signed. The Technical Discussions involved a full discussion and agreement between ILBANK and the World Bank on the terms and conditions of the draft Grant Agreement.
Conclusion of the grant negotiations, based on the Technical Discussions, will be done after signing of the AA. ILBANK has indicated its preference to sign the loan and grant agreements with the Bank at the same time. However, should there be a significant delay in signing the grant, or non-approval of the grant, ILBANK would be able to sign the loan agreement and access IBRD funds prior to accessing the grant. Project activities have been structured to separate loan and grant financed activities in the Procurement Plan to allow implementation of the former to proceed while waiting for the AA to be signed, should it become necessary.

Page 36 of 94

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**The World Bank**
Municipal Services Improvement Project in Refugee Affected Areas (P169996)

**VIII.** **RESULTS FRAMEWORK AND MONITORING**

**Results Framework**

**COUNTRY: Turkey**
**Municipal Services Improvement Project**

**Project Development Objectives(s)**

The Project Development Objective (PDO) is to improve host and refugee communities access to safely managed water supply, sanitation and solid waste services in selected municipalities affected by the influx of Syrians Under Temporary Protection in Turkey.

**Project Development Objective Indicators**

**RESULT_FRAME_TBL_PDO**

**Indicator Name** **DLI** **Baseline** **End Target**

**To improve host and refugee communities access to environmental infrastructure services**

People benefitting from safely managed drinking water services 0.00 1,950,193.00 in the selected municipalities as a result of the project (Number) People benefitting from safely managed drinking water services in the selected municipalities (out of which female) (Percentage) People benefitting from safely managed drinking water services in the selected municipalities (out of which host community) (Number) People benefitting from safely managed drinking water services in the selected municipalities (out of which refugees) (Number) 0.00 51.00 0.00 1,728,142.00 0.00 222,051.00 People benefitting from safely managed sanitation services in 0.00 2,402,023.00 the selected municipalities as a result of the project (Number) Page 37 of 94

A dataset, survey, database, index, census, registry, or information system with a specific proper name that can be cited, queried, or downloaded as a data source

A data source described by its characteristics or producer rather than a proper name, containing a data noun and at least one identifying descriptor

A general reference to data, information, or statistics that contains a data noun but lacks enough specificity to identify the exact source


Input:
**The World Bank**
Municipal Services Improvement Project in Refugee Affected Areas (P169996)

**RESULT_FRAME_TBL_PDO**

**Indicator Name** **DLI** **Baseline** **End Target**

People benefitting from safely managed sanitation services in 0.00 50.00 the selected municipalities (out of which female) (Percentage) People benefitting from safely managed sanitation services in the selected municipalities (out of which host community) (Number) 0.00 2,165,834.00 People benefitting from safely managed sanitation services in 0.00 236,189.00 the selected municipalities (out of which refugees) (Number) People benefitting from safely managed solid waste services in 0.00 320,685.00 the selected municipalities as a result of the project (Number) People benefitting from safely managed solid waste services in the selected municipalities (out of which female) (Percentage) People benefitting from safely managed solid waste services in the selected municipalities (out of which host community) (Number) People benefitting from safely managed solid waste services in the selected municipalities (out of which refugees) (Number)

**PDO Table SPACE**

**Intermediate Results Indicators by Components**

0.00 49.00 0.00 288,616.00 0.00 32,069.00

**RESULT_FRAME_TBL_IO**

**Indicator Name** **DLI** **Baseline** **End Target**

**Environmental Infrastructure Investments**

Water supply network constructed, rehabilitated and/or 0.00 2,062.00 extended (Kilometers) Page 38 of 94

A dataset, survey, database, index, census, registry, or information system with a specific proper name that can be cited, queried, or downloaded as a data source

A data source described by its characteristics or producer rather than a proper name, containing a data noun and at least one identifying descriptor

A general reference to data, information, or statistics that contains a data noun but lacks enough specificity to identify the exact source


Input:
**The World Bank**
Municipal Services Improvement Project in Refugee Affected Areas (P169996)

**RESULT_FRAME_TBL_IO**

**Indicator Name** **DLI** **Baseline** **End Target**

Water treatment plants constructed or rehabilitated (Number) 0.00 1.00 Water reservoirs constructed or rehabilitated (Number) 0.00 43.00 Water pumping stations constructed or rehabilitated (Number) 0.00 16.00 Sewerage network constructed, rehabilitated and/or extended 0.00 495.00 (Kilometers) Wastewater treatment plants constructed or rehabilitated 0.00 7.00 (Number) Landfills constructed or rehabilitated (Number) 0.00 1.00 Satisfaction rate of female users of environmental infrastructure 0.00 70.00 services and facilities provided by the project (Percentage)

**Technical Assistance**

Number of municipal authorities and SKIs provided with capacity 0.00 5.00 building support through the Project (Number) Number of municipal authorities and SKIs that have prepared a Performance Improvement Action Plan through the project (Number) 0.00 4.00 Grievances registered related to delivery of municipal services 0.00 90.00 that are actually addressed and recorded (Percentage) Percentage of women’s needs and investment choices that were 0.00 70.00 implemented by selected municipalities and SKIs (Percentage)

**IO Table SPACE**

**UL Table SPACE**

Page 39 of 94

A dataset, survey, database, index, census, registry, or information system with a specific proper name that can be cited, queried, or downloaded as a data source

A data source described by its characteristics or producer rather than a proper name, containing a data noun and at least one identifying descriptor

A general reference to data, information, or statistics that contains a data noun but lacks enough specificity to identify the exact source


Input:
**The World Bank**
Municipal Services Improvement Project in Refugee Affected Areas (P169996)

**Monitoring & Evaluation Plan: PDO Indicators**

**Methodology for Data**
**Indicator Name** **Definition/Description** **Frequency** **Datasource**
**Collection**

**Responsibility for Data**
**Collection**

Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Page 40 of 94 People benefitting from safely managed drinking water services in the selected municipalities as a result of the project People benefitting from safely managed drinking water services in the selected municipalities (out of which female) People benefitting from safely managed drinking water services in the selected municipalities (out of which host community) People benefitting from safely managed drinking water services in the selected municipalities (out of This indicator measures the cumulative number of people benefitted from safely managed drinking water services in the selected municipalities that have been provided through this Project.

This indicator measures the percentage of female benefitted from safely managed drinking water services in the selected municipalities that have been provided through this Project.

This indicator measures the percentage of host community benefitted from safely managed drinking water services in the selected municipalities that have been provided through this Project.

This indicator measures the percentage of refugees benefitted from safely Semiannually Semiannually Semiannually Semiannually Reports from PMU Reports from PMU Reports from PMU Reports from PMU Data to be compiled by municipal PIUs and recorded in PMU progress reports, based on updated beneficiary’s records from respective SKIs.

Data to be compiled by municipal PIUs and recorded in PMU progress reports, based on updated beneficiary’s connection records from respective SKIs.

Data to be compiled by municipal PIUs and recorded in PMU progress reports, based on updated beneficiary’s records from respective SKIs.

Data to be compiled by municipal PIUs and recorded in PMU

A dataset, survey, database, index, census, registry, or information system with a specific proper name that can be cited, queried, or downloaded as a data source

A data source described by its characteristics or producer rather than a proper name, containing a data noun and at least one identifying descriptor

A general reference to data, information, or statistics that contains a data noun but lacks enough specificity to identify the exact source


Input:
**The World Bank**
Municipal Services Improvement Project in Refugee Affected Areas (P169996) which refugees) managed drinking water services in the selected municipalities that have been provided through this Project.

Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Page 41 of 94 People benefitting from safely managed sanitation services in the selected municipalities as a result of the project People benefitting from safely managed sanitation services in the selected municipalities (out of which female) People benefitting from safely managed sanitation services in the selected municipalities (out of which host community) People benefitting from safely managed sanitation services in the selected municipalities (out of which This indicator measures the cumulative number of people benefitted from safely managed sanitation services in the selected municipalities that have been provided through this Project.

This indicator measures the percentage of female benefitted from safely managed sanitation services in the selected municipalities that have been provided through this Project.

This indicator measures the percentage of host community benefitted from safely managed sanitation services in the selected municipalities that have been provided through this Project.

This indicator measures the percentage of refugees benefitted from safely Semiannually Semiannually Semiannually Semiannually Reports from PMU Reports from PMU Reports from PMU Reports from PMU progress reports, based on updated beneficiary’s records from respective SKIs.

Data to be compiled by municipal PIUs and recorded in PMU progress reports, based on updated beneficiary’s records from respective SKIs.

Data to be compiled by municipal PIUs and recorded in PMU progress reports, based on updated beneficiary’s records from respective SKIs.

Data to be compiled by municipal PIUs and recorded in PMU progress reports, based on updated beneficiary’s records from respective SKIs.

Data to be compiled by municipal PIUs and recorded in PMU

A dataset, survey, database, index, census, registry, or information system with a specific proper name that can be cited, queried, or downloaded as a data source

A data source described by its characteristics or producer rather than a proper name, containing a data noun and at least one identifying descriptor

A general reference to data, information, or statistics that contains a data noun but lacks enough specificity to identify the exact source


Input:
**The World Bank**
Municipal Services Improvement Project in Refugee Affected Areas (P169996) refugees) managed sanitation services in the selected municipalities that have been provided through this Project.

Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Page 42 of 94 People benefitting from safely managed solid waste services in the selected municipalities as a result of the project People benefitting from safely managed solid waste services in the selected municipalities (out of which female) People benefitting from safely managed solid waste services in the selected municipalities (out of which host community) People benefitting from safely managed solid waste services in the selected municipalities (out of which This indicator measures the cumulative number of people benefitted from safely managed solid waste services in the selected municipalities that have been provided through this Project.

This indicator measures the percentage of female benefitted from safely managed solid waste services in the selected municipalities that have been provided through this Project.

This indicator measures the percentage of host community benefitted from safely managed solid waste services in the selected municipalities that have been provided through this Project.

This indicator measures the percentage of refugees benefitted from safely Semiannually Semiannually Semiannually Semiannually Reports from PMU Reports from PMU Reports from PMU Reports from PMU progress reports, based on updated beneficiary’s records from respective SKIs.

Data to be compiled by municipal PIUs and recorded in PMU progress reports, based on updated beneficiary’s records from respective SKIs.

Data to be compiled by municipal PIUs and recorded in PMU progress reports, based on updated beneficiary’s records from respective SKIs.

Data to be compiled by municipal PIUs and recorded in PMU progress reports, based on updated beneficiary’s records from respective SKIs.

Data to be compiled by municipal PIUs and recorded in PMU

A dataset, survey, database, index, census, registry, or information system with a specific proper name that can be cited, queried, or downloaded as a data source

A data source described by its characteristics or producer rather than a proper name, containing a data noun and at least one identifying descriptor

A general reference to data, information, or statistics that contains a data noun but lacks enough specificity to identify the exact source


Input:
**The World Bank**
Municipal Services Improvement Project in Refugee Affected Areas (P169996) refugees) managed solid waste water services in the selected municipalities that have been provided through this Project.

**ME PDO Table SPACE**

progress reports, based on updated beneficiary’s records from respective SKIs.

**Monitoring & Evaluation Plan: Intermediate Results Indicators**

**Methodology for Data**
**Indicator Name** **Definition/Description** **Frequency** **Datasource**
**Collection**

**Responsibility for Data**
**Collection**

Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Page 43 of 94 Reports from PIUs Reports from PIUs Reports from PIUs Reports from PIUs Reports from PIUs Water supply network constructed, rehabilitated and/or extended Water treatment plants constructed or rehabilitated Water reservoirs constructed or rehabilitated Water pumping stations constructed or rehabilitated Sewerage network constructed, rehabilitated and/or extended Length of water supply network constructed, rehabilitated and/or extended due to project activity.

Number of water treatment plants constructed or rehabilitated due to project activities.

Number of water reservoirs constructed or rehabilitated due to project activities.

Number of water pumping stations constructed or rehabilitated due to project activities.

Length of sewerage network constructed, rehabilitated and/or extended due to project activities.

Semiannually Semiannually Semiannually Semiannually Semiannually

A dataset, survey, database, index, census, registry, or information system with a specific proper name that can be cited, queried, or downloaded as a data source

A data source described by its characteristics or producer rather than a proper name, containing a data noun and at least one identifying descriptor

A general reference to data, information, or statistics that contains a data noun but lacks enough specificity to identify the exact source


Input:
**The World Bank**
Municipal Services Improvement Project in Refugee Affected Areas (P169996) Reports from PIUs Reports from PIUs Targeted beneficiary satisfaction survey Reports from PIUs Reports from PIUs Wastewater treatment plants constructed or rehabilitated Landfills constructed or rehabilitated Satisfaction rate of female users of environmental infrastructure services and facilities provided by the project Number of municipal authorities and SKIs provided with capacity building support through the Project Number of municipal authorities and SKIs that have prepared a Performance Improvement Action Plan through the project Number of wastewater treatment plants constructed or rehabilitated due to project activities.

Number of landfills constructed or rehabilitated due to project activities.

Satisfaction rate of female users of environmental infrastructure services and facilities provided by the project and their perception of responsiveness of the project to their needs and preferences.

This indicator measures the number of municipal authorities and SKIs benefitted from capacity building activities in the selected municipalities that have been provided through this Project.

This indicator measures the number of municipal authorities and SKIs that have prepared a Performance Improvement Semiannually Semiannually Start and end of the project.

Semiannually Annually A targeted beneficiary satisfaction survey will be carried out among the targeted community groups at the start of the project and at an appropriate time after the services have been provided, towards the close of the project.

Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU The survey will be carried out by selected NGOs and consultants supported through the project, and results will be reported to the municipalities and ILBANK and the World Bank and EU.

Municipal PIUs and ILBANK PMU Municipal PIUs and ILBANK PMU Page 44 of 94

A dataset, survey, database, index, census, registry, or information system with a specific proper name that can be cited, queried, or downloaded as a data source

A data source described by its characteristics or producer rather than a proper name, containing a data noun and at least one identifying descriptor

A general reference to data, information, or statistics that contains a data noun but lacks enough specificity to identify the exact source


Input:
**The World Bank**
Municipal Services Improvement Project in Refugee Affected Areas (P169996) Action Plan through this Project.

Semiannually Before the hygiene and sanitation facilities are selected and after the facilities are implement ed.

Grievances registered related to delivery of municipal services that are actually addressed and recorded Percentage of women’s needs and investment choices that were implemented by selected municipalities and SKIs

**ME IO Table SPACE**

This indicator measures the number of grievances registered related to delivery of municipal services that are actually addressed and recorded in the selected municipalities through the Project.

Measuring women’s needs or investment choices regarding the hygiene and sanitation facilities under Component 2d that were implemented by selected municipalities and SKIs (baseline 0%; target 70%).

Reports from PIUs Needs assessment, Post-survey.

A survey will be conducted among women who participated in needs assessment activities after facilities are constructed. The survey will measure if their needs or investment choices are reflected in decisions made by municipality and SKI, and the built facilities are constructed in the way that they requested.

Municipal PIUs and ILBANK PMU Ilbank PMU and Municipalities/SKIs.

Page 45 of 94

A dataset, survey, database, index, census, registry, or information system with a specific proper name that can be cited, queried, or downloaded as a data source

A data source described by its characteristics or producer rather than a proper name, containing a data noun and at least one identifying descriptor

A general reference to data, information, or statistics that contains a data noun but lacks enough specificity to identify the exact source