Safeguards and Community Driven Development (CDD)

World Bank Safeguard policies are designed to prevent and mitigate undue harm to people and their environment in the development process. As the Bank’s environmental and social agendas have evolved, its safeguard policies have also shifted from focusing on mitigating the potential environmental and social damage towards a more comprehensive focus on sustainability of projects (a shift from do no harm towards do good). As such, the Bank’s social and environmental safeguard policies seek to ensure that relevant measures, capacities and processes are in place, and that their application helps Bank’s borrowers decide what actions and programs need to be taken to ensure the environmental and social soundness of projects. Safeguard policies also provide a platform for the participation of stakeholders in project design and selection, and have been an important instrument for building ownership among local populations.

• World Bank’s 10 + 1 safeguard policies

OP 4.01 Environmental Assessment
OP 4.04 Natural Habitats
OP 4.09 Pest Management
OPN 11.03 Cultural Property
OP 4.12 Involuntary Resettlement
OD 4.20 Indigenous Peoples
OP 4.36 Forestry
OP 4.37 Safety of Dams
OP 7.50 Projects on International Waterways
OP 7.60 Projects in Disputed Areas
BP 17.50 Public Disclosure

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• Guidance on compliance with safeguard policies in CDD programs

The processes outlined below are designed to guide compliance with the Safeguard Policies in CDD programs. In addition to these, it is recommended to have an ESSD staff member on the task team to help identify and address potential safeguard issues.




1. Project Identification

Where details of all sub-projects to be financed are known, CDDs are generally categorized as EA Category B. Depending on the location and nature of the sub-projects and their expected impacts, there may be justification for assigning a different EA category. Projects that would be EA Category A should not be selected.




2. Project Preparation

The Borrower undertakes a brief Safeguards Assessment early during project preparation to identify the typical impacts that may be encountered in the CDD subprojects. Based on this assessment, the Operational Manual (OM) should describe the process to identify and address safeguard issues in sub-projects. This should include:

• Systems and procedures to identify and address safeguard impacts of sub-projects;
• Capacity building measures required;
• A monitoring system

The OM may also include a negative list of activities that the CDD will not fund, as well as a list of goods and services the CDD will not procure.




The PAD should reflect the contents of the OM and include coverage of the safeguard policy issues in the terms of reference for the supervision and mid-term reviews.




An estimate of the costs of implementing safeguard measures (mainly in terms of capacity building, M&E, screening mechanisms and preparation of EAs for sub-projects) should be included in the project budget.




3. Project Supervision

During project supervision, staff should ensure review the implementation of the safeguard measures and review the findings of the project’s monitoring system. Field visits should be made to a sample of the sub-projects with actual or potential safeguard issues. Special attention should be paid to implementation of safeguard capacity building activities targeted at local communities and officials.




The mid-term review should include at least one ESSD specialist. Ideally the review should include two such specialists, one to review social issues and the others to cover biophysical environmental issues.




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Community Driven Development (CDD) programs empower local communities and local governments with control over decision-making and investment resources. However, despite community involvement, cumulative negative environmental and social impact of CDD subprojects can be substantial, especially with regard to changes in land use for livestock, irrigation and reforestation projects. Also there is some danger that such impacts, particularly in resettlement cases, may not be recognized and suitably mitigated. In a recent OED evaluation of CDD, 70% of projects in the study sample of 84 were judged “moderately satisfactory” and above for their compliance at entry and implementation. This is not adequate given Bank’s emphasis on “zero tolerance.” The study also found that 9% of Category B and 34% of Category C projects from the sample were misclassified.

A significant challenge in ensuring environmental and social sustainability in CDD is the fact that the location and design of the eventual subprojects are not known at project appraisal, though the types of potential subprojects may be fairly well-defined. As a result, traditional safeguards instruments (e.g. an environmental assessment or resettlement action plan) cannot be prepared before appraisal, and safeguards measures to support environmental and social sustainability can only be established during project implementation. Thus, there is a need for greater attention to safeguards implementation, and a need for more supervision mechanisms and resources.