Evaluation Team

This evaluation is undertaken by the Policy Division of the Operations Evaluation Department of the African Development Bank  under the leadership of Ms. Odile Keller (Division Manager). It’s task managers are Mr. Detlev Puetz (Chief Evaluator) and Mr. Girma Kumbi (Senior Evaluator). The preparation and desk review (April 2010 – May 2011) were managed by Mr. James Edwin, former Principal Evaluator in OPEV. The evaluation had substantial inputs from a Bank internal reference group composed of Mr. Mbarack Diop and Justin Ecaat , Mr Ali Aymen Osman , Mr. Noel Kulemeka and Mr. John Kanyarubona.

For further information, please contact Mr. Detlev Puetzd.puetz@afdb.org or Mr. Girma Kumbi g.kumbi@afdb.orgof OPEV, AfDB.

Objective

The principal objectives of this evaluation are to evaluate environmental mainstreaming, safeguards, and results in the road subsector; consider how far regional member countries have taken up environmental concerns and mainstreaming; and review the sustainability of environmental outcomes

Main Findings

• The evaluation shows that environmental results in roads are best where regional member country systems work well. Country legislative frameworks and institutional arrangements for environmental mainstreaming, resourcing and enforcement are important. Good country systems ensure that environmental management plans and safeguards are clearly formulated and validated at project launch; country roads authorities have motivated staff, budgets and processes for environmental planning and monitoring; and construction contracts and bidding documents contain appropriate environmental provisions and clauses that are well monitored and supervised by the implementing agencies.

• Short-term environmental outcomes of Bank-supported roads were by and large satisfactory. Well-constructed and upgraded roads usually have overall positive environmental effects, particularly in the short-run, for instance in terms of reduced carbon-dioxide emissions. Many environmental mitigation measures are in place such as environmental protection at work-sites, construction of appropriate water and erosion control structures and routine restoration of borrow pits and quarries at completion. Such positive environmental outputs are often related to good practices and engineering quality standards by construction companies, proactive on-site environmentalists, and supervision by road agencies. Sometimes good environmental practices are less respected resulting in environmental nuisances for local populations, natural resources, and wildlife.

• The quality of long-term environmental road management and maintenance is often deficient, in contrast to short-term effects. Environmental management during road maintenance and upkeep of environmental investments receive very little attention and resources from the Bank and from regional member countries, undermining initial efforts

• Induced secondary environmental damages from road construction - such as deforestation, unplanned land settlements and loss of bio-diversity - are rarely mitigated through project and sector interventions. Negative secondary effects occur for some roads that pass through natural reserves or otherwise sensitive and protected areas. Bank guidelines are vague about mitigating such secondary effects.

• The technical quality of the Bank’s Environmental Impact Assessments and Management Plans for roads, as submitted with Project Appraisal Reports, has been satisfactory. But some projects could benefit from more effective alignment of the Bank’s safeguards and Environmental and Social Management Plans with those of regional member countries and other donors. Bank safeguards staff have few incentives to be flexible in formulating environmental requirements and safeguards, to follow country leads, to join and align with other donors, and to take pragmatic and costoriented approaches without compromising the Bank’s essential environmental safeguards and goals. Few efforts are made to reconcile various environmental assessments, corresponding management plans and budgets at project launch, which is particularly important for parallel and co-financed projects.

• Environmental monitoring and supervision by the Bank are weak. The Bank’s monitoring and evaluation framework, supervision records, and Project Completion Reports do not provide a comprehensive picture of environmental results and shortcomings for individual road projects or the subsector as a whole. The Bank’s supervision format and System of Application and Products (SAP) platform lack environmental and social performance indicators in project summary ratings. Weak supervision information also affects the quality of environmental reporting in PCRs. Poor staff incentives and capacity contribute to weak supervision and followup on environmental safeguards during implementation. Environmental specialists are rarely part of supervision teams. Thematic overload among sector taskmanagers and managers and diversion from other performance indicators drive priorities: approval and disbursement targets. Environmental categorization is not useful to draw attention to environmentally sensitive projects for follow-up in implementation because the criteria focus on the size of projects rather than environmental risks.

• Strategic Environmental Assessments for countries and sectors are considered an important entry point for environmental mainstreaming, but are underused by the Bank and countries. Strategic Environmental Assessments (SEA) are a systematic process to address broader sector- and country-wide environmental goals, including the mitigation of longer-term environmental effects and trade-offs with other development goals.

• As evidenced in the three country case studies and confirmed by the evaluation literature review and interviews regional member countries have made substantial progress in environmental policies since the 1990s, but enforcement structures and procedures often remain weak. For instance, Cameroon, Morocco, and Uganda have all developed comprehensive environmental policies, legal frameworks, institutions, and business processes and are raising environmental awareness. But political will, agency commitment, and enforcement are still lacking. Environmental management tends to be overstretched and under-resourced.

• Donors have contributed substantial resources to enhance the image and mainstreaming of environmental issues in regional member countries. Continued support, engagement and advocacy for the environment remain important. Donor supervisions and implementation assistance are reportedly the best ways to attract the attention of government agencies, roads authorities, and construction contractors to environmental mitigation and to strengthen the weight of environmentalists in public agencies.

• Country systems are being used for environmental safeguards, but legal obligations require continued Bank engagement. Country systems are widely used for Environmental and Social Impact Assessments and design of management plans, for negotiating environmental clauses with construction contractors and for monitoring environmental results through road authorities. But the Bank’s legal safeguard and due diligence requirements and the independent complaint mechanism demand continued attention and engagement for establishing and monitoring safeguards, throughout the project cycle. Still, critical safeguards and due diligence standards are not always clearly established which can lead to arbitrary decisions. An exception is the clear and legally binding formulation of compensation for resettlement in road (and other) projects. Interestingly, the Bank does not define or use the term “safeguards” in its 2001 and 2003 guidelines or in the 2004 environmental policy.

• Many regional member countries find it difficult to reconcile different donor demands for environmental safeguards, management and procedures. The quality and integrity of country produced Environmental and Social Impact Assessments, Environmental and Social Management Plans, and approval processes are often driven and obfuscated by multiple donor requirements that are not always well communicated and aligned in practice.

• The Bank’s approach to environmental mainstreaming and support for country systems has not worked well. The Bank has failed to turn high environmental policy goals and ambitions into actions. The environment has not been mainstreamed well in the Bank’s country and sector strategies, economic and sector work and country capacity building as prioritized in the 2004 environmental policy. Few efforts and resources are expended to these ends.

• Responsibility for environmental mainstreaming is not clearly assigned at the Bank. First everybody’s business and then nobody’s business? The concept of mainstreaming requires that something becomes “everybody’s business” in other words, well integrated, institutionalized, and present in everyday thinking, priorities, and business processes. But evidence from this and other evaluations has shown that mainstreaming works best when there is some institutional responsibility and focal point for championing, technical guidance, and monitoring otherwise it easily becomes nobody’s business. Several reorganizations between 2006 and 2010 led to the loss of a clearly mandated organizational unit, or champion, for environmental issues and mainstreaming at the Bank. This left a void for broader environmental coordination, advocacy and monitoring, and in particular country system support.

Main Recommendations

Recommendation(s) to the Bank:

• Collaborate more interactively with regional member countries on the design of environmental project impact assessments and safeguards; to develop clear, coherent, and actionable environmental management plans for Bank-supported road projects, particularly when co-financed with other donors 

• Follow country environmental processes and requirements to the extent possible. Provide incentives and guidelines for Bank staff to follow country systems and to align with all partners, without compromising essential Bank safeguards. Help further enhance country capacity for high-quality safeguards and environmental management planning. 

• Work towards consolidated, joint, and fully agreed environmental management plans at project launch under country leadership. Partner alignment is particularly important in parallel and co-financed projects. 

• Carefully formulate and limit Bank environmental safeguards when revising the Bank’s safeguard system, in all relevant Bank policy and project documents; to include only safeguards that carry legal or due diligence implications for the Bank. 

• Improve Bank communication on environmental safeguards with regional member countries to enhance transparency and predictability through up-to-date on-line systems and relevant expertise in country and regional offices. 

• Support and strengthen regional member country execution and enforcement of environmental safeguards and management plans for roads during project implementation, particularly in environmentally sensitive and high-risk projects. 

• Help countries systematically include and monitor environmental provisions and budgets in project construction contracts and related procurement documents. 

• Strengthen environmental attention within country systems by enhancing Bank reporting requirements on environmental issues in quarterly progress reports and supervision missions. 

• Prioritize environmental supervision based on environmental risks by better categorizing projects as environmentally high-risk (possibly by distinguishing between environmental and social risks), and by clearly indicating and flagging projects and areas of particular environmental sensitivities for follow-up and supervision in logical frameworks and Environmental and Social Management Plans. 

• Consider new and expanded Bank environmental support and supervision modalities for environmentally sensitive projects, such as specialized environmental implementation assistance by sector operations departments and targeted environmental compliance monitoring and country audits by the Safeguards Division (ORQR.3) 

• Use risk-targeted supervision, implementation support, and environmental compliance monitoring to raise awareness and enhance know-how and capabilities of country implementing institutions for environmental supervision and enforcement. 

• Strengthen regional member countries’ long-term sector and national environmental capacities. Bank support should be selective and mindful of available resources, capabilities, and instruments. 

• Expand environmental diagnostic and strategic sector analyses in accordance with the Bank’s environmental policy and emerging vision on green growth, in close collaboration with regional member countries. This may include expanded economic and sector work, Strategic Environmental Assessments, or similar tools during the preparation and implementation of country, regional and sector strategy plans. 

• Enhance environmental through stronger engagement with countries in infrastructure maintenance programmes. 

• Mitigate more through strategic sector work to manage long-term environmental effects and related institution building. 

• Support environmental A broad range of Bank instruments may be deployed for this purpose, such as trust funds, technical assistance, governance capacity projects, and training programmes, possibly with other donors and country authorities through basket-funding. This could include support for civil society organizations. 

• Assume a stronger pro-active, catalytic, and values-oriented responsibility for environmental mainstreaming in Africa, thus reinforcing the Bank’s long-term strategy of sustainability and green growth, taking into account financial and technical resources for the environment.

• Institutionalize environmental mainstreaming This includes paying more attention to mainstreamed environmental policies and guidelines, clarifying institutional responsibilities for environmental mainstreaming at the Bank, promoting of environmental values and mindsets, offering regular staff training; building environmental capacity, and taking pro-active environmental actions beyond “do no harm” safeguards. 

• Pioneer and show-case ,for instance in countries, regions or sectors that are receptive to the idea—as already commenced in Central Africa, Morocco and Rwanda, or in sectors of particular importance to the Bank. 

• Increasingly partner with to identify environmental solutions and strengthen environmental values, policy implementation, enforcement and capacities. 

• Introduce appropriate indicators ; for instance through regular annual environmental reports and specific performance indicators at corporate, department and country levels (key performance indicators or others).