The World Bank · PIM Project Implementation Manual PPP Public-Private Partnership ... (ALRMP II),...

Document of

The World Bank

Report No: 71427-KE

RESTRUCTURING PAPER

ON A

PROPOSED PROJECT RESTRUCTURING

OF THE

KENYA COASTAL DEVELOPMENT PROJECT

APPROVED ON JULY 27, 2010

TO THE

REPUBLIC OF KENYA

August 9, 2012

Environment and Natural Resources

Kenya Country Department

Africa Region

This document has as restricted distribution and may be used by recipients only in the

performance of their official duties. Its contents my not otherwise be disclosed without World

Bank authorization.

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2

ABBREVIATIONS AND ACRONYMS

ALRMP II Arid Lands Resource Management Project II

BDS Business Development Services

BP Bank Policy

CAAC Coastal Area Advisory Committee

CDA Coast Development Authority

CDD Community Driven Development

CSO Civil Society Organization

CRC Citizen Report Card

CVF Coastal Village Fund

EA Environmental Audit

EEZ Exclusive Economic Zone

EOP End of Project

EIA Environmental Impact Assessment

ESMF Environmental and Social Management Framework

FID Fisheries Department

FM Financial Management

FY Fiscal Year

GEO Global Environmental Objective

GEF Global Environmental

GoK Government of Kenya

GIS Geographical Information System

HMP Hazina ya Maendeleo ya Pwani

ICR Implementation Completion Rport

ICZM Integrated Coastal Zone Management

ISR Implementation Status an Results

IDA International Development Association

ISDS Integrated Safeguards Datasheet

IPPF Indigenous Peoples Planning Framework

KACC Kenya Anti Corruption Council

3

KCDP Kenya Coastal Development Project

KMFRI Kenya Marine Fisheries Research Institute

KEFRI Kenya Forestry Research Institute

KWS Kenya Wildlife Service

MoF Ministry of Finance

MoFD Ministry of Fisheries Development

MCS Monitoring, Control and Surveillance

M&E Monitoring and Evaluation

MLDP Ministry of Lands (Department of Physical Planning

MPA Marine Protected Area

MPs Management Plans

MSMEs Micro Small and Medium Enterprises

MoL Ministry of Lands

MS Moderately Satisfactory

NEMA National Environment Management Authority

OP Operation Policy

OPCS Operations Policy and Country Services

PAD Project Appraisal Document

PC Project Coordinator

PF Process Framework

PPOA Public Procurement Authority

PCU Project Coordination Unit

PIM Project Implementation Manual

PPP Public-Private Partnership

PPR Procurement Post Review

PDO Project Development Objective

RP Restructuring Paper

SDR Special Drawing Rate

SMSEs Small and Medium Sized Enterprises

SoE Statement of Expenditure

TTL Task Team Leader

VMS Vessel Monitoring System

4

Regional Vice President: Makhtar Diop

Country Director: Johannes Zutt

Sector Manager / Director: Jonathan Kamkwalala

Task Team Leader: Ann Jeannette Glauber

5

KENYA


P094692

CONTENTS

A. SUMMARY ........................................................................................................................... 8

B. PROJECT STATUS .............................................................................................................. 8

C. PROPOSED CHANGES ...................................................................................................... 9

D. APPRAISAL SUMMARY ................................................................................................. 22

ANNEX 1: RESULTS FRAMEWORK AND MONITORING .............................................. 24

ANNEX 2: UPDATED GOVERNANCE ACTION PLAN ..................................................... 31

6

Data sheet

RestructuringStatus:

Restructuring Type: Level I (Board Approval)

1. Basic Information

Project ID & Name: P094692 (IDA Cr. 4801-KE/TF097578) – Coastal

Development Project

Country: Republic of Kenya

Task Team Leader: Ann Jeanette Glauber

Sector Manager / Director: Jonathan Kamkwalala / Jamal Saghir

Country Director: Johannes Zutt

Original Board Approval Date: 07/27/2010

Original Closing Date: 10/29/2016

Current Closing Date: 10/29/2016

Proposed Closing Date: 10/29/2016

EA Category: B-Partial Assessment

Revised EA Category: B-Partial Assessment

EA Completion Date: 06/06/2008

EA Completion Date, Revised:

2. Revised Financing Plan (US$

million)

Source Original Revised

Borrower 2.00 2.00

GFCO 5.00 5.00

IDA 35.00 35.00

Total 42.00 42.00

3. Borrower

Organization Department Location

Ministry of Finance, The

Treasury, Nairobi, Kenya

Nairobi, Kenya

4. Implementing Agency

Organization Department Location

Kenya Marine Fisheries

Research Institute (KMFRI)

Mombasa, Kenya

Fisheries Department (FiD) Mombasa, Kenya

Kenya Forestry Research

Institute (KEFRI)

Mombasa, Kenya

Kenya Wildlife Service (KWS) Mombasa, Kenya

Coast Development Authority

(CDA)

Mombasa, Kenya

National Environment

Management Authority

Mombasa, Kenya

Ministry of Lands (Department

of Physical Planning)

Nairobi, Kenya

5. Disbursement Estimates (US$m)

Actual amount disbursed as of July 25, 2012

Total to date: 3.02

7

Fiscal Year Annual Cumulative

2011 0 0

2012 2 2

2013 6 8

2014 10 18

2015 9 27

2016 5 32

2017 3 35

Total 35 35

6. Policy Exceptions and Safeguard Policies

Does the restructured project require any exceptions to Bank

policies?

NO

Does the restructured project trigger any new safeguard

policies?

NO

7a. Project Development Objectives and Outcomes

Original/Current Project Development Objectives/Outcomes:

The original Project Development Objective (PDO) is: “To promote environmentally

sustainable management of Kenya’s coastal and marine resources by strengthening the

capacity of existing relevant government agencies and by enhancing the capacity of rural

micro, small and medium sized enterprises in selected coastal communities”.

7b. Revised Project Development Objectives/Outcomes:

The proposed revised PDO is: “To improve management effectiveness and enhance

revenue generation of Kenya’s coastal and marine resources.”

8

KENYA


RESTRUCTURING PAPER

A. SUMMARY

1. This Restructuring Paper (RP) responds to the request of the Government of

Kenya and proposes to introduce the following changes to the Kenya Coastal

Development Project (KCDP; P094692, Credit 4801-KE/TF097578) and accompanying

amendments to the Project’s legal documents: (i) simplification of the Project

Development Objective (PDO); (ii) revision of the results framework, including changes

to outcome indicators so as to better monitor project impact, and revision of targets to

reflect reallocated resources (see below); (iii) revision of institutional arrangements to

allow for implementation of the Development Fund of the Coast, or Hazina ya

Maendeleo ya Pwani (HMP), formerly Coastal Village Fund (CVF) (Part 4(b) of the

Project), by the Kenya Marine Fisheries Research Institute (KMFRI), rather than the Arid

Lands Resource Management Project II (ALRMP II), which is now closed; (iv) revision

of activities included under Schedule 1 of the Financing and Grant Agreements to reflect

agreed simplification and streamlining; (v) reallocation of about 26% of credit proceeds

to facilitate project implementation; (vi) definition of project activities to be financed

under the GEF grant at 100% and to allow for project financing of 100% of expenditures

under Category 1 of the Financing Agreement; and (vii) revision of eligible procurement

methods to include Force Account and Community Participation. The reallocation of

project funds among existing categories will address unbudgeted costs associated with

safeguards requirements and management costs associated with the HMP (now

implemented directly by KMFRI). The reallocation also reflects a reduced scope of

Public-Private Partnership and HMP activities in line with the revised Results

Framework. Overall, the proposed restructuring provides an opportunity to: (i) clarify and

simplify the project design so as to ensure achievement of objectives within the duration

of the project, which is expected to close on October 29, 2016, and (ii) improve the

potential for demonstrating project success.

B. PROJECT STATUS

2. The project was approved on July 27, 2010 and became effective on June 30,

2011, almost a year after Board approval, due to delays in achieving the project’s six

conditions of effectiveness. The project, which has now been under implementation for

one year, has experienced initial delays in procurement and financial management, which

have resulted in an overall slow implementation progress. These shortcomings, mainly

due to weak capacity, have been addressed and implementation is picking up the pace,

with key studies, works and technical consultancies being procured. As of July 25, 2012,

the project has disbursed US$3.02 million. Overall, project implementation progress is

rated Moderately Satisfactory (MS) in the last ISR dated May 7, 2012, to reflect the slow

9

start in implementation. This project restructuring includes simplification and

streamlining of activities which will help expedite implementation.

C. PROPOSED CHANGES

Project’s Development Objective

3. The original Project Development Objective (PDO) is: “To promote

environmentally sustainable management of Kenya’s coastal and marine resources by

strengthening the capacity of existing relevant government agencies and by enhancing the

capacity of rural micro, small and medium sized enterprises in selected coastal

communities”.

4. The proposed revised PDO is: “To improve management effectiveness and

enhance revenue generation of Kenya’s coastal and marine resources.” This change

simplifies the PDO by eliminating the description of the component activities from the

PDO statement, aligning it with the activities supported, and facilitating measurement of

results within the project lifetime.

Results/indicators

5. In addition to changing the PDO, the proposed restructuring introduces changes to

the Results Framework, which has been revised and simplified to include more relevant,

measurable and clearly defined results indicators that are better suited to assess and

monitor the implementation progress toward achieving the PDO. In addition, the targets

related to activities of, or supported by, the HMP have also been revised to better reflect

the pilot nature of these activities. (See Annex 1 for details).

Components

6. The restructuring does not propose revision of any components or

subcomponents; rather it includes changes to the activities to be supported under each

component (Schedule 1 of the Financing and Grant Agreements, and Parts 1, 2, 3 and 4

of the Project). The proposed modifications are intended to reflect the agreed

simplification and streamlining, and distinguish grant- and credit-financed activities,

while retaining the general project design and component structure. Table 1 shows the

activities originally supported by the project and those that would be supported under the

restructured project:

Table 1: Original Versus Proposed Activities

Original Activities Proposed Activities

Component 1: Sustainable Management of Fisheries Resources

Promote sustainable management of

fisheries resources and enhancing the

benefits and revenue generation derived

from coastal fisheries through:

(a) developing and implementing a cost

effective monitoring control and

surveillance strategy in Kenya’s

Promote long term management

effectiveness of fisheries resources and

enhance the benefits and revenue

generation derived from coastal fisheries

through:

(a) Promoting and developing fisheries

governance including support for and

10

Exclusive Economic Zone;

(b) developing the Recipient’s capacity to

negotiate fair and transparent license

agreements with distant water fishing

nations and vessels through training

and technical advisory services;

(c) developing and implementing a vessel

monitoring system for licensed fishing

vessels;

(d) carrying out routine monitoring of

vessels, licenses, fish landings and

developing a fisheries management

information system;

(e) carrying out research to support stock

assessments for ten (10) agreed priority

fish species;

(f) carrying out demand-driven research

for aquaculture;

(g) rehabilitating and constructing

hatcheries;

(h) promoting aquaculture production

through technical assistance, training

and provision of necessary equipment;

(i) undertaking quality assurance and

building capacity and awareness of

fishing communities through training

and dissemination of information;

(j) developing the legal and policy

framework for sustainable aquaculture

development;

(k) undertaking spatial mapping of

fisheries and related oceanographic and

environmental parameters;

(l) promoting ecosystem-based

management of fish resources;

(m) developing fishery specific co-

management plans;

(n) carrying out research on by-catch

management and control and on tools

for reducing mortality of turtles,

seabirds and mammals and other

protected or endangered species.

the development of increased capacity

to undertake monitoring, control and

surveillance and optimizing the use of

deep-sea resources within Kenya’s


(b) Promoting and developing the

Recipients fisheries management and

research capacity including assessment

of fish stocks, ecosystem approach to

fisheries, co-management of fisheries

through beach management units and

fishery management plans;

(c) Promoting and developing value

addition of fish catches in the coastal

fisheries and the affected communities;

(d) Promoting and developing aquaculture

through research and technical support;

(e) Carrying out minor infrastructure

improvements.

Component 2: Sound Management of Natural Resources

Promote sound management of natural

resources and eco-tourism related

industries through:

(a) setting up of a coastal biodiversity

information management system;

Promote improved management of natural


industries through:

(a) Improving the management and

regeneration of natural resources and

11

(b) carrying out specialized surveys on

flora and fauna in the Arabuko-Sokoke,

Boni-Dodori and Kiunga forests areas

and any other areas agreed with the

Association;

(c) carrying out of biodiversity

assessments in the Mombasa Marine

National Park and Kisite-Mpunguti,

Shimba Hills, Shimoni, Marereni and

Assakone community conservation

areas and any other areas agreed with

the Association;

(d) developing and implementing

guidelines for management of

environmentally and socially critical

habitats in the Tana Delta;

(e) developing and implementing

conservation strategies for endangered

species/ecosystems such as sea turtles,

coral reefs and dugong and other

critical habitats;

(f) promoting co-management of

conservancies by facilitating

partnership between the Recipient and

local communities and implementing

management plans for conservation and

sustainable use of coastal mangrove

and other forest ecosystems;

(g) creating and securing an elephant

corridor linking Arabuko-Sokoke forest

to Tsavo East National Park;

(h) building the capacity of institutional

staff and local community members in

conservation management through

training and sharing of best practices;

(i) carrying out of economic valuation for

Shimba Hills and the Malindi -

Watamu Marine Protected Area;

(j) supporting greater collaboration,

harmonization, monitoring and

surveillance of shared fisheries and

other resources at Kisite-Mpunguti and

Shimba Hills, and between South Coast

in Kenya and Tanga, Pangani, Zanzibar

and Pemba in Tanzania so that

individual national budgets in the two

countries are more effective;

(k) strengthening extension services for

biodiversity through co-management

and partnerships;

(b) Improving research capacity and

information systems for natural

resource management and biodiversity

conservation;

(c) Identifying biodiversity products and

markets that will assist in promoting

eco-tourism and related industries;

(d) Conducting institutional and local

communities’ awareness and capacity

building for sustainable natural resource

management, and providing improved

extension services; and

(e) Carrying out minor infrastructure

improvements.

12

village based investment activities

through training, information sharing

and technical advice;

(l) developing and disseminating

information on ten (10) appropriate

technologies for village based

investment activities;

(m) compiling information on existing

tourism infrastructure, assets and

activities along the Kenya coast;

(n) developing new tourism circuits in

Kiunga, Lamu, Mombasa, Malindi,

Watamu, Arabuko-Sokoke and South

Coast, by facilitating partnerships

amongst the local industry players and

local communities; and carrying out

activities to develop and promote

markets for the new circuits;

(o) undertaking a study on tourism income

distribution to identify opportunities for

local communities to exploit and

building their capacity to exploit these

opportunities in sustainable manner;

and

(p) carrying out specific coastal and marine

research for promoting sustainable

management of natural resources.

Component 3: Support for Alternative Livelihoods

Promote sustainable livelihoods within a

sound governance framework through:

(a) preparing land capability plans and land

use plans to assess land potential and

defining broad land use plans at the

provincial, district and ward levels of

the Coast Province;

(b) Strengthening NEMA’s capacity to

implement the Integrated Coastal Zone

Management (ICZM) framework

through: (i) technical assistance for

reviewing the relevant policy and legal

framework, (ii) rehabilitating and

refurbishing offices, (iv) provision of

training and equipment, (v) financing

of community outreach activities and

(v) developing and implementing an

ICZM awareness strategy;

(c) developing and implementing

incentives for environmental

Promote sustainable livelihoods within an

improved governance framework through:

(a) Building the capacity of the

implementing agencies’ decentralized

offices in the Coast Region’s six

counties (MoL, NEMA and CDA);

(b) Preparing a land capability plan for the

Coast Region and land use plans for

selected counties and wards;

(c) Enhancing NEMA's capacity to

strengthen and implement the

Integrated Coastal Zone Management

(ICZM) framework;

(d) Promoting the development of Micro,

Small and Medium Enterprises

(MSMEs) through value chain studies,

and provision of business development

and financial services;

(e) Piloting of Public-Private Partnerships

(PPP) to promote sustainable

13

governance and conservation;

(d) building the capacity of the provincial

and district land offices in the Coast

Province through rehabilitation and

refurbishment of offices and provision

of training and relevant equipment;

(e) sensitizing local communities on

sustainable land use;

(f) harmonizing the legislative and

regulatory framework for addressing

environmental degradation along the

coast and strengthening associated

institutions through sensitization,

training and provision of relevant

equipment;

(g) developing CDA’s capacity to promote

partnerships between local

communities and Micro, Small and

Medium Enterprises (MSMEs) through

training, technical advisory services,

rehabilitation and refurbishment of

offices and provision of relevant

equipment;

(h) providing Business Development

Services (BDS) and establishing BDS

resource centers for MSMEs;

(i) promoting the availability and

accessibility of ready financing for

MSMEs through: (i) value addition

micro studies in the mango, cashew,

fishing and jatropha subsectors and

other natural resources subsectors; (ii)

provision of training and support in

basic financial management, (iii)

developing business plans and business

licensing; and (iv) provision of relevant

equipment and supplies;

(j) promoting value addition of village

based economic activities in five (5)

viable subsectors to maximize

economic returns to local communities;

and

(k) piloting five (5) public private

partnerships between local investors

and MSMEs.

management of coastal and marine

resources; and

(f) Carrying out minor infrastructure

improvements.

Component 4: Capacity Building, Monitoring and Evaluation System, Project

Management, Communication and Coastal Development Fund

Promote investment in village based Promote investment in village based

14

economic activities and enhancing the

capacity for Project implementation, and

stakeholder dialogue through:

(a) establishing and implementing a

Coastal Village Fund to provide grants

to Beneficiaries to implement pre-

selected activities that promote the

sustainable management of fishery

resources and the sound management of

natural resources;

(b) establishing and building capacity of

the Project staff through training,

technical advisory services and

provision of relevant goods;

(c) developing an information and

communication strategy for the Project;

(d) developing and implementing an

effective monitoring and evaluation

system; and

(e) financing of Operating Costs.

economic activities, and enhance the

capacity for Project implementation and

stakeholder dialogue through:

(a) Establishing and building capacity of

the Project staff through training,

technical advisory services and

provision of relevant goods;

(b) Establishing and implementing a a

Development Fund of the Coast

(Hazina ya Maendeleo ya Pwani) to

provide micro-credit banking fees and

grants to Beneficiaries to implement

eligible demand driven sub-projects

that promote micro and small

enterprises (MSME), natural resource

management and community services;

(c) Developing an information and

communication strategy for the Project;

(d) Developing and implementing an

effective monitoring and evaluation

system;

(e) Establishing efficient coordination

mechanisms and management

procedures through financing

consultancies, minor infrastructure

improvements and financing of

Operating Costs for the entire project;

and

(f) Carrying out minor infrastructure

improvements.

Of these activities, the GEF grant will support the following activities:

Original Activities Proposed Activities

Component 1: Sustainable Management of Fisheries Resources

Promote sustainable management of

fisheries resources and enhancing the

benefits and revenue generation derived

from coastal fisheries through:

(a) developing and implementing a cost

effective monitoring control and

surveillance strategy in Kenya's


(b) developing the Recipient's capacity to

negotiate fair and transparent license

agreements with distant water fishing

nations and vessels through training

Promote long term management

effectiveness of fisheries resources and

enhance the benefits and revenue

generation derived from coastal fisheries

through:

(b) Promoting and developing the

Recipients fisheries management and

research capacity including assessment

of fish stocks, ecosystem approach to

fisheries, co-management of fisheries

through beach management units and

fishery management plans.

15

and technical advisory services;

(c) developing and implementing a vessel

monitoring system for licensed fishing

vessels;

(d) carrying out routine monitoring of

vessels, licenses, fish landings and

developing a fisheries management

information system;

(e) carrying out research to support stock

assessments for ten (10) agreed priority

fish species;

(f) carrying out demand-driven research

for aquaculture;

(g) rehabilitating and constructing

hatcheries;

(h) promoting aquaculture through

technical assistance, training and

provision of necessary equipment;

(i) undertaking quality assurance and

building capacity and awareness of

fishing communities through training

and dissemination of information;

(j) developing the legal and policy

framework for sustainable aquaculture

development;

(k) undertaking spatial mapping of

fisheries and related oceanographic and

environmental parameters;

(l) promoting ecosystem-based

management of fish resources;

(m) developing fishery specific co-

management plans; and

(n) carrying out research on by-catch

management and control and on tools

for reducing mortality of turtles,

seabirds and mammals and other

protected or endangered species.

Component 2: Sound Management of Natural Resources

Promote sound management of natural


industries through:

(a) setting up of a coastal biodiversity

information management system;

(b) carrying out specialized surveys on

flora and fauna in the Arabuko-Sokoke,

Boni-Dodori and Kiunga forests areas

and any other areas agreed with the

Association;

Promote improved management of natural


industries through:

(b) Improving research capacity and

information systems for natural

resource management and biodiversity

conservation.

16

(c) carrying out of biodiversity

assessments in the Mombasa Marine

National Park, Kisite-Mpunguti,

Shimba Hills, Shimoni, Marereni and

Assakone community conservation

areas and any other areas agreed with

the Association;

(d) developing and implementing

guidelines for management of

environmentally and socially critical

habitats in the Tana Delta;

(e) developing and implementing

conservation strategies for endangered

species/ecosystems such as sea turtles,

coral reefs and dugong and other

critical habitats;

(f) promoting co-management of

conservancies by facilitating

partnership between the Recipient and

local communities and implementing

management plans for conservation and

sustainable use of coastal mangrove

and other forest ecosystems;

(g) creating and securing an elephant

corridor linking Arabuko-Sokoke forest

to the Tsavo East National Park;

(h) building the capacity of institutional

staff and local community members in

conservation management through

training and sharing of best practices;

(i) carrying out of economic valuation for

Shimba Hills and the Malindi -

Watamu Marine Protected Area;

(j) supporting greater collaboration,

harmonization, monitoring and

surveillance of shared fisheries and

other resources at Kisite-Mpunguti and

Shimba Hills, and between South Coast

in Kenya and Tanga, Pangani, Zanzibar

and Pemba in Tanzania so that

individual national budgets in the two

countries are more effective;

(k) strengthening extension services for

village based investment activities

through training, information sharing

and technical advice;

(l) developing and disseminating

information on ten (10) appropriate

17

technologies for village based

investment activities;

(m) compiling information on existing

tourism infrastructure, assets and

activities along the Kenya coast;

(n) developing new tourism circuits in

Kiunga, Lamu, Mombasa, Malindi,

Watamu, Arabuko-Sokoke and South

Coast, by facilitating partnerships

amongst the local industry players and

local communities; and carrying out

activities to develop and promote

markets for the new circuits;

(o) undertaking a study on tourism income

distribution to identify opportunities for

local communities to exploit and

building their capacity to exploit these

opportunities in a sustainable manner;

and

(p) carrying out specific coastal and marine

research for promoting sustainable

management of natural resources.

7. It is further proposed to rename the grant fund mechanism supported under

Component 4 (Coastal Village Fund) “Development Fund of the Coast” (Hazina ya

Maendeleo ya Pwani or HMP). The change of name is considered appropriate in order to:

(i) use a name with a better reference to the target group; and (ii) distinguish the fund

from the Constituency Development Fund, presently being implemented by the Kenyan

Government.

Safeguards

8. There are no changes in the safeguards policies triggered by the Project. The PAD

and Integrated Safeguards Datasheet (ISDS) classified the project as “Category B” since

the investments, focused on participatory policy and planning framework at the local

government level, will have moderate environmental impacts. Support to rural economic

development, through assistance to MSMEs, and to subprojects, through the HMP fund,

may have site specific negative environmental impacts. In view of this risk, the project is

supporting the development of spatial plans and land capability maps and of an Integrated

Coastal Zone Management framework that will guide these activities. Larger

investments, such as coastal infrastructure, which may be supported by the Project, will

be carried out after a full EA. Additionally, the project will be financing the development

and implementation of Environmental and Social Management Plans, the preparation of

which is called for in the project’s Environmental and Social Management Framework,

dated March 17, 2010.

9. OP 4.12 (Involuntary Resettlement) applies to the Project since some of the

KCDP activities may restrict or control access to marine and fisheries resources if the co-

management and community rules for access and use of resources are not carefully

18

monitored. The Process Framework (PF) prepared under the Project, which was made

public on May 7, 2010, defines the guidelines for co-management and use of resources,

including a public consultation and disclosure plan and a grievance mechanism.

10. OP/BP 4.10 (Indigenous Peoples) is triggered under the Project as the project area

includes Indigenous Peoples. The Government of Kenya has prepared an Indigenous

Peoples Planning Framework (IPPF), disclosed on February 5, 2010, that provides

information about these communities, their livelihoods and guidance in the event of

impacts by project activities. A comprehensive Social and Impact Assessment for the

entire project area (the six coastal counties of Kilifi, Kwale, Lamu, Mombasa, Taita-

Taveta and Tana River) is being contracted. This study will include a socio-economic

analysis for the entire project area, with screening, mapping and social assessment for

Indigenous Peoples (OP 4.10), and a comprehensive Process Framework for target

groups (OP 4.12). Following the completion of the social assessment, the Project will

support the preparation of site-specific Indigenous Peoples’ Plans will be developed for

all eligible communities affected by the Project (including the HMP).

Institutional Arrangements

11. According to the original project design, the Kenya Arid Lands Resources

Management Project II (ALRMP II) was responsible for implementing the Coastal

Village Fund (CVF) (now Development Fund of the Coast – HMP) activities (Part 4(a) of

the Project). Specifically, the Project was to use established ALRMP II structures at

district and community levels to identify and implement projects and disburse funds

under the CVF. The ALRMP was also to provide necessary technical training to

communities during project implementation.

12. Following the closing of the ALRMP II on December 31, 2010, an alternative

project mechanism has been developed which will provide (i) micro-credits and grants

for priority conservation-compatible activities identified through the various project

components, and (ii) training and capacity building for sub-project implementation.

13. Under the new HMP, responsibility for implementing and overseeing the overall

implementation of the HMP fund will fall under the Kenya Marine Fisheries Research

Institute (KMFRI) -- the agency responsible for implementation of Component 4 and

coordination of overall project implementation -- in collaboration with the co-

implementing agencies (the Kenya Forestry Research Institute, the Kenya Wildlife

Service, the Fisheries Department and the Coast Development Authority).

14. An assessment of KMFRI’s capacity for implementation of the new HMP fund

has been undertaken, highlighting needs in terms of additional staff and equipment.

Specifically, the Project is in the process of: (i) establishing County Liaison Offices in

each of the six coastal counties; (ii) hiring staff for each of these offices; and (iii)

developing and installing a management information system that will permit handling,

processing, monitoring and reporting of HMP activities. Further, each of the seven

partner institutions will appoint one focal point as representative to the HMP fund.

19

Financing

a. Project Costs

15. Currently, the financial intervention is split among the different components as

follows: Sustainable Management of Fisheries Resources Component -- 22% of base

costs; Sound Management of Natural Resources Component -- 22% of base costs;

Support for Alternative Livelihoods Component -- 26% of base costs; and Capacity

Building, M&E, Management and HMP (formerly CVF) Component -- 30% of base

costs, of which support for CDD sub-projects (HMP) represents the largest expenditure at

23%. Project Coordination and Management makes up 7% of base costs. The

restructuring does not affect component project costs.

b. Financing Plan

16. The Financing Plan has been revised to reflect delays in: (i) declaring the project

effective; and (ii) the initial phases of implementation as a result of financial management

and procurement weaknesses. As mentioned in section “B Project Status” above, these

shortcomings have been addressed and the revised Financing Plan includes larger

disbursements during the last 3 years of project implementation (FY 2015, 2016, and

2017). The Estimated Disbursements table in the Data Sheet has been revised

accordingly. As of July 25, 2012, the actual amount disbursed is as follows: IDA

US$2.50 million and GEF US$0.52 million.

IDA – Estimated Disbursements (US$ million)

Fiscal Year 2011 2012 2013 2014 2015 2016 2017 Total

Annual 0 2 6 10 9 5 3 35

Cumulative 0 2 8 18 27 32 35 35

GEF – Estimated Disbursements (US$ million)

Fiscal Year 2011 2012 2013 2014 2015 2016 2017 Total

Annual 0 0.5 1 1.5 1.5 0.5 0 5

Cumulative 0 0.5 1.5 3 4.5 5 0 5

17. Reallocation of Credit Proceeds. It is proposed to reallocate SDR 6.2M (26% of

credit proceeds) from Category 3 and Category 4 of the Financing Agreement, to

Category 2 and to a new Unallocated Category. The proposed reallocation is necessary to

facilitate project implementation towards achieving the project development objective.

Specifically, it will allow for addressing unbudgeted costs associated with safeguards

requirements – including technical consultancies for a comprehensive social assessment

including Vulnerable and Marginalized Groups, updating of the Process Framework,

development of co-management actions and social and environmental guidelines on sub-

projects to be implemented and costs associated with implementing the resulting action

20

plans – and management costs associated with the HMP fund (now implemented by

KMFRI). The reallocation also reflects a reduced scope of PPP and HMP activities

(under Categories 3 and 4) in line with the revised Results Framework.

18. In order to facilitate project implementation, it is proposed to increase the

percentage of expenditure to 100% (including taxes) for Category 1 of the Financing

Agreement. This is possible as GEF funds will now be used to fully finance specific

activities as outlined in the following table.

19. The changes are reflected in the revised Disbursement Table of Section IV to the

Financing and Grant Agreements and provided below:

Financing Agreement Category of Expenditure Allocation

(in SDR)

% of Financing Increase/

(Decrease)

Increase/

(Decrease)

% of

original

allocation

Current Revised Current Revised Current Revised

1. Goods,

Works,

Services,

Training and

Operating

Costs under

Part 1 and 2

of the Project

5.Goods,

Works,

Services,

Training and

Operating

Costs under

Parts 1 and 2

of the Project

(excluding

Parts 1(b) and

2(b))

7,800,000 7,800,000 IDA

70%

IDA

100%

0 0

2.Goods,

Works,

Services,

Training and

Operating

Costs under

Part 3 and 4

(excluding

Part 3(k) and

Part 4(a)) of

the Project

6.Goods,

Works,

Services,

Training and

Operating

Costs under

Part 3 and 4

(excluding

Part 3(e) and

Part 4(b)) of

the Project

5,500,000 9,400,000 IDA

100%

IDA

100%

3,900,000 71%

3.Investments

under Part

3(k) of the

Project

7.Investments

under Part

3(e) of the

Project

3,850,000 1,000,000 IDA

100%

IDA

100%

(2,850,000)

(74%)

4.Grants

under the

Coastal

Village Fund

under Part

4(a) of the

Project

8.Grants and

micro-credit

banking fees

under the

Development

Fund of the

Coast under

Part 4(b) of

6,650,000 3,300,000 IDA

100%

IDA

100%

(3,350,000)

(50%)

21

the Project

9. Unallocated N/A 2,300,000

TOTAL

AMOUNT

23,800,000 23,800,000

Grant Agreement Category of Expenditure Allocation

(in USD)

% of Financing

Current Revised Current Revised Current Revised

1. Goods,

Works,

Training,

Services

and

Operating

Costs

2. Goods,

Works,

Training,

Services

and

Operating

Costs

under

Parts 1 (b)

and 2 (b)

5,000,000 5,000,000 30% 100%

20. Procurement. It is proposed to revise the eligible procurement methods in both

the Financing and Grant Agreements to include the following methods: (a) Community

Participation, which would allow for financing the implementation of community-based

activities for improved fisheries and natural resources management under Components 1

and 2, and of community subprojects under Component 4; and (b) Force Account, which

would allow the carrying out of small and scattered works in remote locations, such as

the construction of fish driers, by the Ministry of Fisheries Development using its own

personnel and equipment.

21. Specifically, the rationale for, and appraisal of, such changes is the following:

(A) Community Participation in procurement was foreseen during project preparation and

appropriate mitigation measures taken into consideration. At the time of preparation,

the CDD component was expected to have been undertaken by the Arid Lands

Resources Management Project (ALRMP) which had the capacity, experience,

implementation tools and local presence that would have minimized procurement

risks considerably. While the provision for Community Participation was included in

the PAD, it was inadvertently omitted from the Financing Agreement. Given that the

ALRMP Project is no longer active, there is a need to revisit the implementation

arrangements for this component in order to identify and mitigate against any

associated risks and at the same time build in a framework for social accountability.

(B) Force Account was not contemplated during project preparation. However during the

post-effectiveness implementation support missions, it was realized that some of the

activities – particularly those related to fisheries micro-projects – involved a large

number of small, low-value contracts that were geographically spread out in remote

locations and which required a high level of craftsman skills. Such characteristics

would likely render the resulting contracts unattractive to local contractors, raise the

cost of administering such contracts if sourced competitively, and make it difficult to

22

guarantee quality due to their uniqueness and required level of specialization. Given

that the responsible ministry (Ministry of Fisheries Development) has the in-house

capacity to undertake such works, it is considered to be the most prudent approach for

constructing these kind of works. Due to the small size and relatively low value of the

contracts envisaged, there are minimal risks which would primarily be attributed to

the management of SOEs, and travel logistics and general contract administration due

to the wide geographical spread. The project has already taken on board specific risk

mitigation measures to address these issues, as set forth in Annex 2.

22. Disbursement Condition. The design and development of the funding

mechanism for the new HMP fund is well advanced and is expected to be finalized by the

end of August 2012, including inter alia the preparation of a detailed Project

Implementation Manual (PIM) containing clear eligibility and selection criteria,

procedures for the application, screening and vetting process. So as not to delay the

processing of the restructuring package, it is proposed to include a disbursement

condition in the Financing Agreement which would allow for financing of HMP activities

only once the revised PIM, reflecting all restructuring-related changes, has been finalized

and approved by the Bank.

D. APPRAISAL SUMMARY

23. The restructuring will not modify the overall design of the project, thus, the

original assumptions with respect to expected impact remain unchanged.

24. The key proposed changes include the following. First, there will be a reduction

in the number of HMP subprojects supported through grants from 840 to 700. However,

the inclusion of a window to support access to micro-credits for Small and Medium Sized

Enterprises (SMSEs) is expected to significantly increase the number of total people

directly benefitting from the HMP. Secondly, the amount allocated to PPP investments is

reduced by 30% compared to what was included in the Project Appraisal Document.

These funds will be used to better assess the feasibility of possible PPP investments,

which can be supported through other project funds as necessary. As such, the basic

assumptions regarding the project impacts at appraisal remain intact.

Risks

25. Overall, the proposed changes do not entail risks additional to those identified

during the original Project appraisal as summarized in the Project Appraisal Document

(PAD). With regard in particular to governance risks posed by the use of the Community

Driven Development (CDD) approach in the financing of community subprojects, the

new HMP mechanism supported under the Project reflects the adoption of enhanced

governance and accountability measures (see Annex 2 for an updated Governance Action

Plan). Responsibility for implementation and oversight of the HMP fund, together with

related procurement and financial management tasks, will be the direct responsibility of

the agency in charge of overall project implementation -- KMFRI, rather than outsourced

to a separate entity. Further, the new HMP mechanism includes clear measures to ensure

transparency and appropriate use of funds, including:

23

(a) the definition of clear eligibility criteria and vetting and approval processes;

(b) the participation of the beneficiaries and their representatives in the management of

the funds allocated to the community sub-projects;

(c) detailed information regarding disclosure and dissemination requirements, including

rules about disclosure of sub-project level reports in a manner understandable to all

interested parties, including subproject expenditures. Emphasis will be given to

information dissemination of project activities to community members and potential

providers of goods, works, and services so as to enhance transparency and

competition in procurement processes;

(d) the design of a comprehensive grievance and complaint mechanism;

(e) periodic audits of financed sub-projects; and

(f) the definition of clear sanctions and remedies.

26. In addition, the PIM will include measures that support social accountability, such

as: (i) a description of a system of fund use monitoring at the community level to enable

the user groups to keep proper books of accounts and account for funds received and

used; (ii) a description of the internal structure, roles and responsibilities within the

Community Group responsible for receipt and use of the funds, including a Governance

Training; and (iii) a Risk Mitigation Plan to address cases of reported misuse of funds.

27. Finally, measures will be adopted to mitigate risks related to the financing of

training, per diems and vehicle and fuel costs (see Annex 2 for details).

ANNEX 1:

Results Framework and Monitoring

KENYA: KENYA COASTAL DEVELOPMENT PROJECT

Project Development Objective (PDO):

To promote environmentally sustainable management of Kenya’s coastal and marine resources by strengthening the capacity of existing relevant government agencies and by enhancing the

capacity of rural micro, small and medium sized enterprises in selected coastal communities

Global Environmental Objective (GEO):

To strengthen conservation and sustainable use of marine and coastal biodiversity

Revised Project Development Objective:

To improve management effectiveness and enhance revenue generation of Kenya’s coastal and marine resources

PDO Level Results

Indicators* Co

re

D=Dropped

C=Continue

N= New

R=Revised

Unit of

Measure

Baseline

June 2011

2012-EOP Target Values

Frequency Data Source/

Methodology

Responsibility

for Data

Collection Proposed

Comments

/Rationale

for

Change

Original

Revised

Indicator One:

50% increased revenue

generated to GoK from vessel

licensing in 200 mile EEZ and

from nearshore fisheries

development

R Number $0.68m

(2009: 28

vessels,

$0.56m;

2010: 32

vessels,

$.960m;

2011: 34

vessels,

$1,02m)

Increased

revenue

generation to

GOK from

nearshore and

EEZ fisheries

Same

indicator,

but

improved

clarity of

formulation

and annual

fluctuation

corrected

through

using

US$/yr

based on 3-

year

average for

combined

nearshore

and EEZ.

50% 1.0m

Annually Accounting

records from

FiD Fisheries

MIS

FiD

Indicator Two:

10% increase in cost recovery

of MPAs

D Percentage 0 Sustainabili

ty aspect

already

10

25

covered by

increased

revenues in

the above

indicator

Indicator Three:

20% increase in micro, small

and medium sized enterprise

startups and business

expansions directly related to

project interventions in pilot

villages

D Percentage 0 Not a direct

aspect of

the PDO.

The Project

does not

directly

support

expansion

of micro,

small and

medium

enterprises.

20

Indicator Four:

Direct Project Beneficiaries

(number), of which female (%)

X

C Number/Per

centage

0 Mandatory

core

indicator

moved

from the

intermediat

e level as

required by

OPCS

1,000,

35% women

Bi-Annually Surveys,

Progress

Reports

KWS, NEMA,

KEFRI, CDA,

KMFRI

Indicator Five Quality of data, data coverage

and reporting frequency of

catch and effort (the frame)

(15,000 records by EOP)

improved. and associated with

by-catch management measures

R Hectares 0 Target areas

with annually

updated geo-

referenced

biodiversity

data

Replaced

with a

measurable

indicator.

15,000

records

10,000 ha Annually MIS FiD, KWS,

KMFRI, KEFRI

Indicator Six:

At least three of the more

important existing conservation

areas brought under effective

management (including co-

management) by EOP)

R Hectares 0 Conservation/

target areas

with

management

plan in place,

implemented

and showing

improvement

Same

indicator,

but

improved

clarity of

formulation

3 5000 ha Annually Annual

Reports; Mid-

Term Review

and ICR using

Management

Effectiveness

Tracking Tool

KWS, KEFRI,

NEMA

26

in

management

as shown by

effectiveness

tracking tool

by EoP.

INTERMEDIATE RESULTS

Intermediate Result (Component One): Sustainable management of fisheries resources

Revised Intermediate Result (Component One):

Intermediate Result indicator

One:

Installation of VMS on all licensed fishing vessels in the EEZ by the

end of year 6 leading to less illegal

and more legally licensed fishing when combined with a strong MCS

R Number 0 Number of

vessels licensed

to fish in the Kenyan waters

with VMS

installed

Same

indicator, but

improved clarity of

formulation

Installation

completed

20 Annually Reporting VMS

units

FiD


Two: Number of Fishery Management

Plans

R Number 1 (Prawn

fishery)

Number of species with

Fishery

Management plans developed

Same indicator, but

improved

clarity of formulation.

Currently the

Prawn Fishery

Management

plan exists. By EOP will

target ring

net, lobster and

aquarium

fisheries

3 3 (Ring Net,

Lobster)

Bi-Annually Surveys, Monitoring

Reports

FiD, KMFRI


Three: Number of stock assessment (five

priority species and others)

R Number 0 Number of key

exploited species

with stock status established

Same

indicator, but

improved clarity of

formulation.

By EOP will have stock

5 3

(Lobsters,

Aquarium, Small and

Medium

pelagic)

Bi-Annually Surveys,

Monitoring

Reports

FiD, KMFRI

27

assessments

for (1) lobster, (2)

aquarium,

and (3) small and medium

pelagics

Intermediate Result (Component Two): Sound management of natural resources

Revised Intermediate Result (Component Two):


One: Number of Direct Beneficiaries,

including percentage of female beneficiaries

X

C Number/Perce

ntage

Moved to the

PDO level as

required by OPCS


Two: Integrated Conservation Management Plans developed and

implemented

R 0 Number of

Management Plans (MPs)

developed or

updated

Same

indicator, but improved

clarity of

formulation to reflect

input to PDO

3 3 Bi-Annually Progress Reports KWS, NEMA,

KEFRI


Three: Biodiversity management

information system is developed,

populated and updated annually

N YES/NO NO The new

indicator measures

key progress

towards achieving

PDO

YES Bi-Annually Surveys, GIS

progress reports

KWS, NEMA,

KEFRI


Four: Reduction in destructive activities

such as dynamite fishing, cutting mangroves, charcoal

manufacturing, etc.

D Percentage 0 The indicator was removed

due to

challenges of collecting

accurate data


Five: Number of communities engaged in

activities to preserve and use

sustainably the coastal and marine resources


successful community based

interventions

documented and disseminated

Participation

in conservation

in itself does

not indicate a behavioural

change. Lack

5 10 Bi-Annually Policy studies,

monitoring reports

KWS, KEFRI,

CDA, KMFRI, FiD

28

of

information on best

practices was

noted as a hindrance to

adoption

thus the need for an

indicator on

acquiring and

disseminatin

g information.


Six: Number of community level resource-based businesses

established

D Number 0 Not a direct

aspect of the

PDO, which focuses on

improved

effectiveness of coastal

and marine

ecosystem management

and use

3

Intermediate Result (Component Three): Support for Alternative Livelihoods

Revised Intermediate Result (Component Three):


One: Land Capability and Spatial Development Plans prepared in 1

Coast Province; 2 Districts; 8

combined action plans developed


regions and wards with

coastal land

capability plans or maps

developed

Indicator

changed due to

consideration

of various components,

sub

components

and sectoral

spatial

planning needs.

Resultant

output is

1

provincial,2 district, 8

action plans

1 coast region,

2 county, 8 ward level

plans

Bi-Annually Reconnaissance

Surveys, GIS progress reports,

GIS data base

Physical Planning

Department

29

integrated

spatial development

plan


Two: Number of officers from lead

agencies trained on EIA/EA review

process


officers from lead agencies

trained on ICZM

& EIA (including EIA certification)

Same


clarity of

formulation and better

link with

PDO

85 85 Bi-Annually Training reports,

NEMA reports

NEMA


Three: Number of environmental audits

for KCDP community based projects undertaken

R Number 0 Annual

environmental

and social audits for KCDP

supported

projects undertaken

Same

indicator, but

improved clarity of

formulation

3 3 Bi-Annually NEMA reports NEMA


Four: Number of PPPs funded and still in operation at EOP

D Number 0 Not a direct

aspect of the

PDO, which focuses on

improved

effectiveness of coastal

and marine ecosystem

management

and use

5 By-Annually CDA records and

monitoring

reports

CDA


Five:

Entrepreneurs identified,

trained, and with business plan

developed

N Number 0 The new indicator

measures

key progress towards

effective

management of coastal

and marine

resources use

200 Bi-Annually Project records and progress

reports

CDA

Intermediate Result (Component Four): Capacity Building, Monitoring & Evaluation System, Project Management, Communication and Coastal Village Fund

Revised Intermediate Result (Component Four): Capacity Building, Monitoring & Evaluation System, Project Management, Communication and Development Fund of the Coast

30


One: Number of CVF subprojects (community demand-driven, social,

and income generating) completed

and operational

R Number 0 Number of HMP

subprojects (community

demand-driven,

social, and income

generating)

completed or operational

Same

indicator, the change

merely

reflects the new name of

the grant

fund -- Development

Fund of the

Coast (Hazina ya

Maendeleo

ya Pwani – HMP). The

target has

been reduced to better

reflect the

pilot nature of these

activities.

500 200 Bi-Annually M&E reports,

Certificates of completion

KEMFRI


Two: M&E reports produced

R YES/NO 0 Performance

monitoring reports (with

progress on

agreed

indicators)

produced on time and with

satisfactory

quality

Same


clarity of

formulation

YES YES Quarterly and

Annually

M&E reports,

Mid-Term review report,

ICR

KCDP/KEMFRI


Three: Number of staff from participating

institutions trained

D Number 0 This information

is in the

work plan-input level

indicator


Four: Communication products and

channels identified and developed

by end of PY1 and accomplished by EOP

R YES/NO NO Communication strategy in place

Replaced with a

measurable

indicator

YES YES Quarterly, Annually

Outputs from strategy

KMFRI

Annex 2: Updated Governance Action Plan

Significant Weaknesses/Risk Action/Risk Mitigation Measure Responsible Person Completion Date Poor accountability in project

management and use of resources Enhancing social accountability will entail the following

actions:-

Participation and empowerment of coastal stakeholders

through information disclosure on all aspects of the

project. Some of the disclosure features will be:

i) Posting of information in public places, in particular,

Provincial and District Headquarters, locations and sub-

locations, as well as through the World Bank’s InfoShop.

ii) Creation of a project website on which to publish

information on funds disbursed for various components,

their intended use and the location of those investments.

iii) The local media will also have access to information on

a quarterly basis for publication in the daily press.

iv) Local CSOs will participate in carrying out a yearly

social Audit. The ensuing Report will be shared with the

Bank and the Permanent Secretaries.

v) A Citizen Report Card will be prepared before the

Project Midterm Review.

vi) Regarding accountability around training, the project

has taken the following specific measures: 1) preparing a

project training plan, linked with procurement rules, and

cleared by the TTL; 2) developing standardized rates and

rules for training, regardless of level or institution; 3)

disclosing lists of training participants lists disclosures.

vii) Regarding accountability on per diems paid by the

project, the project is developing a policy outlining the

specific rules for per diems. The policy will outline the

specific circumstances and rates that will be paid, based

upon an evaluation of circulars from the implementing

agencies institutions and from Treasury. The policy will

Implementing agencies

and PCU

32

be publically disclosed.

Establishment of a Coastal Area Advisory Committee

(CAAC), with a social audit function and an advisory role

to the KCDP. The CAAC will ensure the inclusion of the

beneficiaries in the Coastal Region as well as the

transparency of all project activities.

Enhanced measures to ensure transparency and

appropriate use of HMP funds, including the

participation of the beneficiaries and their representatives

in the management of funds allocated to the community

sub-projects, periodic audits of financed sub-projects,

disclosure of sub-project level reports, a system of fund

use monitoring at the community level, community

Governance Training, and a Risk Mitigation Plan to

address cases of reported misuse of funds. The project is

also developing measures to publically disclose

information on all activities supported through the HMP

including a geo-referenced database with details on the

subproject objectives, contacts, and funding approved and

disbursed.

Significant Weaknesses/Risk Action/Risk Mitigation Measure Responsible Person Completion Date Complaint handling mechanisms Complaints handling through the establishing of a

project grievance mechanism. Such a mechanism will

include clear procedures, responsibilities, and service

standards to ensure any project complaint will be handled

in a transparent and democratic manner, at the appropriate

level -- both the local (county) as well as the regional level

(Coastal Region/KCDP). The main instruments and

approaches foreseen in the PIM to ensure transparency and

accountability include: (i) dedicated phone and email

accounts; (i) creation of a dedicated position within PCU to

handle complaints and grievances under supervision of a

committee; (iii) structured reporting; (iv) publication of

PCU

33

financial support to beneficiaries on a website; (v) regular

value for money audit; and (vi) irregular inspection and

verification.

Integrity enhancement among

Project staff

In collaboration with the Kenya Anti Corruption Council

(KACC), the Project will provide staff with skills on

corruption prevention, corruption red flags and corruption

reporting. At least one integrity workshop will be held per

year.

PCU/

Implementing agencies

at all levels

Specific sanctioning of an

institution

Wrongdoing in the Project implementation unit will be

made public and disbursement of resources stopped in that

particular institution. The Project will be proactive in

supporting public debate on areas that undermine project

implementation. This will be done through local media.

PCU

FINANCIAL RISKS AND ACTIONS

Significant Weaknesses/Risk Action/Risk Mitigation Measure Responsible Person Status The several implementing

agencies under KMFRI pose an

accountability challenge because

of inadequate capacity in this area.

Poor accountability of funds

expenditure leading to increase

possibilities of misuse

Implementation delegation

between Min. Fisheries and

implementing partners not clear

Hiring a FM and procurement consultant for two years will

enhance capacity at the PCU level.

KMFRI will, not later than February 15, 2011, computerize

its accounting functions.

Setting low ceilings for the maximum amount of money

that subsidiary project accounts and in the Regional

Development Authorities can hold (US$100,000 max).

The Subsidiary agreement signed between MoFD and Core

Ministries clearly spells out duties and responsibilities and

the role of the PCU

PCU

KMFRI

ALL

Ministry of

Fisheries

Development

Completed

Completed

Completed (through

MIP)

Completed

Management of staff imprests No individual will be allowed to carry imprest on behalf of PCU and ALL

34

groups, unless specific exceptions have been requested and

approved by the PC – The Financial and Procurement

Section of the PIM contain direction.

No imprest can be taken to hire training facilities. This

payment is made directly from the Account holders in the

project.

Imprest to individual staff will be sent directly to their

accounts to avoid signficant cash handling and collusion.

Capacity building workshops and

seminars

Training calendars are to be prepared in advance and

approved as part of the Procurement Plan.

Participants lists are to be disclosed.

Payments for training are to be made directly to the

Training institutions and participants booked full board

without per diem, unless specific exceptions have been

requested and approved by the PC.

Training activities are to be audited at least once a year.

PIM to contain guidance on the above

PCU and All

In process

Nepotism In order to tackle nepotism, there will be no hiring of

relatives using KCDP. Persons violating this rule are

subject to dismissal. Any contracted staff will be required

to sign a disclosure form. Their contract will contain this

clause.

Per diem and allowances Payments of eligible per diems and allowances need to

follow Bank’s and GOK’s rules.

PCU and All

Fuel and fleet

management

Regarding vehicle running and fuel costs, the project is

establishing a system to ensure sound management of

vehicle-related aspects. Such a system is expected to

In process

35

include contracting of a vehicle fleet service, development

of a vehicle log system, quarterly monitoring of the same,

and follow-up as necessary. Management should include

monitoring the cost of repairs per vehicle. A mechanism to

receive monthly returns for vehicle management from all

areas where vehicles are stationed will be put in place and

described in the PIM.

PROCUREMENT RISKS AND ACTIONS

Risk Action Timeframe Responsibility Inadequate procurement capacity

at KWS, KEFRI, CDA and MoF

CDA will set up a Project coordination Unit staffed with a

qualified procurement officer conversant with Bank’s

procurement procedures.

KWS and KEFRI will second to the Project a senior

procurement officer conversant with Bank’s procurement

procedures.

The Ministry of Finance (MoF) will second a senior

procurement officer to the project conversant with Bank’s


Development and follow up of a plan on formal training

program for all procurement staff.

Conducting of procurement clinics/training on Bank’s


Completed

Completed

Completed

In process

Completed/ongoing

Recipient /

IDA

Review threshold Prior review required for three additional goods, works and

consultants’ contracts, each of which are below the prior

review threshold, at random, each year of project

During implementation

of the Project.

IDA

36

implementation.

Procurement planning Each Agency should develop and regularly update a

project-specific Procurement Plan. KMFRI should

consolidate the Plan.

Completed Recipient

Procurement audit The Public Procurement Authority (PPOA) will conduct

procurement audits for sub-projects in addition to Bank’s

PPRs


of the Project.

Recipient

Inadequate record keeping and

filing system

Creation of a procurement filing system on a contract–by-

contract basis.


of the Project.

Recipient

Procurement oversight Establishment of all the relevant procurement oversight

committees in accordance with the provisions of the law.


of the Project.

Recipient

Office space Providing adequate office and storage space, equipment

and access to internet facilities.

In process Recipient

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