PROJECT INFORMATION DOCUMENT (PID) APPRAISAL STAGE Report No.: AB5235 Project Name. Low Income Land and Housing Development Project Region
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1 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized PROJECT INFORMATION DOCUMENT (PID) APPRAISAL STAGE Report No.: AB5235 Project Name Low Income Land and Housing Development Project Region LATIN AMERICA AND CARIBBEAN Sector Urban housing (50%); Other urban development (50%) Project ID P Borrower(s) REPUBLIC OF COLOMBIA Implementing Agency Ministry of Environment, Housing and Territorial Development Environment Category [ ] A [X] B [ ] C [ ] FI [ ] TBD (to be determined) Date PID Prepared September 18, 2009 Date of Appraisal October 5, 2009 Authorization Date of Board Approval February, Country and Sector Background Housing Sector Issues The housing sector in Colombia is characterized by large quantitative and qualitative deficits and constrained capacity to meet residual and new demand for housing solutions. Based on results from the 2005 census, the overall housing deficit stood at 3.8 million of which 2.2 million households were in urban areas representing approximately 27 percent of all urban households in the country. An estimated 1.0 million of this deficit in urban areas was characterized as quantitative while the remaining 1.2 million households experience a qualitative housing deficit related to substandard structures and inadequate access to basic services. New household formation averaged just over 302,000 annually between 1993 and Extrapolating from the current household income distribution by income segment, in which 64 percent of households earn between 0 and 4 minimum wages 1 around 193,000 of these should be for low income or VIS housing. During the same period the overall housing stock expanded by over 261,000 on average annually. However, over 62 percent (or around 162,000) of this supply was in the informal sector thereby contributing to the growing qualitative deficit. Moreover, on average housing production per 1,000 inhabitants was 5.4 for the main six urban centers in Colombia for , comparatively, this figure was 22 and 13.4 for Ireland and Spain respectively in Main Factors in Access to Affordable Housing 1. Demand-Side Factors Institutions with mortgage finance products do not address the informal sector segment which accounts for 56.6 percent of the labor force in the thirteen main urban areas. Mortgage finance is mostly supplied by three types of institutions: Cajas de Compensación Familiar (CCF), the Governmnetowned National Savings Fund (FNA), and private Banks. CCF are entities funded through monthly contributions from private sector employers and salary deductions from their employees. Amongst the services they provide to their affiliates are housing and education loans. The FNA is a public entity 1 One monthly minimum wage (2009) is equal to 496,900 pesos, around 226 USD 2 Includes Bogota D.C, Medellín A.M., Cali A.U., Barranquilla A.U., Bucaramanga, A.M., and Pereira A.U. Source: CENAC
2 financed through public-sector employees monthly contributions and provides long-term funding for housing and other uses. By their limited mandates, both these institutions leave the informal sector workers unaddressed. Banks have remained risk adverse after the mortgage sector crisis and have not developed a product line specifically for people working in the informal sector. The role of the CCFs has grown in the last four decades to include a vast array of services including health and housing finance in addition to housing subsidies. Overall subsidy allocations are not sufficient to match the scale of desired increases in housing production for VIS segments if housing demand is to be met. Colombia has two distinct national level housing subsidy programs for households with incomes below 4MW: (i) Fonvivienda programs funded from the national budget, and (ii) Cajas de Compensacion Familiar (CCFs) programs which receive funds through the 4 percent labor tax levied on formal sector wages out of which a fixed proportion can applied to housing subsidies. Both programs subsidize finished housing through an upfront national subsidy complemented by beneficiary savings and by either additional subsidies from local government (in the case of FonVivienda subsidies) or a mortgage loan (in the case of CCF subsidies). Only 2,000 FNV subsidies were allocated in 2007 in principal urban areas through the Bolsa Unica where vast majority of demand is located. Household growth and deficit figures are highest in the income category of below 4 minimum wages. To address this problem, CCF could fee up subsidy funds by lowering the subsidy amount for households above 2 minimum wages could afford a higher loan amount. Preliminary calculations for 2007 suggest that for the income levels above 2 MW the actual loan amount is considerably below the repayment capacity of the households. 3 Alternatively, the cost of finished housing solutions could be lowered by considering expandable units and higher densities. Large-scale increase in subsidy delivery will necessarily require a credit component, which as mentioned above, remains a challenge in particular for the informally employed which account for most of the unmet housing demand. As Banks have in the past only extended credit to formally employed workers who are considered lower risk because of regularity of income and the option to deduct mortgage payments from salaries directly. In the future, it will be essential that banks or other financial institutions develop underwriting systems and credit risk management systems to serve the informally employed segment of the market 4. Such investments have been hindered particularly during times when the cap on interest rates put a limit on their ability to recover such costs through interest rates. And while this constraint was not binding in the last few years, and some banks began to experiment in this sector, current uncertainties in financial markets are likely to hinder further expansion. Potential solutions can focus on alleviating these lender constraints and/or on creating incentives more entrepreneurial non-bank financial institutions to enter this market. Utilizing of Findeter liquidity funding specifically for mortgages to this employment group, which will enable new non-bank institutions to develop specialized systems to serve the informally employed; or exploring public mechanisms to compensate the lender for the higher servicing cost and risks imbedded in lending to this clientele (particularly in the current macro-economic climate where interest rate caps become binding) and to allow lenders to develop appropriate systems for serving informally employed. Supply-side factors 3 CCF subsidy recipients typically obtain loans through private banks. The average loan for VIS housing is in the order of US$ 2,300 to 2,500, with a 15-year term and an interest rate of 8% + inflation. The average LTV for the period was 55.7%. 4 One bank with some experience in serving informal workers mentioned that while defaults did not appear to be higher for informal workers in general, defaults among displaced people were noticeably higher.
3 The developer sector is too concentrated and with limited access to finance. While big construction companies of Brazil and Mexico operate in other Latin American countries and capitalize in international markets, Colombian companies do not have a significant operation anywhere outside the country. The number of players in the industry is low and limited to those players who have either land or financial backup such as a Bank within its business group. This situation has created a quasi-monopolistic market where specialization is rare. Separation of the land development from the construction process, real estate will benefit the VIS sector by lowering the costs. Additionally, limited access to construction finance for developers inhibits growth in the sector and transfers risk to homeowners. Construction finance is limited in Colombia, as seen in figure6 below the number of credits taken by developers in the financial sector in Colombia is extremely low and has increased only slightly in the last decade. Most developers business model does not include high leverage ratios from bridge loans. This restricted access to credit limits not only entrepreneurship but does not promote a risk-taking culture among housing builders. Traditionally, developers pre-sell the units until they reach an equilibrium point which is usually between 50 to 70% of the overall cost and is equal to the hard costs of the entire project. Only after the hard costs are secured the construction phase starts effectively transferring all the risk of construction from developers to households. This situation is likely to worsen in the current financial crisis as financial institutions avoid risk investments. The large urban centers where the housing deficit is concentrated face important constraints of serviced land for VIS housing.. Most municipal governments face financial constraints that limit their capacity to finance large capital investments such as trunk infrastructure. For high-income residential construction, developers are able to finance the trunk infrastructure and the corresponding costs are later recovered through house prices, but these added costs make housing unaffordable for many households. A high income development allocates around 7 percent of its costs to introduction of services, for a VIS project these costs represent almost 20 percent of the total. This problem is exacerbated given the lack of articulation of POTs with municipal development plans and sector agencies (i.e. electricity, water utilities, etc.), the volatility and speculation of prices of land, the lack of funding to finance the feasibility and technical studies, the lack of continuity in the local government policy due to the change in administration and the lack of private sector participation in VIS market. As a result, construction of VIS housing remains low at the risk of increased informal settlements. Complex land use planning regulations and development and construction permitting procedures add to the constraint of the supply of affordable land and housing. While technically a robust instrument for integrated land use planning, POTs are responsible for establishing very specific land uses for residential, commercial and industrial purposes. The legal process for amending POTs and developing a Partial Plan for very small parcels is exceedingly lengthy and equivalent to the same for major land use changes which involve public consultations, environmental assessments and high-level approvals from municipal authorities. Additionally, municipalities frequently lack adequate urban planning capacity to develop and review POTs and Partial Plans. This is most critically the case in predominantly rural municipalities bordering large cities that increasingly feel the pressure of resultantly informal urban expansion. The unit of analysis for each POT is the municipality and as such these instruments effectively lack an adequate regional land use framework. Converting rural or other non-residential land to urban land developable for residential purposes with associated development and construction permits is a highly complex and subjective process varying considerably across jurisdictions. A study by CAMACOL 5 for the Cundinamarca department which includes Bogotá, for 2007 found that the process for converting rural to urban land and acquiring 5 CAMACOL is the Camara de Construción de Colombia the Construction Chamber of Commerce for Colombia.
4 necessary land use and construction permits took over 7 years for the average parcel including considerable rent-seeking behavior by municipal officials throughout the process. The same study estimates that the cost of delays and procedures associated with this regulatory approval process adds up to 8 percent to the final cost of the finished housing unit. Additionally, building codes and norms are excessively rigid resulting in a final housing product that is unaffordable for a large segment of the population and consequently limiting the possibility of progressive housing development models. The limited supply of serviced land in key cities has an impact on land and housing affordability and intensifies development pressure in neighboring municipalities. Table 1 illustrates land scarcity in 5 major urban centers. Bogota, for example, has sufficient land for approximately 205,000 housing solutions. However, the accumulated quantitative deficit in the capital is estimated at over 282,000 units. A large percentage of this available land in Bogotá is along the northern corridor a primarily non-vis market. Land supply in Medellin and Bucaramanga is similarly limited. Additionally, a large proportion of this available land is not geographically contiguous thereby complicating the prospects for large scale housing development. Land scarcity in principal urban centers puts expectant development pressure on outlying municipalities. Moreover, on average only half of the land identified for urban expansion is available for development once areas for streets, parks and other urban spaces are taken into account. In general, for every hectare of available land, an average of 100 VIS units may be built. So for every hectare categorized as expansion, only 50 VIS houses could be counted in the most optimistic calculations. This is the least profitable use and developers will always prefer other uses on top of VIS. In addition, other uses are desirable for a balanced urban expansion. It is important to note, however, that effective policy should not focus on land scarcity in isolation as a large volume of land in urban areas suffers from suboptimal use. A more well-rounded policy approach would concurrently focus on increasing access to affordable land while also encouraging reforms to improve rental markets, decrease vacancy rates and encourage densification. Table 1: Availability of Land in Five Major Urban Centers (2005) City Urban Land under Residential Use (Ha) Available Urban Land for Residential Use (Ha) Potential Housing Units Bogotá 20,409 2, ,800 Cali N/A 1, ,000 Medellin 7, ,900 Bucaramanga 1, ,700 Barranquilla 2, ,700 Total 32,281 5, ,400 Source: DNP Government Strategy The Government has outlined a comprehensive policy platform to address these key areas of reform. In August 2005 the Government outlined a comprehensive Livable Cities strategy in the context of the President Uribe Administration Vision Colombia II Centenario: which focuses on creating access to affordable urban land and housing, improvements in water and sanitation service delivery and in the affordability and availability of urban transport. The strategy outlines 13 key sector goals and objectives for 6 See for the Ciudades Amambles or Livable Cities strategy and for the overall Vision 2019 document.
5 2019. These broad goals are more recently reflected in the National Development Plan which reinforces the Livable Cities strategy focusing national urban policy during the period on three key areas for investment and reform: (i) slum upgrading and basic service provision for informal settlements; (ii) Macroproyectos Urbanos for low income land and housing development; and (iii) urban revitalization and densification. The Government has since moved quickly to develop the Macroproyectos Urbanos program by passing Decree 4260 in November 2007 which outlines a broad framework for Government support to large scale low-income land and housing development. First, the decree enables the national government through MAVDT to supersede municipal land use planning authority in the development of social interest housing projects that provide housing solutions for at least 1% of the number of households in associated primary cities. This provision enables MAVDT with a mechanism for land use planning specific to these projects and superior to the POT instrument and associated approvals process. Second, the decree enables MAVDT to identify large parcels of land across multiple municipal jurisdictions and effectively apply a common land use planning regime to these projects. Third, the decree provides MAVDT with the authority to involuntarily acquire land from private landholders as a last resort based on independent market valuations and after other voluntary means to associate have been exhausted. Absent from the decree and the subject of ongoing technical work led by the Ministry are details regarding a wide range of more specific rules of the game for the program. 2. Objectives The project development objective is to increase access to affordable and serviced land for housing development for over 36,000 low income households. The Project will leverage the development of 36,000 low income housing units by financing approximately 12,000 supply-side housing subsidies within the context of mixed-use land development subprojects. The supply-side housing subsidies will be used for secondary infrastructure development associated with small and medium size land development projects of approximately 4,000 to 5,000 units. 3. Rationale for Bank Involvement The Bank is well positioned to support the Government of Colombia s housing sector program. First, the Macroproyectos program and this proposed operation have been identified by the Government in relation to equity and sustainable growth pillars of the National Development Plan (NPD) The Bank s Country Partnership Strategy 8 (CPS) for Colombia is organized around these NDP pillars. The CPS reflects the Bank s emerging approach in middle income countries (MICs) and includes a focus on frontier products in areas such as public-private partnerships. The proposed Project will contribute to a reduction in poverty by improving access to serviced land and formal sector housing solutions for lower income population segments. Second, the Government has outlined an aggressive countercyclical public investment program to stimulate growth, increase employment and improve access to infrastructure and services. Investments to stimulate the low and middle income residential real estate sector including the proposed operation are a key component of this strategy. The construction, residential rental and real estate service sectors 7 See for National Development Plan and Chapter 3.5 for urban strategy. 8 The CPS for Colombia was approved by the Board of Directors on March 4, 2008.
6 combined constituted 15.5 percent of GDP in 2007 and as such the proposed operation would reinforce growth and employment in these sectors. Third, the proposed Project builds upon and reinforces important recent Bank Group activities in Colombia. The IFC has supported the development of a successful secondary mortgage market through financial support to Titularizadora Colombiana, the country s first secondary mortgage company, and associated technical assistance. Bank lending of over US$450 million in the transport sector has supported the development of bus rapid transit systems in Bogotá and five major cities that have had major impacts in terms of reducing travel times, congestion and air pollution. These systems are designed around strategic growth corridors around which potential Macroproyectos would be developed. Bank support in the water and sanitation sector has supported dramatic service improvements through sector modernization in key metropolitan areas including Barranquilla and Cartagena. Fourth, the proposed operation is part of a broader Bank engagement with the Government of Colombia in the affordable land and housing sectors. The Bank has been actively engaged in a range of sector dialogues including demand subsidy reform, rental housing, construction finance and urban renewal and densification. In addition, the Bank has been asked by the Government to serve in an advisory capacity to an ongoing housing finance policy assessment process being led MAVDT and a team of external experts. The policy assessment process could lead to a series of concrete reform proposals to expand access to housing finance for low income households. 4. Description The Project will finance three components. Component 1: Subsidies for Low-Income Land and Housing Development (US$48 million, of which Bank financing is US$38 million). The component will finance supply-side subsidies for low income land and housing development. The subsidies would be used for investments in secondary water supply and sanitation, urban drainage, and basic transportation infrastructure associated with the implementation of selected land and housing development pilots. Electricity and gas secondary networks might also be financed through the subsidies when such investments cannot be financed directly by utility service providers. Component 2: Technical Assistance Program (US$0.5 million of Bank financing). The component will finance technical assistance to: (i) develop key aspects of the Macroproyectos Program model; (ii) structure specific Macroproyectos to be financed beyond the scope of this Project; and (iii) support key areas of housing policy reform and capacity building. Component 3: Project Management (US$1.5 million of Bank financing). The component will finance the operating expenses associated with program management, monitoring, implementation, evaluation and supervision within the Ministry of the Environment, Housing and Territorial Development (MAVDT). These activities will include the hiring of an independent Technical Advisory Group (Grupo de Apoyo Tecnica GAT) to validate real estate development transactions and instruments developed under the Program. The component will also finance costs associated with financial and technical audits, monitoring and mid-term and end project evaluation. 5. Financing Overall project size is US$50.0 million, of which US$40.0 million will be provided by the Bank and US$10.0 million by the borrower.
7 Components 1. Basic Infrastructure for Urban Land Development Table 1: Project components Total (US$m) World Bank (US$m) National Government (US$m) Technical Assistance Program Project Management Total Implementation Borrower: The Republic of Colombia through the Ministry of the Environment, Housing and Territorial Development (MAVDT) will be the recipient of the proposed SIL. The National Fund for Housing (FONVIVIENDA) within MAVDT as the executing entity for the Macroproyectos operation and will serve as the conduit for all funds under the Project. A Macroproyectos Unit within MAVDT will concentrate technical coordination and implementation supervision capacity. This document will hereafter refer to this implementation structure as MAVDT-FONVIVIENDA. Project Management: The Project has been designed to be implemented in four years and involves a combination of implementation, monitoring and oversight functions concentrated at the national level within MAVDT-FONVIVIENDA. Project implementation will also involve decentralized levels of Government and contracted private actors as described below. MAVDT-FONVIVIENDA. The Macroproyectos Unit within MAVDT will serve as the primary office for Program coordination and reporting to the Bank. More specifically, key functions will include: Identify and prequalify subprojects based on key technical and financial eligibility criteria; Lead process to announce Macroproyectos including the drafting and processing of the relevant administrative decree; Contract an independent Technical Advisory Group (GAT) to provide arms-length advisory support and technical assistance on real estate transactions; Contract a real estate structuring agent to structure real estate trust vehicles for each subproject; Contract fiduciary agents for each subproject to manage loan proceeds and other investment resources; Structure, contract and supervise the Documento Tecnico de Suporte (DTS) and land use plans through the fiduciary agent; Maintain oversight and provide a clearance function with respect to the design, implementation and contracting of bidding process for developer rights; Implement technical assistance activities outlined under component 2 of the Project; Coordinate project mid-term and end-project evaluations and financial audits; Conduct spot-checks of the technical quality of subprojects under implementation and completed; Supervise the procurement process for works and contract of consultant;
8 Maintain and update guidelines for the technical, economic, financial, social and environmental preparation of Macroproyectos; and Coordinate financial and operational reporting to the World Bank. The Project will finance the strengthening of the Macroproyectos Unit through the recruitment of engineers, real estate and finance specialists, architects and urban planners, and social and environmental specialists. The terms of reference for these staff will be agreed upon with the Bank and included in the Project Operations Manual. Municipalities. Municipal functions under the Project will include: Participate in the identification of potential Macroproyectos with MAVDT and other relevant actors; Ensure access to, monitor and maintain utility networks and access to Macroproyectos through agreements with local service providers and utilities companies; Process urban development and construction permits based on land use plans and DTS; and Participate in real estate trust governance. Technical Advisory Group (GAT). A Technical Advisory Group (GAT) will be contracted by MAVDT to provide independent and arm-length advisory support and validation on real estate transactions. The GAT will be contracted as a firm and will include leading expertise in real estate finance and development, real estate and commercial law, urban development and planning and low-income housing development. The contract structure for the GAT will be on a retainer basis. Real Estate Structuring Agent. A real estate structuring agent will be contracted by MAVDT to manage the financial and legal structuring of the subproject. The structuring agent will combine extensive experience in investment banking, project finance, land and real estate law and real estate development and finance. The structuring agent will primarily oversee: (i) the structuring of each real estate trust; and (ii) the design and implementation of the bidding process to award developer rights. The contract model for the structuring agent will be similar to those used in Colombia for the concession of complex infrastructure projects. Fiduciary Agent. A fiduciary agent will be contracted for each subproject to manage relevant fiduciary aspects associated with implementation. The Bank has an extensive track record in Colombia in working through fiduciary agents. Consistent with agreements with the National Government, the use of a fiduciary agent for the operation is justified given that: (i) the fiduciary agencies hired under the project would be selected among commercially available entities that would provide basic fiduciary management services; (ii) the fiduciary agents would be selected on a competitive basis; and (iii) this approach has been successfully used in most large real estate developments in Colombia and in other bank operations (Water Sector Reform Assistance Project, Loan 7077-CO, the Water and Sanitation Sector Support Project, Loan 7281-CO, and the La Guajira Water and Sanitation Infrastructure and Service Management Project (Loan CO). 7. Sustainability The proposed Project has been designed to ensure the sustainability of the land and housing developments that will be financed through the supply-side housing subsidies based on a careful consideration of environmental, economic, technical, institutional, and social factors. For each pilot subproject to be financed, a thorough social and environmental assessment will be carried out, based on established criteria and methodology outlined on the Social and Environmental Management Frameworks (SMF and
9 EMF). Assessments will assure that the future home owners have access to the necessary public services, and that environmental impacts will be reduced or mitigated. Independent technical supervision will be contracted for each subproject to validate and ensure the compliance of developers with the technical specifications for infrastructure works and with environmental and social management requirements. The technical assistance component of this loan proposes a business model and a comprehensive set of guidelines (urban planning, environmental, social, financial, etc.) for future operations. These low income land and housing development projects will be compatible with urban planning regulations, ensure the provision of social services and as such will be sustainable housing solutions for the urban poor. Additionally, the Macroproyectos Program will encourage private sector investment and the development of new market instruments in order to relieve pressure on Government financing. The real estate development model that will be supported under the Program will aim to deliver a replicable and scalable low income land and housing development program to address the supply-side constraints that impact Colombia s large housing deficit. 8. Lessons Learned from Past Operations in the Country/Sector Socially inclusive and mixed-use urban development. The Project builds on international experiences of low-income housing and the need to promote a socially inclusive and mixed-use urban development. International experience in public housing has demonstrated that public housing developments - disconnected from middle-income, commercial and retail uses - can be associated with significant social problems. Public housing complexes that concentrate and isolate poor and extremely poor and at risk families have been associated with high rates of crime, delinquency, social pathologies and limited intergenerational social and economic mobility. The Project conversely focused on mixed-use and mixed income housing developments that integrate public housing into a more sustainable urban fabric. Additionally, Macroproyectos will have strategies for the management of crime and violence, linkages with social protection, security services and communications and outreach strategies to develop and cultivate social networks. Build on private sector finance and real estate development capacity. International experience in housing policy emphasizes the importance of building on and leveraging the capacity and financial incentives of developers and the financial sector. The Project has been designed to transfer the greatest proportion of the commercial and project risk for each subproject to the private sector through the bidding out of development rights. Sites-and-Services Portfolio. The Project builds upon the Bank s previous experiences in sites-andservices projects which highlight the importance of market-based approach to overcome some of the shortcomings during the project implementation, such as lack of complementary infrastructure provision and construction financing. The Project finances supply-side subsidies in association with the implementation of a public-private model for land and housing development. The Bank s experiences in similar projects also emphasize maintenance and operation of the financed facilities and cost recovery tariff structure to ensure sustainability. For this, each eligible subproject in the Project will have an agreement with the responsible public authority and relevant utilities for the future financing plan and operation and maintenance of the facilities during the early stage of implementation. Innovative local approaches for land management. The Project builds on the local practice and the legal framework for land use management in Colombia. The City of Bogota has implemented since the late 1990s an innovative program - Metrovivienda which aims to generate affordable land for low income housing development (see Annex 1 for a more detailed analysis of Metrovivienda). The Metrovivienda model requires public financing for land assembly and secondary infrastructure development after which
10 superblocks are sold to developers for social interest housing development. Despite the programs early success it has in recent years found itself underfinanced and negatively impacted by excessive public sector involvement in the selection of developers. The agency has also received criticism for lacking capacity to effectively negotiate land purchases and sales on behalf of the city. The Project builds on the Metrovivienda experience by: (i) reducing the fiscal burden on the public sector by obviating the need for land purchase and sharing the cost of secondary infrastructure development; (ii) engaging developers as commercial partners rather than purchasers of developed superblocks ; and (iii) engaging private real estate development expertise to arrange and structure deals. Additionally, the Project works within land management regulations as outlined in Law 388 of 1997 which amongst other provisions enables the use of land value capture instrument to cross-subsidize the cost of infrastructure development. Support full system housing reforms. Interventions in the housing sector often run the risk of addressing one piece of a complex housing market system. Investment under the Project will focus on addressing supply-side constraints in the housing puzzle. However, the Project has been evaluated with an assessment of housing and construction finance, markets, and subsidy policy and land use management regulations (see Annex 1). Additionally, the Project will support under Component 2 through technical assistance in parallel areas of reform including construction finance, access to credit for informal households, populations and simplification of construction permits and licenses, densification and rental housing. 9. Safeguard Policies (including public consultation) Safeguard Policies Triggered by the Project Yes No Environmental Assessment (OP/BP/GP 4.01) [X] [] Natural Habitats (OP/BP 4.04) [X] [] Forests (OP/BP 4.36) [] [X] Pest Management (OP 4.09) [] [X] Physical Cultural Resources (OP/BP 4.11) [X] [] Indigenous Peoples (OP/BP 4.10) [] [X] Involuntary Resettlement (OP/BP 4.12) [X] [] Safety of Dams (OP/BP 4.37) [] [X] Projects on International Waterways (OP/BP/GP 7.50) [] [X] Projects in Disputed Areas (OP/BP/GP 7.60) * [] [X] 10. Contact point Contact: Taimur Samad Title: Senior Urban Specialist Tel: (202) Fax: (202) tsamad@worldbank.org * By supporting the proposed project, the Bank does not intend to prejudice the final determination of the parties claims on the disputed areas
11 11. For more information contact: The InfoShop The World Bank 1818 H Street, NW Washington, D.C Telephone: (202) Fax: (202) pic@worldbank.org Web:
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