Indonesia - Third National Program for Community Empowerment in Rural Areas Project

Page 1 INTEGRATED SAFEGUARDS DATASHEET APPRAISAL STAGE I. Basic Information Date prepared/updated: 03/03/2010 Report No.: AC5081 1. Basic Project Data Country: Indonesia Project ID: P115052 Project Name: Third National Program for Community Empowerment in Rural Areas (PNPM-Rural Task Team Leader: John Victor Bottini Estimated Appraisal Date: February 10, 2010 Estimated Board Date: March 30, 2010 Managing Unit: EASIS Lending Instrument: Specific Investment Loan Sector: Sub-national government administration (25%);Water supply (20%);Irrigation and drainage (20%);Roads and highways (20%);Primary education (15%) Theme: Decentralization (23%);Rural policies and institutions (22%);Participation and civic engagement (22%);Rural services and infrastructure (22%);Social safety nets (11%) IBRD Amount (US$m.): 785.00 IDA Amount (US$m.): 0.00 GEF Amount (US$m.): 0.00 PCF Amount (US$m.): 0.00 Other financing amounts by source: Borrower 552.00 552.00 Environmental Category: B - Partial Assessment Simplified Processing Simple [] Repeater [X] Is this project processed under OP 8.50 (Emergency Recovery) or OP 8.00 (Rapid Response to Crises and Emergencies) Yes [ ] No [ ] 2. Project Objectives PNPM's overall objective is to reduce poverty and improve local-level governance in Indonesia through the provision of investment resources to support productive proposals developed by communities, using a participatory planning process. PNPM-Rural#s project development objective is for villagers in PNPM-Rural locations to benefit from improved socio-economic and local governance conditions. PNPM-Rural is also an effective mechanism for addressing various environmental/ natural and man-made crises. KDP/PNPM-Rural proved to be a robust tool for addressing post-conflict and post-disaster needs, as seen in Aceh after the 2004 Indian Ocean tsunami and the subsequent Memorandum of Understanding (MOU) that ended thirty years of conflict, and more recently in central West Java (2006) and in West Sumatra (2009) in the wake of devastating earthquakes. In response to the recent financial crisis, the GOI is looking towards PNPM-Rural to provide a means to rapidly disburse critical resources in case of a pronounced slowdown in economic growth. Page 2 3. Project Description The project will cover approximately 420 additional sub-districts, which were recently created by the administrative division of sub-districts and their subsequent incorporation by GOI into the program. It will also continue to support those 4,371 sub-districts already which are participating. The project will utilize the institutions established and processes and mechanisms developed under the first PNPM-Rural project and its predecessor KDP projects, building upon experience gained and lessons learned. The four components will be similar to the ongoing project. Component 1: Kecamatan Grants (US$1,186.82 million). The main activity in PNPM- Rural III, similar to PNPM-Rural and Rural II AF, will be the construction of economic and social infrastructure that is needed and requested by the target communities. The selection of activities is by the community themselves and is open except for items specifically excluded through the project's negative list, or for land purchases of any kind. These activities are funded through grants disbursed by the government to the sub- districts (kecamatan) and villages. Financial services. While project will also continue to support revolving funds managed by women's groups, efforts will be focused on promoting more sustainable access to financial services to the poor, while at the same time maintaining and improving community ownership. Discussions with GOI on a multi-year pilot for access to financial services to the poor, especially targeting women beneficiaries, are currently underway. Presenting details on the best approaches to ensure the financial sector can play a more active role in expanding the poor#s access to sustainable financial services will be part of the pilot's work. Crisis response and other initiatives. There are also a number of special initiatives that can be funded using the block grant disbursement mechanism provided certain procedural changes are made to the standard PNPM-Rural Project Manual and if complemented with additional facilitation and technical assistance. They include inter alia: (i) Responding to crises, including natural disasters, financial, and post-conflict situations, where an accelerated planning and disbursement cycle is allowed; and (ii) Support for communities for investments that are environmentally friendly, including investments in renewable energy, in particular micro-hydro power. Pilots. In addition to the core sub-district planning and block grant scheme, PNPM- Rural has operational pilots funded through loans and grants from several bilateral donors (Australia, Canada, Denmark, The Netherlands, and United Kingdom). The pilots build upon the main PNPM platform and principles of community participatory engagement. Two of the major pilots are: (i) PNPM-Generasi or the incentivized block grant scheme for the achievement of MDGs related to health and education; and Page 3 (ii) Green PNPM to support natural resource management and renewable energy initiatives. Component 2: Facilitation Support (US$ 78.47 million). This component consists of salary and operational costs for the sub-district technical and social facilitators and kabupaten facilitators. It also includes activities to strengthen inter village organizations and forums and local government coordination and oversight. Component 3: Implementation Support and Technical Assistance (US$ 41.75 million). This component provides implementation support, training and technical assistance at the national and provincial levels to manage the program and strengthen the capacity of local governments. A portion of the national level support will include assistance to aid in the strategy development for PNPM going forward. The component also covers the costs of PNPM-Rural#s monitoring and evaluation program. In addition, it includes an enhanced audit program that expands sampling, provides capacity development support for district government auditors, and funding to repair problems that audit reviews attribute to project shortcomings. This project also funds most project training other the community- level training. Component 4: Project Management Support (US$ 29.96 million). PNPM#s special programs, which include pilot projects and government add-ons as well as crisis response activities (natural disasters, conflict, and financial), place several additional demands on normal government budgeting, particularly as the program is operating nationwide. Most of these operational costs will be covered by the Government through their national (APBN) and local budgets (APBD); a minimal amount is financed through the loan. Local Government Add-ons. The local governments of Aceh, Papua and West Papua are capitalizing on the CDD approach and have linked their own development programs to PNPM-Rural. (i) Aceh: PNPM-BKPG. In 2009, the Government of Aceh, as part of its village prosperity program (BKPG), allocated over US$100 million (approximately one-eighth of its provincial budget for the year) in block grants for 6,411 villages in 23 districts and 276 sub-districts. Planning and implementation of the funds are linked to PNPM-Rural#s (and PNPM-Urban#s for 411 of the villages) mechanisms and facilitators. PNPM-BKPG continues in 2010 but with increased block grant funds from both PNPM as well as from the local provincial government for BKPG. (ii) Papua and West Papua: PNPM-RESPEK. In 2007, the local governments of Papua and West Papua launched a village development strategy (RESPEK) and allocated about US$40 million for block grant investment funds for every village and linked planning and implementation of these funds to PNPM-Rural, utilizing over 1,000 facilitators to support about 420 sub-districts and more than 4,000 villages. PNPM- RESPEK continued fully funded in 2009, and is expected to continue in tandem with PNPM-Rural through 2010 as well. Page 4 4. Project Location and salient physical characteristics relevant to the safeguard analysis PNPM-Rural III will continue to be implemented nationwide and will cover more than 4700 rural sub-districts(which have over 61,000 villages), including some environmentally sensitive (forest, coastal, marine) and socially sensitive areas, for example in Papua, in some areas of Kalimantan, and in some of the islands near Sumatra. Salient features relevant to safeguards analysis and mitigation are financed by the project. Typical activities funded by the block grant investment funds under component I of the project are: (i) small- scale infrastructure investments identified and decided on by the community at large, with the involvement of women and vulnerable groups and indigenous persons mandated (project manual#s procedures); (ii) UPK (sub-district management unit) managed revolving funds provided to women#s savings and loan groups for income generating activities; and (iii) social investments, in education and health. The project provides block grants to communities to support sub-district and village level planning processes, including the provision of training and technical inputs to strengthen planning and implementation readiness. Planning includes a simple, community assessment of environmental impact. As a repeater project with similar design and project components, no new safeguard issues are anticipated. Experiences from the ongoing PNPM-Rural and Rural II Additional Financing projects as well as their predecessor, the Kecamatan Development Projects (KDP), indicate that any adverse environment impacts are site specific, very small in scale and can be managed locally by adopting good engineering designs and construction practices. Every location is assisted by an experienced engineer. Furthermore, there have been no significant adverse social impacts registered in either the KDP series of projects or the ongoing PNPM project, including in Papua, Kalimantan, Mentawai, and Nias, to name some of the more sensitive areas, where PNPM has been adapted to reflect unique geographical and cultural conditions. 5. Environmental and Social Safeguards Specialists Ms Indira Dharmapatni (EASIS) Mr Andrew Daniel Sembel (EASIS) Mr Virza S. Sasmitawidjaja (EASIS) Page 5 6. Safeguard Policies Triggered Yes No Environmental Assessment (OP/BP 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 7.50) X Projects in Disputed Areas (OP/BP 7.60) X II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts: There are no large scale, significant, or irreversible impacts. PNPM investments are small (<$35,000), discrete, and non-cumulative. The project will not include any proposal that might require an AMDAL (Category A types of operations). The environmental screening criteria proposed by the project to address potential environmental impacts are acceptable and is the correct approach for this type of modular investment. Potential impacts from the proposed subprojects are likely to be site-specific, not significant, and can be managed by adopting good engineering design and construction practices. OP/BP 4.01 Environmental Assessment All civil works have some impact on the environment although the works built by villagers with assistance from KDP/PNPM-Rural are very small and have mostly negligible negative impacts. A Bank consultant was tasked over the last two years to examine the quality of village infrastructure designed and built by villagers as part of the KDP/PNPM-Rural, including environmental impacts. The study indicated that almost half of the very small projects had a very minor impact that could be have been reduced further with more thorough screening, better designs, and more intensive and focused construction supervision. Eighty four percent (84%) of the sub-projects had very low, nominal impacts involving the need for better drainage (mostly for dirt roads) and localized micro-erosion from run- off. Only nine percent (9%) of these sub-projects with some impact deserve more attention. These include sanitation projects (toilets) without septic tanks or with some localized discharge from septic tanks; and 21 small sub-projects resulted in some localized ground contamination from chemical leakage from engines (used for water pumps usually). These problems are easily rectified. The sub-projects that deserve the most attention (2% of the total observed) are those that involve - blockage of a small watercourse and steep new dirt roads that lack proper drainage. Serious attention must be given to adequate drainage on steep roads during the design stage, during construction (such as delaying the second and third tranches of funding until drainage is satisfactory), Page 6 and during the O&M phase. Only two village dams were observed that were a concern, and the problem could be mitigated by the construction of check-dams that do not completely block the watercourse. Mitigation of these minor negative environmental impacts requires improvements in facilitator training, in the tools provided in the Project Manual and in improvements in the design and construction of the sub-projects. Intensified supervision, including the involvement of an environment specialist in supervision missions, is recommended. An illustrated field manual of good and bad practice in environmental management of small village infrastructure which is expected to help facilitators and villagers to minimize adverse environmental impacts was recently released. The basic environmental impact potential of investments supported through the project is low, so the general strategy followed under KDP and PNPM-Rural remains relevant. The project will continue to internalize environmental impact mitigation measures in all stages of the project activities in order to minimize the negative impacts. The following documents are available and will be used for managing environmental and social impacts from the proposed project: # Operation Manual, Annex 1 : Project#s negative list # Operation Manual, Form 22: Environmental Checklist, Handling of Potential Negative Impacts # Technical Operation Manual # Illustrative Field Manuals o Picture Book: The Good and the Bad Infrastructure # Road and Bridge (1) o Picture Book: The Good and the Bad Infrastructure # Water Supply and Sanitation (2) o Picture Book: The Good and the Bad Infrastructure # Miscellaneous (3) o Picture Book: The Good and the Bad Infrastructure # House Construction (4) o Picture Book: The Good and the Bad Infrastructure # Environmental Management (5) # Implementation Guidelines for Land Acquisition/Compensation # General Framework for IVP OP/BP 4.04 Natural Habitats It is expected that some sub-projects will be carried out in environmentally sensitive (forest, coastal, marine) areas - particularly throughout Sulawesi, Sumatra, Papua and Maluku. Experience implementing PNPM has shown that communities living in and/or near such sensitive habitats benefit from supplemental technical assistance designed to raise local awareness of environmental issues. Support of such technical assistance can do much to abate community practices which inadvertent degradation of the environment. Examples of these practices include some communities in South Sulawesi and southern Aceh mining coral to use in road construction/rehabilitation sub-projects; and communities in Sulawesi building roads that verge into protected forests. These types of cases reflect poor oversight by the provincial and district regulatory teams. As part of the effort to ensure that PNPM's activities do not contribute to further ecological degradation, an environmental pilot program, 'Green PNPM', was launched in Page 7 2007 with approximately $50 million in funding from Denmark, Australia, Canada, and The Netherlands. Scheduled to run through 2015, Green PNPM is currently active in more than 70 sub-districts throughout eight provinces in Sulawesi and Sumatra. Beyond providing community block grants specifically allocated for 'green' projects (e.g. watershed management, renewable energy, reforestation, and natural resource management planning, etc.), Green PNPM provides grant funding to local and international environmental NGOs throughout its target areas to raise local awareness of environmental issues and deliver training to community and local government officials in ecologically sensitive spatial planning and in monitoring the environmental impact of community development projects. To date, the pilot program has gone through two planning cycles, and participating communities have selected over 400 'green' sub- projects to implement with Green PNPM funds. The GOI is working to adopt the lessons learned through this Green PNPM and apply them to implementation and oversight of PNPM as a whole. Such lessons include targeting specific environmental awareness raising technical assistance on environmentally sensitive locales; increasing the training of local government officials and verification teams in evaluating and preventing and adverse environmental impact of sub-projects selected by communities; and potential avenues for strengthening the environmental safeguards applicable to PNPM - particularly in regards to local infrastructure projects. OP/BP 4.10 Indigenous Peoples Indonesian communities covered by the World Bank#s policy on indigenous people can generally be classified as falling in to one of three categories. First, there are small pockets of highly isolated, vulnerable groups such as the Mentawai or other small island populations. Such groups can easily be adversely affected by development projects because of unfamiliarity with modern market mechanisms, cultural and administrative prejudices against them, or inability to retain control over productive and natural resources. A second category refers to the much larger ethnic populations which meet most of the World Bank#s typological requirements (own language, sense of identity, traditional attachments) but exhibit varying degrees of vulnerability. Populations such as the so- called Dayak of Kalimantan or the tribal groups of Nusa Tenggara Timor fit here. The third group refers to heterogeneous communities, where a segment of the population is culturally or economically marginalized. Several of the fishing populations of the eastern islands, for example, have unique identities and also occupy subordinate positions within local social structures. As a project that begins from the principles of grassroots participation and flexible project designs/ procedures determined through local planning and decision-making by communities themselves, KDP and PNPM-Rural have not experienced any significant adverse impacts on indigenous or culturally distinct populations and none have been found during project supervision over the last eleven years. Experience has shown that incorporating considerations for the indigenous peoples in the planning processes of the Project Manual is key - to implementation progress and mitigating adverse impacts. The project will adopt the current General Framework for IVP of PNPM-Rural and update as Page 8 necessary to accommodate lessons learned and recent situations. Additional training is also being included in the project to improve the quality of facilitators. OP/BP 4.12 Involuntary Resettlement PNPM-Rural has a project land acquisition/compensation guideline embedded in its Project Manual. Application of the guideline, measured through field reviews of KDP and PNPM-Rural, reports generally good results from implementation of the policy. A recent review of about 350 representative sites found no cases of involuntary displacement. PNPM-Rural does not involve state powers of eminent domain at any stage, and land transactions can only take place on a willing-buyer/willing-seller basis. Land acquisition assessments are part of the proposal review process and must be approved by the district level oversight engineer. Land and resettlement are also recorded in the village records and reviewed during field supervision. No significant adverse impacts from land acquisition or involuntary resettlement resulting from a KDP subproject have ever been reported. However, there are occasional cases where engineers do not follow the safeguard review rules or villagers have felt pressured to contribute land without receiving #fair# compensation in return. In such cases proposed works are canceled or redesigned and there have been no cases found where land was actually transferred by force or threat of force. PNPM's training is being improved to strengthen facilitator skills and oversight by district consultants. The project has also adopted the Guidelines for land acquisition/compensation and will update it as necessary to accommodate lessons learned. The project also documents land acquired through donations from villages. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: There are no significant long-term potential impacts triggered by this project. The primary environmental impact would be caused by increases in commercial activity caused by improved farm to market linkages. However, all such roads are small (avg. 3 kms). 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. NA 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. The project's Guidelines and Operation Manuals has embedded instruments for the safeguards policy triggered by the program. These (embedded instruments) has been disclosed in the infoShop for the orginal project, showing and explaining how and where in the project mechanism and procedures(the planning and implementation process by the community itself) the instruments for the triggered safeguards elements are applied. The indigenous people's concerns are met primarily through the design of the project itself since the whole point of demand-driven investment funds like KDP/PNPM Rural is to allow the villagers themselves - where the IPs are among them or as the primary beneficiaries - to make the decision over how development resources (the block grant) Page 9 get used. Therefore a separate IPP is not required. The design of the sub-projects where IP communities are benefitted from or affected is by the community members themselves, the same way as in the other villages. That is how the elements of an IPP is included in the design of the sub-projects. The Borrower (the central PMU and down to the village level) is familiar and has the capacity to implement the environmental and social guidelines enshrined in the operations manual, in its processes and procedures for land acquisition and resettlement and Indigenous Peoples. The implementing agency have managed the implementation of the KDP series and PNPM-Rural and Rural II AF over the last 11 years. The National Consultant Team is currently assisting the PMU and has experts who have sufficient experience in environmental management and social safeguard issues, including land acquisition and gender and safeguarding isolated vulnerable peoples, or IVPs. This project will adopt the same Project Manual of the ongoing PNPM-Rural. The manual and the training has been and will be improved and updated, as necessary, based on lessons learned and implementation experiences. Each kecamatan has a minimum of two facilitators, of whom one is a civil engineer who assists the local communities on subproject designs and implementation. These facilitators are required to consider the possible environmental and social impacts of proposed subprojects. Impacts are defined as those changes that arise directly as a result of development activities, both positive and negative. The project will continue strengthening the capacity of project management staff, consultants and facilitators in environmental and social safeguards. Learning from experiences of the KDP series and PNPM-Rural and Rural II AF, the project will improve the documentation of the consultation process and supporting information pertaining environmental and social safeguards. Web-based reporting will also be improved. The Project will not finance sub-projects that use items listed in the negative list, that will have potential negative environmental impacts or negative impact on cultural property or that have a potential large-scale land acquisition/ resettlement. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The key stakeholders and decision makers (for funding of sub-projects) are villagers in rural areas themselves. The project manuals are posted on the project's website; explained in detail at the first inter-village meeting, at the first village meetings and then in community training for village facilitators and for the village implementation teams as well. The social assessment and FPIC is the first part of the project processing by the targeted community itself. The mechanism prior to sub-project identification, village proposal decision, and sub-project design involves social, poverty and problem mapping, priority discussion among villagers themselves, special women meeting which will produce 2 out Page 10 of 3 village proposal to be submitted for funding; all done through focal group discussions, a facilitated wide village meetings, and review of safeguard issues which must be anticipated in the village proposals document. There are four particularly important concerns in how the project approaches indigenous communities: (i). developing dissemination and facilitation materials in collaboration with local communities (issues of language, graphics, etc); (ii). using appropriate, inclusive self decision-making mechanisms in environments where indigenous groups are politically and culturally marginalized; (i.e. the Papua PNPM-Respek) (iii) finding a balance so that groups (i.e. women) excluded from traditional institutions can also join project processes; (iv) Since KDP, the project included several adaptations to address concerns that marginalized indigenous groups are especially vulnerable to problems of elite domination and corruption. [by recruiting and training of facilitators from these communities, special logistical support, having 2 village facilitators (a man and a woman) trained and mentored to allow them to gradually in charge for village meetings under PNPM Rural planning and accountability meetings, village proposal writing team and village implementation committee comprise village elected team, etc.) Participatory consultation takes place in the formation of inter-village (MAD) and sub- village (MD) community meetings and verification teams at the village and sub-district level, preparation of the sub-project proposals and implementation of sub-projects. Environmental screening and mitigation measures are identified and agreed among the beneficiaries during the preparation of the sub-project proposals. Similarly, the need and mechanisms for obtaining land are identified and agreed among the beneficiaries through participatory consultations during the preparation of sub-project proposals. Facilitation and verification of the process and documentation included in the sub-project proposals are done by the facilitators. Disclosure is mandatory, and project conditionality includes village-level disclosure of operational rules, including safeguard rules. PNPM does not involve any state expropriation; all decisions, including safeguard-implying decisions, are by village level consensus. B. Disclosure Requirements Date Environmental Assessment/Audit/Management Plan/Other: Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 04/15/2008 Date of "in-country" disclosure 11/15/2008 Date of submission to InfoShop 04/15/2008 For category A projects, date of distributing the Executive Page 11 Summary of the EA to the Executive Directors Resettlement Action Plan/Framework/Policy Process: Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 04/15/2008 Date of "in-country" disclosure 11/15/2008 Date of submission to InfoShop 04/15/2008 Indigenous Peoples Plan/Planning Framework: Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 04/15/2008 Date of "in-country" disclosure 11/15/2008 Date of submission to InfoShop 04/15/2008 Pest Management Plan: Was the document disclosed prior to appraisal? Date of receipt by the Bank Date of "in-country" disclosure Date of submission to InfoShop * If the project triggers the Pest Management and/or Physical Cultural Resources, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: C. Compliance Monitoring Indicators at the Corporate Level (to be filled in when the ISDS is finalized by the project decision meeting) OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) report? No If yes, then did the Regional Environment Unit or Sector Manager (SM) review and approve the EA report? N/A Are the cost and the accountabilities for the EMP incorporated in the credit/loan? N/A OP/BP 4.04 - Natural Habitats Would the project result in any significant conversion or degradation of critical natural habitats? No If the project would result in significant conversion or degradation of other (non-critical) natural habitats, does the project include mitigation measures acceptable to the Bank? N/A OP/BP 4.10 - Indigenous Peoples Has a separate Indigenous Peoples Plan/Planning Framework (as appropriate) been prepared in consultation with affected Indigenous Peoples? No If yes, then did the Regional unit responsible for safeguards or Sector Manager review the plan? N/A If the whole project is designed to benefit IP, has the design been reviewed and approved by the Regional Social Development Unit or Sector Manager? Yes Page 12 OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/process framework (as appropriate) been prepared? Yes If yes, then did the Regional unit responsible for safeguards or Sector Manager review the plan? Yes The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the World Bank's Infoshop? Yes Have relevant documents been disclosed in-country in a public place in a form and language that are understandable and accessible to project-affected groups and local NGOs? Yes All Safeguard Policies Have satisfactory calendar, budget and clear institutional responsibilities been prepared for the implementation of measures related to safeguard policies? Yes Have costs related to safeguard policy measures been included in the project cost? Yes Does the Monitoring and Evaluation system of the project include the monitoring of safeguard impacts and measures related to safeguard policies? Yes Have satisfactory implementation arrangements been agreed with the borrower and the same been adequately reflected in the project legal documents? Yes D. Approvals Signed and submitted by: Name Date Task Team Leader: Mr John Victor Bottini 02/05/2010 Environmental Specialist: Mr Virza S. Sasmitawidjaja 02/03/2010 Social Development Specialist Ms Indira Dharmapatni 02/05/2010 Additional Environmental and/or Social Development Specialist(s): Mr Andrew Daniel Sembel 02/04/2010 Approved by: Sector Manager: Ms Sonia Hammam 02/06/2010 Comments: