Categorization: According to World Bank documentation, The project is categorized A because of the potential adverse environmental and social impacts of the civil works activities related to rehabilitation of priority infrastructure; undertaking structural improvements for critical public assets such as hospitals, airport, public buildings; and rehabilitation of the damaged spillway and stilling basin to improve dam safety, major rehabilitation of bridges and CDC, cleaning of river channels on main three rivers, and restoring or establishing natural flood retention ponds may have significant adverse impacts that are sensitive, diverse, cumulative, irreversible or unprecedented. Project documentation states that, the environmental and social impacts associated with rehabilitation and restoration of drains, bridges and culverts on critical secondary and tertiary sub-catchment areas across the city of Ibadan; undertaking flood plain management activities and structural improvements of critical public assets such as hospitals, public buildings are expected to have site-specific and moderate impacts, which are listed in the Environmental and Social Management Framework (ESMF). In addition to negative environmental impacts, the ESMF lists the following social impacts for the IUFMP: The impact of floods is often as dramatic as it is negative on individuals, families, communities and governments. Flood engenders socio-economic and humanitarian crises (loss of lives, disruption of livelihoods and economic activities, loss of property and damage to critical public infrastructure roads, utilities, and school buildings, displacement of whole families, and spread of diseases). All this negatively affects the standard of living, resulting in impoverishment, increased social vulnerability and, above all, threat to life. Other anticipated benefits which are further discussed in the ESMF - include enhanced safety, improved health, and general well-being of beneficiaries through improved sanitation and hygiene occasioned by better drainage system. Sources: *World Bank Documentation Applicable Social and Environmental Standards -Environmental Assessment OP/ BP 4.01 Safeguards policy OP 4.01 is triggered, in component 2 and since the exact locations and impacts of the sub-projects have not been identified; an Environmental Management Framework (ESMF) is prepared. According to Bank documentation, The following five safeguard policies are triggered, namely Environmental Assessment (OP 4.01), Involuntary Resettlement (OP 4.12), Natural Habitats (OP/BP 4.04), Physical and Cultural Resources (OP/BP 4.11), and Safety of Dams (OP/BP 4.37). -Involuntary Resettlement (OP/BP 4.12) This policy is trigged because, according to Bank documentation most of the sub-projects could involve land acquisition and or restriction of access to usual means of livelihood as most of the sub-projects will largely be rehabilitation of existing infrastructure. However, some of the projects may involve significant land acquisition and displacement of affected people. -Natural Habitats OP/BP 4.04 This policy is triggered because some project activities may take place near to critical natural habitats (forests, wetlands, mangroves, etc.) or environmentally sensitive areas and some mitigation measures may be necessary to minimize any adverse environmental and social impacts. The Bank claims, The rehabilitation and operation of dam and drainage systems could affect downstream rivers, floodplains, wetlands and other fragile ecological systems thereby triggering OP4.04. The project will also include interventions in upstream catchments. -Physical Cultural Resources OP/ BP 4.11 This policy is triggered because some activities in components 2 may include civil works that could expose chance finds. These chance find sites may include sacred shrines and burial sites. Similarly, The project will carry out earthworks that may impact on some physical cultural resources along the river drainages system. -Safety of Dams OP/BP 4.37 Although the proposed project will not be directly involved in the construction of new dams, component 2 may include rehabilitation of damaged spillway and stilling basin to improve dam safety thus triggering OP4.37. Sources: *World Bank Documentation Consultation Project documentation states, Stakeholders consultation were carried out during project preparation, however, additional consultations and a more detailed social assessment will be carried out as needed in the course of the selection of specific project sites. The project's necessary safeguards instruments the Environmental and Social Management Framework (ESMF) and Resettlement Policy Framework (RPF) in accordance with National and World Bank policies, were prepared by the Borrower and were disclosed in-country in Nigeria and in the World Bank's InfoShop on January 24th, 2014. According to Bank documentation, the project's key stakeholders are the Oyo state ministries of Environment and Habitat; Water Resources; Urban Development and Physical Planning; Works; Emergency management Agency; the 11 Local Government Agencies (LGAs); local communities, Nongovernmental Organizations (NGOs) and other relevant institutions. The Bank claims, All the relevant stakeholders have been adequately informed of the project, and that key concerns raised during the consultation processes included Land degradation & land use; Water pollution and drainage systems; Solid management; Waste Water Management; Floods; man induced issues; Labour and socio-economic issues; Public Health (Especially HIV/AIDs; Water-borne diseases & Choleras; STIs; Malaria; etc). These concerns are reflective of how Nigerian's feel about the weakened effectiveness of government policies, as outlined above, specifically poor solid waste and wastewater management policies, which arguably resulted in the 2013 cholera outbreaks in parts of the city. Project documentation states that public participation and consultation i.e. meetings, radio programs, requests for written proposals/comments, filling in of questionnaires, explanations of project to the locals, making public documents available at the state and local levels will be an on-going activity taking place throughout the entire project process. Sources: *World Bank Documentation ENVIRONMENTAL AND HUMAN RIGHTS RISK ASSESSMENT Right to Culture According to Bank documentation Excavation/earth works, deforestation activities and other engineering activities, e.g water channeling increase the likelihood of archeological and cultural losses. Some activities, documentation states, in Components 2 may include civil works that could expose chance finds. These chance find sites may include sacred shrines and burial sites. According to the Bank documentation, in the event of chance finds of items of cultural significance, all forms of excavation in and around the site will be stopped. Subsequently, experienced archaeologists and anthropologist would be recruited to carry out an investigation and proposed plans for the preservation of such cultural artifacts. The following questions may be relevant to determining whether you or your community's right to culture has been adversely affected by the investment project: -Do the land, natural resources, or other sites affected by the investment project have a cultural significance for your community? -Have your traditional practices or knowledge been affected since the beginning of the investment project? - What opportunities (legal or other) are available if you feel that your right to take part in cultural life has been restricted or denied? - Has your community been discriminated against because of its culture as a result of this proposed project? Sources: *World Bank Documentation Right to Health The World Health Organization (WHO) defines 'health' as a state of complete physical, mental and social well-being and not merely the absence of disease or infirmity. World Bank documentation on this project notes that the effects of a development project on individual mental and physiological well being (health status and trends) are often omitted or treated in an unsatisfactory manner. Some groups of individuals may be more exposed to harmful pollutants and their health status will decline. Health impacts also can occur directly from project activities, particularly from hazardous wastes stream, improper disposal of construction wastes, air and water pollution. For example, Water-Borne Diseases, e.g. Cholera, Dysentery, Amoebiasis sp., [and] Salmonellosis sp., in communities are often the result of such project activities. Local communities may find the following questions relevant to assessing whether they may be suffering a human rights violation resulting from the construction or operation of the Project: -Do you have reasons to believe that your health and/or your access to health services could be affected as a result of the planned investment Project? -Have you as an employee or an inhabitant of a nearby community experienced any health issues since the advent of the Project's activities? -Does the Company have a policy or program to ensure that its activities do not cause public health problems or affect people's right to health? Sources: * http://www.who.int/about/definition/en/print.html *World Bank Documentation Right to Housing and Property According to Bank documentation the World Bank policy on Involuntary Resettlement OP4.12 is triggered because the IUFMP will finance productive infrastructure investments that may require land acquisition and/or land use leading to loss, denial or restriction of access to economic resources. Impacts due to involuntary resettlement from development projects give rise to severe economic, social and environmental risks if left unmitigated such as: landlessness, homelessness, joblessness, food insecurity, increased morbidity and mortality, educational loss, social displacement, marginalization, and loss of access to common property. Those people who feel any of those impacts are, according to the World Bank, described as a project affected person (PAP), who, as a result of works carried out or to be carried out under the Project, would incur: (i) relocation or loss of shelter, such as houses; (ii) loss of assets or access to assets, such as land or crops; or (iii) loss of income sources or means of livelihood whether or not the affected persons must move to another location, such as stalls or productive activities on the land; or (iv) the involuntary restriction of access to legally designated parks or protected areas, which would result in adverse impacts on the livelihoods of displaced persons. Project documentation states, Since the exact nature of project construction activities that may lead to taking of land and the construction sites are not known at the time of the preparation of the project, the preparation and disclosure of this [Resettlement Policy Framework (RPF)] by the [Ibadan Urban Management Project (IUMP)] office is a conditionality for appraisal of this project. However, during implementation of this project the identification of the specific activities that will lead to taking of land and the areas that will be specifically involved will be made. When that happens, people will be affected. At that stage, the Bank's policy calls for the preparation of individual Resettlement Plans that must be consistent with [the] RPF. The legal framework for land acquisition in Nigeria is the land use Act of 1978, reviewed under Cap 202, 1990. The relevant World Bank operational policy (OP 4.12), which addresses land acquisition and involuntary resettlement was reviewed. The differences between the Land Use Act and the Bank's OP 4.12 are mostly in rehabilitation measures, which are neither proscribed nor mandated in the Act. Thus it is noted in this RPF that in the event of divergence between the two, the World Bank safeguard policy shall take precedence over Nigeria Land Use. Given these considerations, the following survey questions related to the rights to land and property should be raised by communities and individuals affected: -Have you and your community had an opportunity to provide meaningful input at each stage of the project design and planning, including on economic resettlement plans, and provide suggestions about alternatives to relocation? - Has the land provided following relocation been adequate and of an equal or better quality than the land previously occupied? - If you were resettled, do you feel that you received adequate compensation for your land, housing, crops, or other assets? - What options do you have (legal or otherwise) at your disposal in the event that you feel that your right to property or adequate land or employment has been compromised? Sources: *World Bank Documentation Right to a Healthy Environment Bank Documentation addresses a significant number of harmful impacts that the proposed project will likely have on the environment during each of the project's phases. According to the Bank documentation, Sub-projects like constructions [and] excavations are likely to lead to significant conversion or degradation of natural habitats, described as land and water areas whose ecological functions have not been essentially modified by human activities. During site preparation the mobilization of equipment, construction activities including movement of goods and services the clearing of natural vegetation and excavation may expose soil surface to erosion and water pollution. Likewise, The clearing of natural vegetation, excavation and compaction activities may expose the soil surface to erosion, and will alter the soil properties including loss of valuable top soils. The Bank also recognizes that project activities, such as grading, dredging, filling, and excavation, have the potential to reduce the number of flora and fauna species in the area. The project is projected to have more harsh affects on the water, soil, and air quality during the construction phase. According to Bank documentation soil quality will suffer due to, pollution as a result of improper disposal of excavated materials and construction wastes; 
Exposure of soil surfaces to rain and wind;
 [and] High sediment yields from construction activities. Similarly, exposing the surface soil to erosion, will alter the soil properties including loss of valuable top soils; 
Presence of undercutting in roads; 
and Increased flooding in other areas, which can lead to destruction of lands, crops and properties. The clearing of natural vegetation, specifically in Eleyele dam, will result in landscape degradation and a harmed eco-system. Bank documentation states, Vegetation clearing in Eleyele dam to expose concrete surfaces, [and c]leaning of drainage channels along flood plains will ultimately lead to the destruction of animal species breeding grounds and ecological niches. Local communities may find the following questions relevant to assessing whether they may be suffering a human rights violation resulting from the construction or operation of the Project: -Do you feel that your natural environment (air, water, land, animals, and plants) has changed since the start of the investment project? -Where will hazardous waste be disposed of and what impact is this likely to have on the local environment? -What means do you have to seek redress if the environmental impact of the proposed operations become a problem for local communities and/or the local ecosystem? Sources: *World Bank Documentation Right to Water Bank documentation addresses the environmental impact of the proposed project on water quality. During the pre-construction phase, Bank documentation states, The mobilization and transport of soil particles may, in turn, result in sedimentation of surface drainage networks, which may result in impacts to the quality of natural water systems and ultimately the biological systems that use these waters; Increased sedimentation and runoff during the construction activities such as in the rehabilitation of culverts and bridges. During the Construction phase possible impacts to water quality are, according to Bank documentation, the pollution of water as a result of improper disposal of excavated materials and construction wastes, 
oxygen depletion, increased turbidity, aggravation of eutrophication, change in pH levels; and
 increased cases of disease, illnesses (especially waterborne diseases). The Bank also flags the potential negative impact that improper solid waste management, as a result of construction, may have on the water quality. Bank documentation identifies Pollution of nearby surface water and soil as a result of improper disposal of excavated materials and construction wastes as a potential project impact. Local communities may find the following questions relevant to assessing whether they may be suffering a human rights violation resulting from the construction or operation of the Project: -Does the company or its subsidiaries have a policy or program to ensure that its activities do not affect communities' and individuals' right to water? -Has your access to good and affordable water in sufficient quantity been affected since the beginning of the investment project? -Has the quality of local resources necessary for subsistence (e.g. crops, herbs, animals you rely on for food, etc.) decreased as a result of the Project's environmental impacts? Sources: *World Bank Documentation

ACCOUNTABILITY MECHANISM OF WORLD BANK The World Bank Inspection Panel is the independent complaint mechanism and fact-finding body for people who believe they are likely to be, or have been, adversely affected by a World Bank-financed project. If you submit a complaint to the Inspection Panel, they may investigate to assess whether the World Bank is following its own policies and procedures for preventing harm to people or the environment. You can contact the Inspection Panel or submit a complaint by emailing ipanel@worldbank.org. You can learn more about the Inspection Panel and how to file a complaint at: http://ewebapps.worldbank.org/apps/ip/Pages/Home.aspx.