what formats and forms of communication will be used to make information accessible to persons with disabilities. C. Consultations and Feedback mechanisms 1. Special accomodations for meaningful consultations → The revised SEP points to strategies to remove obstacles to participation for some marginalized groups See section C.1 in the main text for more information about relevant ESF requirements Borrowers are required to explain the ways they will “remove obstacles to participation” in the project for stakeholders, and must conduct consultations in a “culturally appropriate format, in relevant local language(s) and is understandable to stakeholders.”11 Meaningful consultation must also support “active and inclusive engagement with project-affected parties.”12 The revised LCERP SEP marked an improvement from the original SEP in identifying what different stakeholders need to participate in the project and consultations. It has a section titled “Proposed strategy to incorporate the view of vulnerable group [sic],” which provides strategies to “effectively engage and communicate” to “vulnerable groups”: women, pregnant women, elderly, people with disabilities, children, and street vendors commonly known as ZOGOs.13 The revised LCERP also notes that focus group discussions have already taken place during the beginning of project implementation in “different local languages (dialects)” and indicates that this will be an option for future consultations. It does not, however, specify which and how many languages were used. Still, strategies are only listed for some of the groups categorized as “disadvantaged or vulnerable.” The project categorizes “people living on the streets” and “people living in informal settlement slum communit[ies] as “disadvantaged or vulnerable,” and these are both groups that may have particular difficulty accessing information about the project and consultations so that they can participate. Borrowers are required to remove obstacles to participation for all stakeholders, and by only listing strategies for 11 See 3biv and 3dii under ESS10 in Annex 1: “Environmental and Social Framework,” 99, par. 16; 99-100, par. 22(a) and 22(c). 12 See 3diii under ESS10 in Annex 1; “Environmental and Social Framework,” 100, par. 22(d). 13 Srivastava, “Revised SEP - Liberia COVID-19 Project,” 39. BANK INFORMATION CENTER | MAR 2021 engaging some marginalized groups, project staff may ultimately prioritize engagement with those groups, thereby improving their access to project benefits and not others. 2. Clear timelines and personnel for consultations and feedback → The revised SEP includes more information about the topics of consultations and who will carry them out See section C.2 in the main text for more information about relevant ESF requirements Borrowers are required to “describe the timing and methods of engagement with stakeholders throughout the life cycle of the project” in the SEP.14 They are also required to designate which personnel will implement and monitor consultations and other forms of stakeholder engagement.15 The Bank is also required to monitor stakeholder engagement and consultations by Borrowers.16 A template SEP the Bank created for Borrowers also suggests that when key factors about a project are unknown during project preparation, the SEP needs to provide specific details about ways people can get more information when it is known. The original SEP did not provide descriptions or a timeline for consultations and engagement, and did not specify what personnel was responsible for carrying out consultations. It also provided very little information about the topics that would be addressed during consultations.17 The revised SEP, on the other hand, includes a table that explains the different types of consultations and messaging that will happen at different stages of project preparation and implementation.18 For each stage of the project, the table lists the agencies involved in conducting the consultations and messaging, and that an “Environment and Social Specialist” will be involved in carrying out the engagement. This SEP was disclosed about three months after the project took effect, and also describes consultations staff conducted during that time, primarily with government agencies and international institutions.19 14 See 3bi under ESS10 in Annex 1; “Environmental and Social Framework,” 98-99, par. 14. 15 See 3fi under ESS10 in Annex 1; “Environmental and Social Framework,” 100, par. 28. 16 See 1d under ESP in Annex 1; “Environmental and Social Framework,” 9, par. 50. 17 Chisaka, “SEP - Liberia COVID-19 Project,” 10. 18 “Revised SEP - Liberia COVID-19 Project,” 29. 19 “Revised SEP - Liberia COVID-19 Project,” 16. 44