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
Seleccionar párrafo de destino3
Añadir a la tabla de contenidos