Submission Date: December 1, 2009

Expected Calendar (mm/dd/yy)
Milestones	Dates
Work Program (for FSPs only)	06/26/2009
Agency Approval date	04/29/10
Implementation Start	02/01/2010
Mid-term Evaluation (if planned)	08/01/2012
Project Closing Date	02/01/2015

part i: project Information

GEFSEC Project ID: 2602

gef agency Project ID: 95925

Country(ies): Egypt

Project Title: Alexandria Coastal Zone Management

GEF Agency(ies): ,

Other Executing partner(s): EEAA, Egypt

GEF Focal Area(s):

GEF-4 Strategic program(s): IW-SP2 - Reducing nutrient over-enrichment and oxygen depletion form land-based pollution of coastal waters in LMEs consistent with the GPA

Name of parent program/umbrella project: INVESTMENT FUND FOR THE MEDITERRANEAN SEA LME PARTNERSHIP

A. Project framework

¹ List the $ by project components. The percentage is the share of GEF and Co-financing respectively of the total amount for the component.

² TA = Technical Assistance; STA = Scientific & Technical Analysis.

* The Monitoring function under component 3 applies to all project interventions including evaluation and reporting whereas the Monitoring function in component 1 is only intended to monitor the water quality of Lake Mariout and the Mediterranean Sea. In addition, the monitoring equipments are different for each component and require a different set of skills for their operation

** Project management costs are embedded in Component 3, and therefore the estimated PM costs shown are inclusive and should not be added on top of the total cost.

B. Sources of confirmed Co-financing for the project (expand the table line items as necessary)

* Percentage of each co-financier’s contribution at CEO endorsement to total co-financing.

C. Financing Plan Summary For The Project ($)

D. Consultants working for technical assistance components:

* Details to be provided in Annex C.

E. Project management Budget/cost

* Details to be provided in Annex C. ** For others, it has to clearly specify what type of expenses here in a footnote.

F. Does the project include a “non-grant” instrument? yes no
(If non-grant instruments are used, provide in Annex E an indicative calendar of expected
reflows to your agency and to the GEF Trust Fund).

G. describe the budgeted m &E PLAN: EEAA will be responsible for monitoring the progress of the Project, in collaboration with the Alexandria EEAA Regional Branch Office (RBO). The detailed arrangements for M&E[2] including indicators are included in the Project Appraisal Document in Annex 3and in the Operations Manual of the project management unit. EEAA will report to the Bank in quarterly and annual progress reports.

A M&E specialist will be responsible for preparing the periodic Project progress reports, including reporting progress on general implementation and progress against agreed indicators (mid-term review & completion report). The M&E specialist will be assisted by an M&E consultant, to be contracted and paid under the project funds as part of component (3) activities.

part ii: project justification: In addition to the following questions, please ensure that the project design incorporates key GEF operational principles, including sustainability of global environmental benefits, institutional continuity and replicability, keeping in mind that these principles will be monitored rigorously in the annual Project Implementation Review and other Review stages.

A. State the issue, how the project seeks to address it, and the expected global environmental benefits to be delivered: Background: Degradation of water quality due to land-based pollution is a major problem in the Mediterranean coastal areas. The Strategic Action Plan for the Mediterranean[3] has identified several “hot spots and sensitive areas” on the northern coast of Egypt, which for several decades have been experiencing a continuous increase in population, development, and environmental degradation. Two of these “hot spots” are located in Alexandria, namely El-Mex Bay and Abu-Qir Bay. Please see attached map.

Lake Mariout is one of the major sources of conveyance of land based pollution to the El-Mex Bay. According to the Transboundary Diagnostic Analysis (TDA) for the Mediterranean Sea, the pollution load reaching the Mediterranean Sea via the two hot spots in the Alexandria area are significant with more than a third of the total Biochemical Oxygen Demand and Chemical Oxygen Demand discharges in the area.

Today, the Lake Mariout receives polluted water from three major sources:

(a) Industrial effluents: Various industries discharge directly their effluents into the lake or El Mex Bay. The pollutants brought by the industries include high COD and heavy metals.

(b) Domestic effluents: Two wastewater treatment plants discharge their primary treated effluents into the Lake Mariout. The total discharge of primary treated sewage is about 916,000m3/day. The East Waste Water Treatment Plant releases effluents into Dayer-El-Matar drain which then empties into the Lake. Additionally, Lake Mariout receives effluent that is discharged directly from the West Waste Water Treatment Plant.

(c) Drainage water from agriculture: The Lake receives an important part of agricultural drainage water coming from secondary drains and agricultural activities upstream, bringing pesticides, nutrients (phosphate, nitrogen compounds, sulphate, etc) along with organic matter from animal farming and domestic wastewater of nearby villages.

Eutrophication in the basins of the Lake and open sea has been reported. Today, 60% of the Lake basins are covered by plants and aquatic weeds causing the Lake to lose its attraction as a recreational resort. More significantly, however, eutrophication negatively affects the livelihoods of the local population including marginalized groups like the fishermen who are highly dependent on the fish catch from the Lake basins for their income.

Project Objective: The project’s environment hypothesis is that in order to reduce the land-based sources of pollution in the hot spots of El-Mex Bay and Alexandria, including Lake Mariout, all stakeholders and agencies at local, regional and national levels need to be empowered and work together to ensure the sustainable management and protection of the Egyptian coastal zones around the Mediterranean Sea. Efforts are already underway with the on-going preparation of a national strategy for Coastal Zone Management (CZM), the existence of a Lake Mariout management committee under the responsibility of the Ministry of Agriculture and the re-instatement of the National Committee for CZM.

The project will support these initiatives and create synergies among them not only with the preparation and adoption of a master plan on CZM for Alexandria, including Lake Mariout, but also with the piloting of innovative and low-cost technologies and measures for pollution reduction originating from agricultural drainage water and rural domestic wastewater, partially responsible for the severe eutrophication problem in the Lake basins. The project complements conventional infrastructure-based treatment plants which receive concentrated effluent from urban and industrial areas. It proposes innovative integrated and natural process based options such as wetlands which are used as nutrient traps to treat more diffuse pollution load coming from upper parts of the water catchment.

To treat the more diffuse land-based sources of pollution entering Lake Mariout, the project proposes to use in-stream treatment (i.e. bio-films), which introduces a dynamic, mobile and easily manageable technique mechanism. The in-stream treatment, although relatively new in Egypt, has been used successfully by the MWRI as a pilot and has been recommended for broader application elsewhere in the country by other agencies. During project preparation, a pre-feasibility analysis of the pollution reduction measures was conducted and found that the implementation of a number of small interventions (in stream bio-films and in-stream aeration, pilot in-lake wetland, and weed removal) could significantly improve the average water quality of entering Lake Mariout and subsequently the Mediterranean Sea.

The main package to be considered will thus be composed of the biofilm with needed, or additional, aeration and the in-lake wetland. Because the Qalaa drain (where the project interventions will take place) is currently anaerobic (less than 0.5 mg/l dissolved oxygen), aeration is needed to provide the adequate aerobic conditions. The high running costs of aeration if not coupled with a serious cost recovery component might put the whole investment at risk of reverting to the substantially lower efficiency of operation under anaerobic conditions. Therefore, the high potential for income generation represented by the duckweed crop is integrated within a larger package. By integrating the biofilm, the aeration and the in-lake wetland techniques better results are expected. The synergetic effect of the in-stream bio-film and the in-stream aeration will give the in-lake engineered wetland a medium water quality permitting the latter to initiate its own ecological cycle that will permit the cultivation of duckweeds. The duckweeds will in turn absorb the nutritive salts and oxygenate the effluent. Feasibility studies and detailed design will be done in the course of Project implementation, following detailed field surveys and investigations, for which provisions have been made under the Project. Due diligence will be carried out before a decision is made on specifics of the final interventions. With regards to selection of aquatic plant for the in-lake wetland, it will be chosen so that maximum economic benefits (as feed for fish, poultry, etc.) can be obtained, without compromising on human or animal health impact (bio-concentration of heavy metals). The final feasibility study will therefore evaluate the level of heavy metal in both reeds and aquatic plants (duckweed or water hyacinth) for the optimal use of these resources, without being a threat to human or animal health. The study will also recommend various alternative options for use of harvested aquatic plants (e.g. handicrafts).

Expected Global Environmental Benefits: The project is expected to yield global environment benefits through the following key outcomes: (i) Reduction, albeit marginal, in the load of land-based sources of pollution from water nutrients entering the Mediterranean Sea hot spots through Lake Mariout; (ii) Improvement in the ecosystem health of the Mediterranean Sea hot spots and Lake Mariout including in the fish production and bio-diversity; (iii) Pollution reduction measures are scaled up in Alexandria and replicated in other coastal lakes in Egypt and surrounding Mediterranean countries. Although the reduction of land-based sources of pollution entering the Mediterranean Sea from this project will be small, its impact, collectively with the other pollution reduction interventions originating from industrial and domestic urban wastewater, will be significant. This project is one of others project to be implemented under the International Water program, which -collectively- would reduce the pollution load entering the Mediterranean Sea.

B. Describe the consistency of the project with national and/or regional priorities/plans: The proposed GEF project which includes the drafting and adoption of a Master Plan on CZM for Alexandria including Lake Mariout is directly consistent with the on-going preparation of the National Strategy for CZM in Egypt. The National Strategy is prepared under the leadership of the Egyptian Environmental Affairs Agency (EEAA). The project will also complement efforts underway by the Government of Egypt to upgrade the Eastern and Western primary treatment plants, as part of the Alexandria City Development Strategy. Finally, the master plan on CZM and the related public consultations will facilitate and serve as input for the preparation by the Ministry of Housing, Utilities, and Urban Development (MHUUD) of the urban development plan for Alexandria, including Lake Mariout.

Describe the consistency of the project with gef strategies and strategic programs: The activities under the proposed project are aligned with the International Waters Focal Area Strategic Programs for GEF-4, approved by the GEF Council in September 2007, and are contributing to the GEF4 Strategic Objective #2 of the IW focal area. In particular, originally designed in conformity with Operational Program #2 and Operational Program #8 under GEF-3, the project is equally aligned and being developed within the framework of the “Reducing nutrient-enrichment and oxygen depletion from land-based pollution of coastal waters in LMEs” of the International Waters Focal Area Strategic Program #2 of GEF-4. The project will demonstrate how a heavily degraded lake can be rehabilitated using low cost ecological technologies and through policy and institutional reforms as well as innovative partnerships and community participation. The project is directly in line with the implementation of the Strategic Program #2 expected outcomes: political commitments to nutrient and other pollution reduction and Integrated Coastal Management (ICM); institutions and reforms to catalyze implementation of policies for coastal pollution reduction and ICM; and multi-agency partnerships to catalyze innovative investments for nutrient reduction. Specifically, the results framework of the project is aligned with the indicators of the SP #2, i.e. national inter-ministerial committee on ICM; adoption of ICM master plan for Alexandria and policy, legal and institutional reforms; and monitoring of reduced levels of nutrient releases at demonstration sites.

The project is also consistent with the objectives of the Investment Fund for the Mediterranean Sea Large Marine Ecosystem Partnership (World Bank) to accelerate the implementation of transboundary pollution reduction and biodiversity conservation measures in priority hotspots and sensitive areas of selected countries of the Mediterranean basin that would help achieve the SAP MED and SAP BIO targets. The expected results of the Investment Fund are in line with the project’s anticipated results such as increased capacity of countries to implement policies and strategies that address SAP priorities, promotion of most innovative project and technologies, development of replication strategies at national and international level, and monitoring of stress reduction measures at water body level.

As part of the dissemination and replication strategy under component 3, close linkages and synergies will be established with the GEF’s International Waters Learning Exchange and Resource Network (IW LEARN) programs, including development of a website consistent with IW-Learn, production of experience notes, and participation in IW-conferences. In addition, the project impacts will be monitored on an annual basis using the GEF IW Tracking Tool including process and stress indicators which are reflected in the Results Framework. The monitoring of indicators and assessments will guide the preparation of the annual work plan by the PMU in consultation with the stakeholders.

Finally, the proposed GEF project is in conformity with the GEF’s Operational Program # 2 “Coastal, marine and freshwater eco-systems” and Operational Program # 8 “Water based operational program” by addressing land based pollution as a transboundary environmental concern and addressing specific impairments to a waterbody.

The project is consistent with the eligibility criteria of the Investment Fund for the LME as shown by Table below.

C. justify the type of financing support provided with the gef resources. The financing support provided will be in the form of a grant. The GEF project is critical as it adds to a significant mass of investments from the GoE by treating more diffuse pollution coming from agricultural drainage water and rural domestic wastewater through innovative and natural processes in an effort to develop an integrated approach to coastal zone management in Egypt.

D. Outline the Coordination with other related initiatives: The proposed GEF project will build on the existing structures, investments and linkages established by other projects financed by the Bank and by other donors to reduce pollution loads entering Lake Mariout. Specifically, it should be emphasized that the proposed project is complimentary to other on-going projects, each addressing a different source of pollution. The other set of interventions include the EPAPII sub-projects and the Government upgrade of the East and West Waste Water Treatment Plants.

· EPAPII: The GEF project is partially blended with the Second Egypt Pollution Abatement Project[4] (EPAP 2), currently under implementation. The original EPAP 2 loan amount is $165 million, of which the World Bank contribution is $20 million. The Second Pollution Abatement Project (EPAP 2) provides attractive loans to financially viable industrial enterprises for pollution reduction measures. The EPAP 2 investment targets pollution abatement in factories in Alexandria and in Greater Cairo, to reduce water and air pollution in these two hot spots. The specific investment relevant to the proposed GEF project are those sub-projects that directly reduce polluted effluent to Lake Mariout, namely:: (i) the Amria petroleum refining public company with a proposal to use NMP solvent instead of Phenol, (ii) the national paper private company with a proposal to supply and install second stage biological wastewater treatment plant, and (iii) the Wael Tex company with a proposal for rehabilitation of the industrial wastewater. The total contribution from the World Bank, multi- and bi-lateral development agencies for these three sub-projects amounts to $19.7 million. The Egyptian industries contribution in the three sub-projects is $14.3 million. The GEF project will use the same project management unit (PMU) as that of EPAP2 in order to maximize impact and reduce transaction costs. In particular, the Director of the PMU for EPAP II will serve as the PMU Director for the proposed GEF project thereby facilitating synergy and cross-fertilization; (iii) A procurement specialist will be hired to ensure that the GEF project PMU can continue to oversee the project implementation even after the EPAP 2 closure date of 2012.

· Government interventions: The Government of Egypt (GOE), through the Ministry of Housing, is implementing a large scale program to increase sanitation coverage in urban and rural communities throughout Egypt. Of this program, the GoE is planning to increase the capacity of the East and West Waster Water Treatment Plants in Alexandria, and to upgrade the treatment from primary to secondary level. Currently the primary treated effluent from the West Treatment Plant discharges directly to Lake Mariout, while the effluent from the East Treatment Plant reaches the Lake indirectly through Dayer-El-Matar Drain. Therefore, the GoE’s plan of upgrading these two plants to secondary treatment levels contributes directly to the development objectives of the proposed GEF project. A total budget of $611.9 million has been earmarked by the GoE for the activities of capacity expansion and upgrade of the two treatment plants. Currently, consultancy work is underway for the design of the East treatment plan upgrade, and construction is expected to start later in the year. For the West treatment plant, the tender process for the consultancy work would start mid 2009. The East and West treatment plants are expected to be operational in 2011 and 2012, respectively.

The GEF project would treat more diffuse pollution coming from agricultural drainage water and rural domestic wastewater; support the development of sustainable and integrated coastal zone management, and use reliable biotechnology such as engineered wetlands.

The project will also build on the Alexandria Lake Mariout Integrated Management project (ALAMIM) funded under the EU SMAP III (Short and Medium term priority environmental Action Programme) and implemented by CEDARE which aims to promote the integrated development of the Lake Mariout. The activities of the ALAMIM project, expected to be completed in mid-2009, will be used during the GEF funded project.

Therefore, the proposed GEF project together with other interventions provides a critical mass of investments to promote higher political visibility of the pollution reduction measures and benefits.

E. Discuss the value-added of GEF involvement in the project demonstrated through incremental reasoning : In the absence of GEF involvement under the baseline scenario, the planning and use of coastal zones in Egypt would be addressed without particular attention to (i) an eco-system and integrated approach to coastal zone management and protection of downstream water bodies or (ii) to innovative collaborative models to reduce more diffuse land-based sources of pollution entering the Mediterranean Sea. Rather, coastal zone management would be dealt with in an ad-hoc manner with no consideration of the linkages between development and sustainable management of natural resources, policy and institutional reforms and with no strategy for up-scaling or replication.

Implementation of the Baseline scenario would result in:

· Development of a new national strategy for CZM with limited concrete implementation measures for Alexandria area and limited mainstreaming of coastal zones management considerations in urban planning at local level. Continued fragmented approach to coastal zone management in and around Alexandria area;

· A Coastal Zone Management Strategy being developed but incorporation of biodiversity conservation and ecosystem issues with consideration for downstream pollution is limited;

· On-going infrastructure investments mainly target industrial and municipal wastewater through conventional treatment plants. Very limited investments specifically targeting more diffuse upstream agricultural drainage water and rural domestic wastewater;

· Monitoring and evaluation systems established that do not incorporate indicators of biodiversity conservation (fisheries, etc…);

· Capacity to monitor water quality in and around Alexandria on a regular basis area is limited; and

· Limited involvement and participation of local communities and relevant stakeholders in addressing coastal zone management.

Total expenditures under the Baseline scenario are estimated at US$647,003,293 million with contributions from the Government of Egypt, the World Bank, the EU, the EIB, the AFD, and Egyptian industries located in Alexandria. Specifically, the baseline scenario includes (i) the upgrading of the West and East urban and municipal wastewater treatment plants by the GoE in the cost of US$611,111,111, (ii) the EPAP2 project which addresses industrial pollution in the amount of US$19,720,000 and (iii) the financing by Egyptian industries of their effluent treatment costs of up to US$14,380,000.

With support from the GEF, an expanded program would focus on mobilizing and empowering relevant stakeholders at national and local levels to develop and adopt a sustainable institutional and policy framework for coastal zone management in Egypt and test innovative management and financing approach to reduce coastal degradation in Lake Mariout and surrounding areas. The GEF alternative would build a coalition of support among various entities around coastal zone management, support the mainstreaming of environment protection including CZM into land use planning for the city of Alexandria, including Lake Mariout, through policy and institutional reforms, and mobilize support for innovative and collaborative financing mechanisms of pollution reduction measures. In spite of various abuses, Lake Mariout still proves today to be of first importance for the environmental balance of the whole region and provides significant pollution abatement before discharging into the El Mex bay. The Project is expected to yield local environmental benefits through the polishing of the water discharged into the Lake thereby restoring the Lake self-cleaning capacity as well as regional and global environment benefits through the reduction of trans-boundary pollution entering the Mediterranean in the El Mex Bay and Alexandria region.

Under the GEF Alternative Scenario, Egypt will be able to improve the management and conservation of coastal zones areas through targeted low-cost investments, strengthening planning, decision-making process and institutions at national and local levels with the mainstreaming of integrated coastal zone management considerations in development plans and the use of effective water quality monitoring instruments. The GEF alternative to treat more diffuse and up-stream sources of pollution (i.e. agricultural and rural wastewater) through low-cost and innovative interventions is estimated to be US$654,153,293.

Therefore, the incremental cost for the project is estimated at US$7,150,000 to develop a sustainable and integrated approach to the protection of the coastal zones in El-Mex Bay and Alexandria including Lake Mariout.

F. Indicate risks, including climate change risks, that might prevent the project objective(s) from being achieved and outline risk management measures:

G. explain how cost-effectiveness is reflected in the project design: The design of the project is considered the most cost-effective in comparison to the following alternatives:

(a) A wastewater treatment for the tanneries complex in El-Mex bay has been considered. Although the treatment plant would reduce the load of chromium, TSS and COD which enters El-Mex Bay, this alternative was discounted because it does not address the removal of nutrients, source of the eutrophication problem in the Lake and the Mediterranean Sea. On the contrary, the engineered wetland is the only project allowing the removal of nutrients.

(b) The option of diverting part of the primary wastewater from the West Treatment Plant currently being discharged to the basin, through reusing the water for landscaping, has also been considered. Although this would significantly reduce the load of urban domestic waste pollution that enters the Lake, it will not address the removal of nutrients, essentially originating from agricultural drainage water as well as rural wastewater.

part iII: explain the alignment of project design with the original PIF: The project design remains fully consistent with the original PIF.

part Iv: Agency(ies) certification

This request has been prepared in accordance with GEF policies and procedures and meets the GEF criteria for CEO Endorsement.

Agency Coordinator, Agency name	Signature	Date (Month, day, year)	Project Contact Person	Telephone	Email Address
Steve Gorman GEF Executive Coordinator The World Bank		December 17, 2009	Kanta Kumari Rigaud	202 473 4269	kkumari@world bank.org

Annex A: Project Results Framework

The project will adopt monitoring indicators consistent with the Investment Fund for the Mediterranean Sea Large Marine Ecosystem; and will comply with the GEF Waters requirements for monitoring project progress and results (the International Waters Tracking Tool).

Annex B: Responses to Project Reviews (from GEF Secretariat and GEF Agencies, and Responses to Comments from Council at work program inclusion and the Convention Secretariat and STAP at PIF)

Introduction

The STAP reviewer comments are generally highly supportive of the project objectives and design and note that the project overall is scientifically and technically sound. The reviewer draws attention primarily to issues of conflict resolution mechanisms between the fishermen community and proponents of land-based activities around the Lake. The STAP reviewer report has been received by the Bank in February 2009. Following is a summary of the key comments and the team’s replies. The PAD has been revised to address the comments, as needed.

Key Issues

Key Issue 1: Scientific and technical soundness of the project

1. Comment: The project proposes to develop monitoring and evaluation instruments that should help to ensure that the results of the project are implemented in a sustainable manner. While focused on the project-related elements, a practicable monitoring system should be expanded in scope to ensure timely and appropriate feedback to regulatory authorities tasked with ensuring compliance with the environmental quality standards and requirements adopted by the various governmental units having jurisdiction in the coastal zone. Ensuring that communities, the private sector, and governmental bodies participate in this monitoring process will be critical to ensuring sustainability.

Response: A participatory monitoring and evaluation mechanism has been developed and is reflected in project design. A social specialist will be hired by the EEAA to ensure a participatory approach to M&E and to monitor the implementation of the social mitigation measures as part of the site-specific ESMP. Regular consultations with stakeholders will take place including for the preparation of the ICZM Plan and data on water quality collected through the M&E system will be publicly disclosed following the example of the PROPER approach under the EPAP II,

2. Comment: Box 1 of Annex 9 and Figure A9-1 suggest a complicated relationship between fish catches over time. Catches appear to be highly variable and therefore there is a need to clarify the linkages between fish catch and the many factors that can modify fish catch. Such knowledge would be fundamental to the choice of water quality management measures considered for implementation. For example, there is a need to develop an understanding of the relationship between nutrient load and fish catch and fish species composition, between fishing effort and fishing gear types and fish catch and between a decrease in lake surface level and fish catch.

Response. It is clear that identifying the causes of the decline in the fish catch is important for the choice of water quality management measures. However, the available data do not allow to carry out this type of analysis. We can only assume that sufficient improvements in water quality through the reduction of COD, BOD, nutrient load, and heavy metals would increase both the fish catch and its quality for consumption. With regards to heavy metals, duckweed is proposed to be used as the flora medium for the in-lake wetland in the main basin of Lake mariout and is known to bio-concentrate heavy metals. However, the potential removal of heavy metals could not be ascertained until a final design of this component is completed during project implementation.

3. Comment: Notwithstanding, the issue of elevated heavy metals levels in the fish catches is clearly linked to human activities, and is a cause for concern. These discharges should be addressed through the complementary industrial pollution control measures being implemented in the tributary area under the associated investment programs.

Response: The proposed project is partially blended with the EPAP II which targets pollution abatement in factories in Alexandria and in Greater Cairo, to reduce water and air pollution in these two hot spots. The specific investment relevant to the proposed GEF project are those sub-projects that directly reduce polluted effluent to Lake Mariout, namely:(i) the Amria petroleum refining public company with a proposal to use NMP solvent instead of Phenol, (ii) the national paper private company with a proposal to supply and install second stage biological wastewater treatment plant, and (iii) the Wael Tex company with a proposal for rehabilitation of the industrial wastewater.

4. Comment: The PAD documents a conflict between the fishing community and other sectors of the community desirous of implementing land-based developments, and hints at the loss of surface area of Lake Mariout as a direct consequence of development of land-based activities in this coastal zone. The project, as currently conceived, does not seem to offer a mechanism to address this particular conflict. The institutional and implementation arrangements explicitly include the fishing community and government, but do not necessarily include the other sectors, including agriculture, that appear to be contributing a substantial portion of the contaminant loads and occupying the surrounding landscape.

Response: The team recognizes that the added value of the GEF project essentially resides in the fact that it offers a platform where different and competing interests can be brought together and reconciled either through the preparation of a CZM plan or through small scale pilot pollution reduction measures. Several steps to address conflict resolution issues will be taken and include regular multi-stakeholder consultations, the review and monitoring of the social and environmental safeguards of the project and a communication strategy to raise awareness and provide feedback on project implementation. In addition, participation of the Lake Mariout Committee, a sort of fishermen committee, in the Project Steering Committee will ensure that the interests of the fishermen are adequately represented. With regards to agriculture, linkages and synergies between the GEF project and the Bank’s Integrated Sanitation and Sewerage Infrastructure Project will be established through sharing of information during the design of the pollution reduction interventions and dissemination of results and lessons learned in particular for the in-drain treatments.

Key issue 2. Identification of global environmental benefits and/or drawbacks of the project, and consistency with the goals of the GEF.

5. Comment: The threat of ongoing degradation of the aquatic environment as the result of wastewater discharges from urban, industrial, and agricultural development includes both water quality degradation and public health impacts related to the spread of waterborne diseases. Waterborne diseases remain the single greatest cause of infant mortality, despite significant improvements in water supply and sanitation. If unchecked, discharges from these human land-based activities will continue to threaten the globally significant ecosystems of the Mediterranean Sea. Consequently, true global benefit is presumed as a result of the ultimate connection of the Mediterranean Sea to the Atlantic Ocean.

The project is consistent with the goals and objectives of OP 10,[6] contributing to the global effort to address priority environmental concerns arising from land use practices and land-based activities, in this case focusing on the management of pollution from metropolitan areas, coastal industries, and watershed-based agricultural activities. The project complements related initiatives being conducted under the auspices of the GEF Strategic Partnerships for the Mediterranean Sea Large Marine Ecosystem Program and the World Bank Second Egypt Pollution Abatement Project.

In this regard, the participation of the relevant governmental organizations with responsibility for land use management, wastewater treatment, and agriculture is an important element in ensuring the implementation of the project outcomes. This participation is provided through the relevant national, governorate, and municipal government agencies, including the Egyptian Environmental Affairs Agency, Ministry of Housing, Utilities and Urban Development, General Organization of Physical Planning, and relevant local governments. Establishment of a functional operational strategy between and amongst these multiple agencies, as proposed in the project document, will contribute to achieving this objective. It also is important to note that the inclusion of industry and other nongovernmental organizations (NGOs) in the project steering committee. This latter involvement is crucial to the sustainability of remedial measures.

Response: The GEF project value added is based on the promotion of a strong participatory process in the adoption of sound ICZM practices. In that respect, representatives of NGOs and industries will be invited to participate in public consultations during the preparation of the ICZM plan. Although coastal industries are not directly part of the Project Steering Committee given that the project intends to address non-point source of pollution coming from agriculture and rural wastewater, the EPAP II will provide a basis for their involvement as the two projects are partially blended. In particular, following the example of the PROPER pilot approach (Program for Pollution Control, Evaluation and Rating) in the EPAP II, the public disclosure of water quality data as a result of the GEF project interventions will provide a strong incentive for these industries and others to comply with environmental regulations.

Key issue 3. Regional context

6. Comment: While the project is centered on the Lake Mariout, the connection of these waters to the Mediterranean Sea and, ultimately to the Atlantic Ocean argues that adequate and appropriate consideration has been given to the regional context of the project. Actions proposed to better integrate the national regulatory initiatives within a regional program are fully consistent with the development of a sustainable regional approach to managing these waters. To this end, the Mediterranean Sea Regional Seas Program and the associated GEF-WB-United Nations Environment Programme (UNEP) Strategic Partnership for the Mediterranean Sea Large Marine Ecosystem provides an important context for this project, as well as a vehicle for disseminating best practices more widely within the region. This Partnership and related investment programs documented in the PAD ensure a coherent and appropriate regional context for this project. Further, actions are proposed within the project to strengthen the national regulatory programs and institutions. This will encourage and facilitate replication of the project outcomes elsewhere in Egypt. The proposal clearly indicates an intention to disseminate information and results on both a regional and global basis.

Response: Consultations and participatory in dissemination activities from project interventions and results have been included in the project design, in particular participation in the GEF IW-LEARN programs and conferences, preparation of experience notes and the set-up of a website capturing project outcomes and main achievements according to the GEF IW-LEARN standards.

7. Comment: It is noted that the project area contributes more than one-third of the measured biochemical oxygen demand (BOD) and chemical oxygen demand (COD) in the area. Although it is not clear from this statement whether the area referred to is the entirety of the Mediterranean Sea of the Alexandria coastal zone, any efforts to mitigate the discharge of oxygen consuming substances into the Alexandria coastal zone should have significant benefit for the coastal marine ecosystem, and ultimately for the Mediterranean Sea as a whole.

Response: The pollution emptying in the El-Mex Bay and originating from the Lake Mariout contributes more than one-third of the measured BOD and COD in the Alexandria area. Although the primary impact of the land-based pollution is in El-Mex Bay, the mixing process would also result in a positive impact on the adjacent Mediterranean water.

Key Issue 4. Replicability

8. Comment: The implementation of the project clearly contributes to the potential for replication of beneficial practices and techniques—including engineering practices for the management of instream water quality and intergovernmental coordination measures. Further, the inclusion of mechanisms for disseminating information and results achieved fosters replication of effective and successful measures throughout the Mediterranean region.

Response: A Replication Strategy will be developed and will rely on data provided by the water monitoring system which will be put in place as part of the project interventions. Other communications tools will also be used to disseminate results such as a website and publications. A Communications Specialist will be recruited as part of the Project technical assistance and a report capturing outcomes and “lessons learned” will be prepared and published at the end of the project.

Key issue 5. Sustainability of the project.

9. Comment: The PAD indicates that a significant element of the sustainability of the project rests upon the ability of the project team to overcome barriers relating to competing economic activities, especially between land-based and fisheries-based activities; a weak regulatory regime and institutional structure; and, low levels of community awareness and involvement, exacerbating the sectoral competition for land and water resources. Even with respect to the aquatic resources, the PAD documents weak coalitions. For example, the shared interests of lake front property owners, recreational users, and fishers would seem to form the basis for joint action to promote good water quality and a healthy lake ecosystem; however, such coalitions do not seem to exist. The closest approximation to such a coalition would appear to be the provision of assistance by the Friends of the Environment to the fishing community in seeking enforcement of pollution control regulations (directed toward halting reclamation of shorelands). In other respects, there seems to be significant divergence of goals, with the momentum on the side of the argument for continued lake degradation to benefit land-based activities. This particular barrier will have to be addressed within the project, if the project is to have any chance of successfully reducing water pollution and sustaining the coastal fishery.

Response: A strategic plan for the city of Alexandria will be prepared by the General Organization for Physical Planning (GOPP) under the Ministry of Housing during project implementation and will address issues related to land-based activities. In that context, a strategic environment assessment (SEA) for the development of the land around the Lake and Wadi (Valley) Mariout will be developed. Furthermore, the drafting of the Alexandria CZM plan as part of the GEF project will be closely coordinated with the preparation of the Strategic Plan for Alexandria by the GOPP.

10. Comment: The commitment of the Government of Egypt to support the project activities provides some assurance that the project results will be continued beyond the immediate period of project implementation with GEF support. However, the demise of the National Committee for Coastal Zone Management, noted as having been “reinstated” pursuant to Prime Ministerial Decree No. 266 of 2007, does indicate a significant degree of risk.

Response: Significant steps have been taken by EEAA since 2007 testifying to the continued commitment of the Government of Egypt towards sustainable coastal zone management. The revisions of Law 4/1994 for the environment (as amended by Law 9 for the year 2009[7]), include articles defining the coastal zones (Art.39) and the Integrated coastal zone management (Art.40 & Art.48), and articles that assign to EEAA the role of preparing a National Strategy for ICZM (Art.5) to ensure sustainable development of coastal area. The revised law also assigned to the Minister of State for Environment, the role of coordination with the relevant agencies/stakeholders to achieve the [water protection] objectives, as well as the objectives of the integrated coastal zone management. In early 2009, a series of workshops have been held to discuss the main components of a Draft National Strategy for Integrated Coastal Zone Management (Vision, Objectives and Priorities) under the auspices of the National Committee for ICZM. In addition, the executive regulations of the revised law (pending) are expected to establish a Governorate level Coastal Zone Management (CZM) Committee.

11. Comment: The project proposes to address a key element of sustainability through the strengthening of appropriate governmental units. The development of a trained cadre of individuals, the establishment of coordination mechanisms among the appropriate institutions, and the promulgation of the necessary enabling legislation are essential elements of the proposed project. To this end, the constitution of the project management unit (PMU) will be a critical element in ensuring the sustainability of the project outcomes. The composition of the project steering committee (PSC), likewise, will be a crucial element in ensuring dissemination of the project outputs and implementation/replication of project outcomes elsewhere in the coastal zone. It will be vitally important that inter-governmental coordinating mechanisms established for the project (under the auspices of the PSC?) be continued beyond the conclusion of the GEF-funded interventions in order to avoid a return to the sectoral conflicts and environmental degradation that has led to this project.

Response: Drawing from the experience of other GEF projects on CZM, special attention has been paid to participatory and monitoring aspects in the project design with the hiring of a communications, social and M&E specialists as part of the project TA. An institutional structure under the leadership of the EEAA will be put in place towards the end of the project to implement and monitor the implementation of the ICZM plans.

12. Comment: The implementation arrangements and institutional responsibilities (Annex 6) and procurement arrangements (Annex 8) provide some degree of assurance of effective project execution, although the financial management and disbursement arrangements remained to be completed at the time of the STAP review. These measures, combined with the monitoring and evaluation protocols adopted for the project set forth in Annexes 3, 10 and 11, would seem to adequately address these concerns, although the project supervision arrangements were not articulated to any degree in Annex 11. These areas should be addressed prior to project initiation.

Response: Arrangements on procurement, implementation and M&E have been developed in close collaboration with the EEAA during project preparation.

Key issue 6. Targeted Research Projects.

13. Comment: Targeted technical demonstration and capacity building projects are key features envisioned within the GEF International Waters Contaminant-based Operational Program. While not specifically articulated in the PAD, the development and pilot scale implementation of biofilm and instream wetland technologies are included as major elements of this proposed project (Annex 4). To this end, it is important that the demonstration projects be monitored and the results reported, using the information dissemination mechanisms previously identified, beyond the project period. Such continuity is totally consistent with the catalytic nature of the GEF, and an essential element to the sustainability of the project. Capacity building and institutional strengthening, envisioned in the PAD, thus become the basic building blocks upon which this project will succeed or fail, both from the point of view of its sustainability and from its scientific and technical integrity.

Response: Capacity-building and institutional strengthening activities have been built in project design and will be launched as soon as the project is initiated, including training on CZM practices, stakeholder consultations and coalition-building, participatory M&E system, study tour, and participation of the National Committee on ICZM as a scientific and advisory body.

Secondary Issues

Secondary issue 1. Linkage to other focal areas.

14. Comment: This project is formulated as an International Waters project under OP 10 of the GEF Operational Strategy. No specific cross-cutting areas have been identified, although land degradation and hazardous waste management (POPs) are identified as key environmental issues faced by Egypt. The in-stream remedial measures to be implemented as pilot demonstration projects will address elements of the latter issue, while the strategies developed for inclusion in the coastal zone management plan must take the former into account if they are to be truly effective in moderating the current state of affairs.

Response: As part of the CZM master plan, a series of plans will be developed, addressing challenges related to shoreline management; land use; water quality monitoring and climate change/hazardous impact assessment. The issues of land degradation and hazardous waste management (POPs) will be reviewed during the preparation of the plans.

Secondary issue 2. Linkages to other proposals.

15. Comment: The project recognizes the complementarities between the management of Lake Mariout coastal zone, under the auspices of the Mediterranean Sea Large Marine Ecosystem Project, and other ongoing initiatives, including the WB Egypt Pollution Abatement Projects and other bilateral and multilateral initiatives. The inclusion of the GEF-financed activities within the implementation arrangements under the Strategic Partnership for the Mediterranean Sea Large Marine Ecosystem Program provides specific linkages with regional seas projects and related environmental and economic development projects being conducted in the Egyptian coast zone (as enumerated in section III.A. of the PAD).

In addition, it is recommended that the project make use of IW-LEARN and related mechanisms for dissemination of the project outcomes and outputs. Such an overt linkage provides a high degree of sustainability and connectivity to this project, and contributes to the likelihood that lessons learned can and will be transferred beyond the project boundaries to other, similar situations and locations within the Mediterranean Sea region and beyond.

Response: The project will build on the experiences accumulated by the National Water Resources Center (NWRC), and its Drainage Research Institute about the use and replication of low-cost mechanisms to improve water quality in the agriculture drains. Options to extend the technology for treatment of domestic sewage in the villages located on the fringes of the Delta where land is more readily available will be assessed. Please see response to comment 6 above about dissemination of the project outcomes.

Secondary issue 3. Other beneficial or damaging environmental effects.

16. Comment: The project has no known or obvious damaging environmental impacts associated with the activities proposed to be executed. The beneficial impacts of the project have been articulated and include the implementation of targeted interventions that address diffuse land-based sources of pollution of the aquatic environment. The provision of trained staff and institutional capacities needed to enforce and enhance existing environmental protection regulations, and the dissemination of successful management measures further contribute to the benefit of this region. Nevertheless, the creation of specific mechanisms to address cross-sectoral resource conflicts—associated with land-based developments, shore land reclamation, and loss of aquatic habitat—has not been fully articulated and remains a significant risk, as indicated in the critical risks matrix.

Response: Please see response above to comment 4.

Secondary issue 4. Degree of involvement of stakeholders in the project.

17. Comment: The project involves some of the stakeholders, including fishermen and governmental agencies. The project explicitly indicates support for capacity building and institutional strengthening with respect to governmental organizations. Unfortunately, a mechanism for including proponents of land-based activities, that affect the shoreward areas of the coastal zone and contribute to the filling of Lake Mariout, are not stated, and introduce a significant risk into the project as has been noted in the critical risks matrix. The involvement of all stakeholders in the development of a strategy for the management of the coastal zone and its resources is critical to the sustainability of the project.

Response: Although the project is expected to have positive impact on the livelihood of the fishermen community on the long-run, pollution from industries located close to the Lake and pressures from proponents of land-based activities will remain a challenge. To address this, a comprehensive strategy for stakeholders’ involvement will be elaborated including regular consultations and development of a communication strategy. In addition, encouraging synergies with other Bank projects in Egypt such as the Integrated Sanitation and Sewerage Infrastructure Project (ISSIP) and building relationships with the NOPWASD will create an opportunity to leverage government support and participation of all stakeholders in the project.

Secondary issue 5. Capacity building aspects.

18. Comment: Capacity building is a critical element of the proposed project. Creation and strengthening of the appropriate institutions, conduct of the demonstration projects, and the training of agency staff form the core of the GEF-financed elements of the Project. Annex 4 briefly introduces these issues as part of the proposed stakeholder involvement process and monitoring and evaluation (M&E) process. Further elaboration of these mechanisms is noted to be an element to be completed during project appraisal. As noted above, this element should be implemented in conjunction with the best practices data base of IW-LEARN to enable wider dissemination of practices that have positive effects beyond the project area. Such knowledge is an essential element in building capacity and strengthening institutions in the region and beyond.

Response: Beyond a technically focused team, special expertise in the field of communications, stakeholder outreach, community development and institutional strengthening will be hired under the project technical assistance building on lessons learned from other GEF projects in Egypt, including the Lake Manzala UNDP-GEF project. A communications specialist and M&E specialist will be hired by the project to raise public awareness and generate consensus on sustainable coastal zone management and project interventions if broader social and institutional goals are to be achieved.

Secondary issue 6. Innovativeness.

19. Comment: Development of appropriate practices for the management of coastal lakes and the coastal zone is a critical element for the protection of the marine environment, within the context of an integrated land- and water-based management program. By creating and strengthening the appropriate human resources and institutions, creating inter-institutional coordination and cooperation mechanisms, and developing appropriate remedial technologies, such as the in-stream biofilm reactors, the proposed program will complement other pollution abatement practices being implemented by the basin governments and stakeholders. In particular, the development of the biofilm reactors under the rigorous conditions present in the Lake Mariout area will provide an important new tool for replication in other drainage areas where diffuse source pollution is a major concern and where site-specific remedies are not practicable. The proposed actions and approaches reflect state-of-the-art practices. Their application to Lake Mariout, and the near shore areas of the Mediterranean Sea, will significantly advance current environmental management practices in the Metropolitan Alexandria region, as well as within the Mediterranean Sea region as a whole. In this manner, the project promotes innovation and development of regionally applicable remedial practices and experiences.

Response: To treat the more diffuse land-based sources of pollution entering Lake Mariout, the project proposes to use in-stream treatment (for example bio-films), which introduces a dynamic, modular and easily manageable technique mechanism. The in-stream treatment, although relatively new in Egypt, has been used successfully by the MWRI as a pilot and has been recommended for broader application elsewhere in the country by other agencies. As part of the package proposal, the synergetic effect of the in-stream bio-film and the in-stream aeration will give the in-lake engineered wetland a medium water quality permitting the latter to initiate its own ecological cycle that will permit the cultivation of duckweeds. The duckweeds will in turn absorb the nutritive salts and oxygenate the effluent and the sale of the duckweeds will cover the running cost of the aeration. The project thus proposes innovative integrated and natural process based options such as wetlands which are used as nutrient traps to treat more diffuse pollution load coming from upper parts of the water catchment where conventional treatment solutions are not feasible. Feasibility studies and detailed design will be done in the course of Project implementation, following detailed field surveys and investigations, for which provisions have been made under the Project.

Annex c: consultants to be hired for the project using gef resources

Position Titles	$/ person week*	Estimated person weeks**	Tasks to be performed
For Project Management
Local
Procurement specialist (2)	1750	5	Oversee all aspects of procurement process for contracts financed by the project
Social Specialist (2)	1750	5	Monitor implementation of social mitigation measures
M&E Specialist (2)	1750	8	Prepare progress reports against agreed indicators
Communications Specialist (2)	1750	33	Draft communication and replication strategy and dissemination materials
International
Procurement specialist 1	3000	7	Provide support to the PMU
Social Specialist 1	3000	6.5	Provide support to the PMU
M&E Specialist 1	3000	6.5	Provide support to the PMU
Communications Specialist 1	3000	31.5	Provide support to the PMU
Justification for Travel, if any: The procurement specialist will attend a procurement skills building workshop in the region (estimated $6000 for 2 weeks).
For Technical Assistance
Local
Facilitator/Trainer (3)	1750	40	Facilitate public consultations on CZM plan; train staff of public agencies
Technical Specialist for feasibility studies (2)	1750	20	Conduct feasibility studies for small scale & innovative investments of component 2
International
Facilitator/Trainer (3)	3000	13	Provide technical support to local trainer/facilitator
Technical Specialist for feasibility studies (2)	3000	13.5	Provide technical support/reviews to feasibility studies
Justification for Travel, if any:

* Provide dollar rate per person week. ** Total person weeks needed to carry out the tasks.

Annex d: status of implementation of project preparation activities and the use of funds

1. explain if the ppg objective has been achieved through the ppg activities undertaken. Yes
2. describe findings that might affect the project design or any concerns on project implementation, if any: N/A

3. provide detailed funding amount of the ppg activities and their implementation status in the table below:

Project Preparation Activities Approved	Implementation Status	GEF Amount (€)				Co-financing ($)
		Amount Approved	Amount Spent Todate	Amount Committed	Uncommitted Amount*
Inception Report	Completed	37050 €	37050 €	37050 €
Strategic Environmental Assessment for the Alexandria Coastal/Lake Zone and Environmental Improvement Master Plan	Completed	49499€	49499€	49499€
Pre-feasibility Studies for Demonstration Projects.	Completed	49499€	49499€	49499€
•Report on the Baseline conditions in the Lake, •Proposal for a Water Monitoring Network, •Specifications for Preliminary El Mex Bay and Lake Mariout Circulation model	Completed	49499€	49499€	49499€
•Monitoring & Evaluation Plan, including indicators for the full project •Co-financing strategy for the full GEF project •GEF Project Document suitable for GEF and World Bank appraisal	Completed	61750 €	61750 €	61750 €
Environmental and Social Impact Assessment Framework (ESIAF) and a Resettlement Policy Framework (RPF) of Alexandria Integrated Coastal Zone Management Project	Completed					20000
EGYPTIAN CONTRIBUTION FOR AICZM PROJECT (In-kind), including Staff costs , Office space and Maintenance and consumables/utilities, furniture, and computers	Completed					63207
Total		247000€	247000€	247000€		83207

* Any uncommitted amounts should be returned to the GEF Trust Fund. This is not a physical transfer of money, but achieved through reporting and netting out from disbursement request to Trustee. Please indicate expected date of refund transaction to Trustee.

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