Zeila-Asha Addo Road (22km)

Mar 05, 2025

GOVERNMENT OF SOMALILAND

MINISTRY OF TRANSPORT AND ROADS DEVELOPMENT AGENCY

Consultancy services for the feasibility study preliminary and detailed Engineering design, Environmental and social Impact Assessment (ESIA) and preparation of Tender documents for upgrading of

Zeila-Asha Addo Road (22km)

Ref No.: S/L/RDA/LFBR/SVS/2019-10/002

SAP Code P-SO-DB0-007

RESETTLMENT ACTION PLAN (Final)

March 2025

Contents

EXECUTIVE SUMMARY. 8

1 GENERAL OVERVIEW.. 32

1.1 Introduction. 32

1.2 Project Description. 32

1.3 Objectives of the resettlement action plan. 33

1.4. AfDB Guideline on Involuntary Resettlement. 34

1.4. Scope of the Study. 34

1.5. Methodology. 34

1.5.1. Literature Review. 35

1.5.2. Socio-Economic Survey. 36

1.5.3. Stakeholders Consultation. 37

2. LEGAL FRAMEWORK. 38

2.1 National Legal Frame work. 38

2.1.1 Government of Somaliland Constitution. 38

2.2.2 Legislative framework. 39

2.2 The African Development Bank Policy and Procedures. 40

2.2.1 The Integrated Safeguards Systems (ISS) of the AfDB, 2013. 40

2.2.2 Environmental and Social Assessment Procedures, November 2015. 43

2.2.3 African Development Bank’s Safeguard Policy and guidelines Involuntary Resettlement Policy, 2003. 44

2.2.4 AfDB Gender Policy. 47

2.3.5 Bank Group Policy on Poverty Reduction. 49

2.3.6 AfDB Disclosure and Access to Information. 50

2.3.7 Handbook on Stakeholders Consultations and participation on AfDB Funded Projects. 51

3. POTENTIAL IMPACTS AND MITIGATION MEASURES. 52

3.1 Project Affected Persons. 52

3.2 Loss on incomes and Economic Livelihoods. 52

3.3 Loss on Houses. 52

3.4 Loss of structures. 53

3.5 Impact on vulnerable groups. 54

3.7 Impact on Public Social services. 54

3.8. Impact Due To the Construction of Workers’ Camps. 55

3.9. Impacts on Air, Noise, and Dust Pollution. 56

4. RAP Implementation Process. 58

4.1. Notification. 59

4.2. Verification of properties of PAPs and losses. 59

4.3. Compensation and resettlement. 59

4.4. Preparation for clearance of the road corridor. 60

4.5. Membership and responsibility of Resettlement Committee. 60

4.6. Organization Structure for RAP Implementation. 61

4.7. Resettlement Committee. 61

4.8. Implementation Schedule. 61

5. PUBLIC AND STAKEHOLDERS CONSULTATIONS AND COMMUNICATION. 63

5.1. Consultation and community participation. 63

5.2. Objectives of Consultations. 63

5.3. Consultation Strategies. 64

5.4. Public Disclosure. 66

5.5 Public Consultation. 66

5.6 The Consultation Process. 67

5.7. Consultation Processes and Outputs. 67

5.8. Summery Consultation Outputs. 69

5.9. Summary of Consultations. 71

5.10. Stakeholder Consultations. 72

5.11. Public Consultations. 73

5.12. Information Dissemination. 74

6. Grievances Redress Mechanism. 75

6.1. Need for Grievance Redress. 75

6.2. Types of Grievances. 76

6.3. Sources of Grievances. 76

6.4. Grievance Management Approach. 77

6.5. Grievance Redress Mechanism. 78

6.6. Dispute procedure. 81

6.7. Role of PAP’s Representatives in Grievance Redress Committee. 83

7. Socio-Economic Condition of the Project Area and Project Socio Affected Persons. 84

7.1. Background. 84

7.2. Administrative Setting. 84

7.3. Population and Demography. 84

7.4. Economic Activities and Livelihood. 85

7.5. Income Distribution. 86

7.6. Social Services and Infrastructures. 86

7.7. Transportation. 87

7.8. Telecommunication. 87

7.9. Water Infrastructure. 87

7.10. Health. 88

7.11. Education. 89

8. ORGANIZATIONAL AND INSTITUTIONAL RESPONSIBILITY. 90

8.1. Ministry of Transport and Road Development. 90

8.2. Ministry of Public Works, Land and Housing. 90

8.3. Awdal and Salal Regional Governments. 90

8.4. District/Town administration units. 90

9. ELIGIBILITY CRITERIA AND ENTITLEMNT MATRIX. 92

9.1. Overview.. 92

9.2. Eligibility Criteria. 93

9.3. Project Affected Persons (PAPs) 94

9.4. Project Affected Families (PAFs) 94

9.5. Displaced Family. 94

9.6. Squatters. 94

9.7. Vulnerable Groups. 95

9.8. Entitlements for the PAPs. 95

9.9. Cut Off Date. 96

10. VALUATION AND COMPENSATION FOR LOSSES. 97

10.1 Methodology in Valuing Losses. 97

10.2 Basis for Valuation. 98

10.3. Valution for Loss of Houses. 98

10.5. Valuation for Public Utility Lines. 99

10.6. Income and livelihood restoration. 99

10.6. Livelihood Compensation Plan. 101

10.7. Special Assistance for Vulnerable Project Affected Persons. 102

11. RESETTLEMENT AND INTEGRATION WITH HOST COMMUNITIES. 103

11.1. Resettlement Sites. 103

11.2. Host Communities. 103

12. COSTS AND BUDGET. 104

12.1. Cost of Compensation and Resettlement. 104

13. MONITORING AND EVALUATION. 106

13.1. General. 106

13.2. Social and Environmental Management Plan. 107

13.3. Construction Phase. 107

13.4. Operation Phase. 108

13.5. Cost for Environmental and Social Mitigation. 109

13.6. Performance monitoring. 109

13.7. Impact Monitoring. 109

13.8. Internal Monitoring. 110

13.7 Monitoring Indicators. 110

13.9. External Evaluation. 111

14. CONCLUSIONS AND RECOMENDATIONS. 113

14.1. Conclusions. 113

14.2. Recommendations. 113

ANNEX I-List of Project Affected Persons. 114

ANNEX II-Minutes of Meetings. 115

List of Tables

Table 0‑1:- Entitlement Matrix. 16

Table 0‑2: RAP Implementation Schedule. 19

Table 0‑3 The total affected assets with the corresponding compensation cost 22

Table 3‑1: Impacts on Social Services and Utilities. 54

Table 3‑2:- Summary of PAPs and types of properties and economic activities affected by the project 58

Table 4‑1: RAP Implementation Schedule. 62

Table 6‑1:- Public and Stakeholder Consultations Conducted In the Project Area. 70

Table 6‑2: Summary of concerns, issues, fears, expectations, etc. rose by the consulted participants and provided responses by the Study Team.. 71

Table 8‑1: Settlement alongside the Road Corridor 84

Table 8‑2: Distribution of sources of income of respondents. 86

Table 8‑3: Distribution of Annual income earned by responding Households. 86

Table 8‑4: Availability of Different Water Schemes alongside the project road Towns. 87

Table 8‑5: Health Facilities alongside the project road. 88

Table 8‑6: Health Professionals alongside the road project 88

Table 8‑7: Number of Schools of all category alongside the project road. 89

Table 10‑1:- Entitlement Matrix. 96

Table 12‑1 The total affected assets with the corresponding compensation cost 103

List of Figures

Figure 1‑1:- Project Location (Zeila-Asha Addo points) 33

Figure 1‑2:- Conducting Interview of PAPs @ Asha Addo village. 37

Figure 3‑1:- Potentially Affected Trade and Business centers by the road project @ Asha Addo. 52

Figure 3‑2:- Loss of Structures due to the road project @ Asha Addo. 53

Figure 3‑3:- Loss of Public structures due to the road project 55

Figure 6‑1: Consultations with Local administration @ Zeila. 70

Figure 6‑2: Consultations with Higher Level Government Stakeholders 70

Figure 7‑1: Typical Grievance Redress Procedures. 82

Acronyms/Abbrevations

ADB	Africa Development Bank
ESIA	Environmental and Social Impact Assessment
FDG	Focus Group Discussion
GRC	Grivance Redressing Mechanism
Ha	Hectare
LHS	Left Hand Side
M & E	Monitoring and Evaluation
M	Metre
m.a.s.l	Metres Above Sea Level
NGOs	None Governmental Organizations
PAP	Project Affected Persons
PAP	Project Affected People
RAP	Resettlment Action Plan
RDA	Road Development Agency
RHS	Right Hand Side
ROW	Right of Way

EXECUTIVE SUMMARY

The Government of the Republic of Somaliland, represented by the Somaliland Roads Development Agency, an implementing agency of the Ministry of Transport and Roads Development has been allocated grant from the African Development Bank towards Feasibility Studies, Environmental and Social Impact Assessment, Resettlement Action Plan (RAP), Detailed Engineering Design, Cost Estimates and Preparation of Bidding Documents for Upgrading to Paved (Bitumen) Standard of Zeila-Asha Addo Road Project.

The above mentioned road project will be part of the strategic link between Ethiopia, and Djubouti. The road is expected to solve the prevailing nationwide transportation cost, transportation efficiency and serve as strategic link between Somaliland, Ethiopia and Djibouti. The Asha Addo road project starts at Lowyaddo town, which is located in North East direction of part of the republic of Somaliland. The end point of the project is at the Borama town which is the capital of the state of the Awdal Region and it is located around 280km West of Hargeissa within the Republic of Somaliland.

PROJECT LOCATION AND DESCRIPTION

The Project Road Zeila-Asha Ado is found in Salal regions of the Republic of Somaliland. The distance between Zeila to Asha Addo is 22 Km by road. The Zeila-Asha Ado Road is an important trade road which connects Djibouti, North Somaliland, and Ethiopia with a significant regional integration and economic development potential.

From start to end, the project road crosses Zeila and Asha Addo. The geographic coordinates is start and end point of the project road are Easting 333469 Northing 1255372 and Easting 329751 and Northing 1235409 respectively, the elevation of starting point is about 0 m above sea level, while that of end of the project is about 4m above sea level. The proposed project centreline passes through flat terrain. After its completion, the upgraded road will improve the overall socio-economic aspect of the Republic of Somaliland and contribute its own share towards reducing travel time, maintenance cost and the riding quality of traffic movement along the route.

Objectives of the resettlement action plan

The main objective of the RAP for the Zeila-Asha Addo Road project is to identify and assess the impact of the project on project-affected populations and formulate a RAP consisting of all appropriate measures and strategies which are necessary to mitigate the adverse effects of the project, restore and improve the income and livelihoods of PAPs.

Methedology

The information for preparing this Resettlement Action Plan was based on primary and secondary data sources. The information collected through different methods was organized, analyzed and interpreted to come up with sound, critical and practical action plan. In this regard, the following key activities were undertaken.

Literature review: Reviewed documents include: ESIA of the Lowyaddo-Ferdha-Borama road project, Somaliland Country Report, summery report, 2016, Pastoral society of and transformational refugee: population movement in Somaliland, Augest2002, UNHCR,Somaliland food and water security strategy, Somaliland Interagency need assessment, Somaliland National policy by the land policy drafting group. ESIA document of the project road, Review the legal and other institutional framework; Awdal nutrition survey report, lughaya and zeila districts, January 2002
Socio Economic Surveys: for this a structured questionnaire was developed and applied to gather information through interviewing PAPs
Public and Stakeholder Consultations
Key informant interviews
Observation along the road corridor on characteristics of the communities to be potentially affected by the road improvement.

Identify the actual project affected persons; determine the severity and extent of the impacts. (Including assessment of the impacts on their assets, infrastructure and livelihoods etc)
Identify the poor and vulnerable groups and develop strategy to restore and sustain their livelihood;
Develop mitigation measures in consultation with the affected people;
Prepare detailed entitlement matrix and
Detail implementation plan with schedule and responsibilities;
Prepare detail resettlement budget; and
Develop Monitoring and Evaluation and reporting system for the Resettlement Plan.

POTENTIAL IMPACTS AND MITIGATION MEASURES

Loss on incomes and Economic Livelihoods

19 households will lose their businesses from which they make a living by working on or renting them to others. These households will have to have their business houses reconstructed as new, and it has to be ensured that the new areas are not far from the present ones and be equally or more accessible to their potential customers so that their business shall not be disrupted.

During consultative meetings with state and town administrators, consensus has been reached that for PAPs who lost their business centers, selection of resettlement areas shall take into account their conduciveness and proximity to markets and potential customer

Loss on Houses

In road and other infrastructure projects, impact on houses that are either used for residential or business purposes due to the widening of existing ROW or construction of new roads is a common phenomenon.

As it has been observed during the field site observation and from the land acquisition plan the road project will affect about 2429 m2 of houses, 2106m2 of sheds, 110 m2 fences, which include residential houses and business houses in Asha Addo Town Administration. Consequently, the affected households due to loss of residence and business houses will be dislocated and faced resettlement problems. The majority walls of affected houses are constructed with wooden or brickwork and their roofs are made of CIS (corrugated iron sheet).

Mitigation Measures

Compensate for lost houses (residential and commercial) as per the aw
Provide land for PAPs so that they could construct houses

Involve PAPs in the property valuation committee

Loss of structures

4 Governmental services and 40 house holds are observed to loss structurers. Out of the total 40 households, 21 households will lose their residential houses and additional 19 households will lose their business houses/commercial properties from which they make a living by working on or renting them to others. These 40 households have to be given reasonable compensation for reconstructing new houses.

Loss of social services

Social services observed along the road corridor include government institutions buildings (sheds/offices and their toilet blocks) are affected.

Impact on Public Utilities

There are no public utilities, such as, electric poles and water reservoirs, water pipe, water meter, water points, manhole, solar panel lines that will be affected due to the construction of the project road in different locations mainly in urban settlements. However, only the sheds customs offices are affected in Asha Addo.

Before the construction work commences, the above identified shades and fences of 4 governmental offices need to be removed and replaced its removal has to be discussed in advance with the concerned organizations, such as Municipalities of Asha Addo town.

Mitigation Measures

Compensate to the owners of for the social services before the commencement of the construction works and ensure that utility lines are not interrupted due to construction works.

Impact Due To the Construction of Workers’ Camps

The establishment of construction camps and residential houses for the construction workers sometimes competes with the limited local resources and services available in the area. The existence of camps for the constructions workers close to settlement areas could influence negatively on local life style and sometimes may lead to cultural and social conflicts. To avoid such type of conflicts and problems the establishment of the construction camps should be in a planned way without negatively affecting the local resources and services.

Impacts from construction camps will be created if camps are built close to the local settlement areas by creating noise pollution, competition on the use of local resources. Hence, it would be appropriate and advisable to ensure that the construction of camps and other temporary work sites do not negatively affect local communities.

Mitigation Measures

To limit such type of problems direct contacts between the local community and construction workers could be discouraged by putting up construction camps in distant locations from local people, and if the construction camp is built close to local people, admission to the camp should be limited to workers only.
The preconditions to choose the location of the construction workers camp should be more or less similar to any planned permanent settlement that is developed for residential purpose. The selection of camp sites should be done in good co-operation with Local administrations.
Construction camps should also be able to provide some services to its workers, which otherwise would overburden the local public utilities/facilities. Hence, the selection of camp sites should be done in good co-operation with the local population and administration.
Avoid creating construction camp sites on farm and grazing land or near farms.

LEGAL FRAMEWORK

National Legal Frame work

Relevant policies and legislations of the National Government of Somaliland and those of African Development Bank are discussed. This will enable implementers of the RAP to comply with the required national and AfDB policy requirements, as well as to use the policies and legislations to ensure that adequate mitigation measures are put in and to deal with any negative impacts on the project affected persons. The only available documents relevant to expropriation of land holdings and compensation for loss of properties are the Constitution of Government of Somaliland and the legislative instruments that have been adopted to govern specific sectors related to land.

Government of Somaliland Constitution

Land Tenure is not available in separate document in the Government of Soamali and it is treated under the constitution of the Country. The Constitution contains provisions related to land as a national property and establishes the state responsibility for the land and natural resources.

Article 12 says, “The land is a public property commonly owned by the nation, and the state is responsible for it12”, and shall take all possible steps to explore and exploit the natural resources which are available in the nation’s land or sea. The protection and the best means of the exploitation of these natural resources shall be determined by law.

This constitutional principle for women’s rights need to be interpreted into practice and mainstreamed into programs within the public sector delivery of services.

Legislative framework

There are several legislative instruments that have been adopted to govern specific sectors related to land. Prominent among them are the Agricultural land ownership Law No. 8/1999 and Urban land management law No. 17/2001. There are also other laws on mining, livestock, water and environment that are relevant to land governance.

Apart from the Somaliland tenure Policy and analysis of Legal Issues related to Land in Somaliland (Final Draft Report April 2016) has been reviewed as it has a number of amendments of the previous land tenure documents. According to this document Article 8 of Law No. 8/1999 provides that if agricultural land is nationalized for public use, the state has to pay compensation to the previous owner within three months. The law does not specify the remedial procedures to be followed in order to ensure fair compensation is received by the previous owners. Urban land may similarly be expropriated for public purpose subject to compensation to owners. Under Art. 1 and 6 of law No. 17, the President of Somaliland has the authority to issue decree transferring land for the public interest or town re-planning after consulting with the Cabinet and the National Urban Land Planning Committee. Public interest means the use of land for the construction of new roads, extension of existing roads, bridges, electrical and communication lines, offices and government buildings and any other reason deemed necessary. The presidential decree will be circulated through official channels. The National Land Planning Committee is responsible for the evaluation of the costs and payment of the compensation for the properties affected by the re-planning, and an owner shall also receive a plot that is equal, in terms of size and location, to the plot that is expropriated.

According to Art. 3 of Law No. 08/99, the Minister of Agriculture is responsible for the administration of agricultural land on behalf of the government, and at the same time, the Ministry issues title deeds and makes registration of farms.

On the other hand, Law No. 17/2001 established the National Urban Land Planning committee21 which is responsible for urban planning, approval of master plans and extension of towns. The Committee is comprised of six Ministries including Minsters of agriculture and rural development and the Minster of Public

The African Development Bank Policy and Procedures

The Integrated Safeguards Systems (ISS) of the AfDB, 2023

Environmental and Social sustainability is a key to economic growth and poverty reduction in Africa. The Bank’s ISS emphasizes the need to assist regional member countries in their efforts to achieve inclusive growth and transition to green growth.

In addition, the Bank is committed to ensuring the social and environmental sustainability of the projects it supports. The ISS is designed to promote the sustainability of project outcomes by protecting the environment and people from the potentially adverse impacts of projects. Minimize, mitigate, and/ or compensate for adverse impacts on the environment and affected people when avoidance is not possible; and the safeguards aim to:

Avoid adverse impacts of projects on the environment and affected people, while maximizing potential development benefits to the extent possible;

Help borrowers/clients to strengthen their safeguard systems and develop the capacity to manage environmental and social risks.

The Bank requires that borrowers/ clients comply with these safeguards’ requirements during project preparation and implementation. The Integrated Safeguards system sets out the basic tenets that guide and underpin the Bank’s approach to environmental safeguards.

In addition, the Bank has adopted ten OSs required to achieve the goals and optimal functioning of the ISS. Given the proposed project nature and scope, most OSs are triggered with the most relevant being OS1 and OS5, that are directly related to Involuntary Resettlement Land Acquisition and Social impacts are discussed in the below section.

Operational Safeguard 1 (OS 1): Assessment and Management of Environmental and Social Risk and Impact

This overarching safeguard governs the process of determining a project’s environmental and social Category and the resulting environmental and social assessment requirements. The objectives of this Operational Safeguard (OS 1) are to identify and assess the environmental and social impacts and climate change vulnerability issues of Bank lending and grant financed operations in their area of influence; avoid or if not possible minimize, mitigate and compensate for adverse impacts on the environment and on affected communities; and ensure that affected communities have timely access to information in suitable forms about Bank operations and are consulted meaningfully about issues that may affect them. This OS 1 will be triggered if the project is likely to have potential (adverse) environmental risks and impacts on its area of influence.

Given the nature and scope of the proposed Zeila-Asha Addo Road project, this OS 1 is triggered because the project has different environmental and social impacts on the nearby biophysical and social environment, and the activities under this project have been subjected to full ESIA to meet this policy requirement which makes the proposed project eligible for the African Development Bank (AfDB) financing.

ELIGIBILITY CRITERIA

For the proposed road Project the following groups are entitled to compensation and/or assistance.

Project Affected Persons (PAPs)
Project Affected Families (PAFs)
Significantly Project Affected Families (SPAFs)
Displaced Family
Squatters
Vulnerable Groups

ENTITLEMENTS FOR THE PAPS

For this project, there are categories in consideration to receive benefits as an entitlement. These are:

Residential houses
Commercial/Buissnes
Loss of public social service (governmental)

During consultative meetings with senior administrative officials of the Regions and Districts/Towns, agreement has been reached that, as much as possible, PAPs made to resettle in areas closer to previous areas.

Table 10‑1:- Entitlement Matrix

No.	For Public social service	For Commercial/bussiness	For Residental houses
I	It is the pre-project or pre-displacement, whichever is higher with similar or improved public infrastructure facilities and services and located in the vicinity of the affected area	It is the pre-project or pre-displacement, whichever is higher	It is the market cost of the materials to build a replacement structure (house) with an area and quality similar to or better than the affected house, or to repair a partially affected house
II	The cost of any registration and transfer taxes	Market value of land of equal productive potential or use located in the vicinity of the affected land	The cost of transporting building materials to the construction site
III	The cost of transporting building materials to the construction site	The cost of land constructing structures, fences, toilet and shade for public.	The cost of any labour and contractors' fees
IV	The cost of any labour and contractors' fees	The cost of any labour and contractors' fees	The cost of any registration and transfer taxes

Implmentaion Process

Road Development Agency (RDA) will set-up the Resettlement Committee to oversee the implementation of the RAP. The Committee will mobilize the PAPs provides them with all the necessary information at various stages. The main responsibilities of these committees include but not limited to the following

Identify relevant government agencies that are mandated to plan and implement the RAP before the commencement of the road project.
Acquire the land required of the road project
Ensure that resettlement compensation for PAPs is fully implemented during the preconstruction period
Conduct regular monitoring and ensure that the objectives of the resettlement plan have met.

The following key tasks comprise Implementation of the RAP:-

Notification
Verification of properties of PAPs and losses
Compensation and resettlement
Preparation for clearance of the road corridor

Implementation Schedule

Time frame for implementing the RAP is based on the assumption that the Road Construction will start at late 2025, and the implementation process of this plan is estimated to last the duration of the road project Time schedule and summary of activities is presented in the Table 3 below.

Table 0‑2: RAP Implementation Schedule

SN	List of Activities	Calendar Year and Time table in Months
		2025								2026
		5	6	7	8	9	10	11	12	1	2	3	4	5	6	7	8	9	10	11	12
1	Conduct Inventory on PAPs
2	Asset Inventory valuation
3	Road Reserve Confirmation Survey
4	Establish District/town level sub committees and Grievance redress committees
5	Notify & reach agreement with PAPs
6	Vocational Training for PAPs
7	Implementation of Resettlements
8	Demolition and clearance of RAW
9	Grievance Redress
10	Monitoring

GRIEVANCES REDRESS MECHANISM

The filing of grievances has to be carefully recorded and properly kept. Complainants should be assisted by GRC members so that they can be able to address their issues in a satisfactory manner. Once a complaint is received at the complaints desk in the project office, it is registered and given a reference number for ease of following up. The Office will evaluate the application and determine whether the issue can be handled administratively or the Committee has to meet over the matter.

Where the Committee has to be convened, all its proceedings are recorded and minutes prepared of the deliberations. The minutes have to be confirmed at the next meetings and authenticated by the full sitting. All the resolutions agreed upon by the GRC have to be given prompt action so that the delay will not cause negative impact on the activities of the road project. Some issues that arise in-course of the project implementation are dealt with as they arise.

During the first months of the project, it is advised that the committee meet regularly every week since it will be common to receive many complaints from PAPs, which require the frequent presence of members for immediate actions and decisions. The frequency of the meetings can be reduced as the issues to be addressed decrease and the meetings may now be scheduled on periodic basis over months, until the completion of the project. The guiding principle in addressing the complaints is that the matters must be addressed as expeditiously as possible and within the dispute resolution mechanism, not more than a week should be taken before a decision is communicated to the complainant.

Grievance Redress Procedure

A PAP appeals grievance Local Grievance committee representative

Grievance addressed and PAP satisfied, no Further Action

Local Committee deals with the issue, makes decision and notifies to complainant within 1 week

Unresolved grievance referred to District Redress Committee by the Local PAP Committee or complainant

No Further Action

Grievance addressed and PAP satisfied

County Redress Committee deals with the issue, makes decision and notifies to complainant within 1 week

Resettlement committee receives the grievance from the Grievance Redress Committee, deals with the issue, makes decision and notifies to complainant within 1 week

Complainant not satisfied-then LEGAL ACTION

COSTS AND BUDGET

The estimate cost of the Resettlement Action Plan and Budget is prepared based on survey data collected from the PAPs, price list gathered from State Ministries of Public Works, land and housing and Agricultural Development. Information obtained from these offices include price of houses and other structure in various categories, price of constructing or planting public utilities and average market price of major crops for the last five years.

Table 0‑3 The total affected assets with the corresponding compensation cost

No.	Asset		Measurement	Quantity measures	Estimated Cost
1	Houses,Shedes and Fences (Private)		M2,metre	4645	800,296
2	Governmental Social service buildings.		M2,metre	167	17,648
Total		4,812			817,944

Table 1‑5:- Cost estimates for compensation and RAP implementation

List of Items	Unit Measurement		Amount (USD)
Cost Estimates for Compensation
Value of Structures/Buildings	M2		800,296
Public Utilities	Sum		17,648
Total 1			817,944
Cost Estimates for RAP Implementation
Professional service for Verification of assets and training of PAPs		6500
Resettlement and Grievance Redress Committee Cost (Allowance for members)		9750
Stakeholder Participation (Consultations and continuous sensitization)		13,000
Livelihood Support (Support and allowance for vulnerable groups)		22,750
RAP Implementation and Administration (Office Expenses and documentation)		7800
Monitoring and Evaluation		9750
Total2		69,550
Total 1+Total 2		817,944+69,550= 887,493.2
Disturbance Allowance (15%)		133,123.98
Grand Total		1,020,617.18

MONITORING AND EVALUATION

Monitoring and Evaluation is an integral part of this RAP and will oversee re-establishing process of the Project Affected Person (PAP). It will be a compliance monitoring and this will assist to follow the type of measures incorporated in RAP documents, and the extent to which on these matters, as set out in the RAP, are complied with. It is the objective of RDA to use lessons from the monitoring and evaluation results to enhance the preparation and implementation of future resettlement action plans.

The monitoring and evaluation process will assess the implementation of the project and ensure that it is carried out as per the plan and as per the requirements of the Republic of Somaliland laws, constitution and policies.

The monitoring and evaluation plan process will assess the implementation of the project and ensure that it is carried out as per the plan and as per the requirements of Republic of Somaliland laws and AfDB laws and guidelines.

The basic monitoring principles will describe:

The internal monitoring process;
Key monitoring indicators (provide a list of monitoring indicators, which would be used for internal monitoring);
Institutional (including financial) arrangements;
Frequency of reporting and content for internal monitoring, process for integrating feedback from internal monitoring into implementation;
Financial arrangements for external monitoring and evaluation, including process for awarding and maintenance of contracts for the duration of resettlement;
Methodology for external monitoring;
Key indicators for external monitoring, focusing on outputs and impacts;
Frequency of reporting and content for external monitoring and process for integrating feedback from external monitoring into implementation.
Analysis of the environmental and social performance or record of each sub-project

RAP reports indicate the arrangements for monitoring of resettlement/rehabilitation activities by the implementing agency, supplemented by independent monitors as considered appropriate by the donor and/or the Financer for this particular project.

Social and Environmental Management Plan

The Social and Environmental management plan is prepared in order to measure the social and environmental benefits and impacts during construction and after construction. The implementation of the management plan mainly will be that of Ministry of Transport and Roads Development (MTRD)/the RDA and local administrative bodies. The expertise required for the implementation of the management plan is available in the RDA.

Social and environmental management plan activities will be required for the following project phases; Pre–Construction phase (Engineering design and tender document preparation); Construction phase; and Road in operation / Service phase.

Construction Phase

This phase includes the implementation of RAP and compensation payment and the supervision of social Issues.

For the implementation of RAP, a prior notice, not less than six months shall be given to local authorities and Project Affected Persons if they are going to be relocated or lose their assets (fully or partially). Compensation payment is carried out according to the RAP for crops, trees, houses, and other affected properties located on permanently and temporarily dispossessed farm land.
Supervision of social issues during construction phase is an important activity and to implement this activity, it is proposed that the supervision consultant employs an experienced Sociologist and Environmentalist. The Issues that need to be supervised include;
Safety and health requirements; HIV/AIDS and STD control measures; Temporary land requirements and reinstatement; Reinstatement / re-cultivation of abandoned road sections after the construction of a respective section of improved / realigned road is completed for compensation of crops and other assets located on permanently dispossessed land (replacement of land)
Create awareness among construction workers not to dump spoil on farmland
Construction of camps to be established in distant location from villages
Avoid spoil dumping on farmland
Plantation of trees
Drainage to be designed properly to protect the road and adjacent slopes and in particular protecting farmlands from drainages

Operation Phase

The third and final phase is the operation phase, and the social and environmental management activities include awareness and education activities on road safety.

Following the operation of the project road, awareness and education activities should be provided on road safety and other negative social impacts. Transport and Roads Development (MTRD)/the RDA, Local authorities, Policemen, NGOs operating in the project area and the Contractor shall be responsible for the introduction and implementation of the awareness and education activities.
Reinstatement of quarry and borrow pit sites
Erosion control measures such as grassing
Installing traffic signs

Performance monitoring

To ensure the complete and objective information; performance monitoring indicators will be used to measure inputs, outputs, and outcomes for resettlement activities. It also checks the involvement of the PAPs in the monitoring process.

Impact Monitoring

Impact monitoring is used to evaluate the impact of resettlement for a reasonable period after all resettlement and related development activities have been completed. It uses the results of resettlement monitoring to guide its subsequent implementation.

For the monitoring and evaluation of the RAP activities, the Implementing Committee (to be established) or the National Land Planning Committee together with MTRD and the RDA will take a prime responsibility at the project area level. The committees through District administration office, which is the coordinator for the implementing committee will follow and clarify the implementation processes, and whenever found to be necessary will arrange the ground for consultation with Project Affected Persons (PAP).

MTRD and the RDA will be responsible to monitor and evaluate the RAP in consultation with District administration office. The monitoring indicators that will be adopted include;

Number of PAPs and amount of compensation made
Type and size of restoration and restitution measures for PAP
Appropriateness of relocation sites etc

RDA will assign a qualified Sociologist/Social scientist to conduct individual evaluations of PAPs re-establishment socio-economic progress. This service aims at evaluating, and reporting on, the level of living conditions and social services of the PAPs, both before and after the re-establishment. The evaluation will be done on quarterly and annual basis for three consecutive years. The monitoring and evaluation results will be based on a number of key indices for selected households, in combination with the special observation by the social scientist.

Internal Monitoring

Internal monitoring will be conducted by the RDA, following the plan described and the assigned team should make the necessary follow-up to ensure that proper monitoring is being undertaken. Since the magnitude and complexity of the operations is not quite large, RDA will conduct the monitoring through field visits at least once a month. The local administration will also conduct its own monitoring of the RAP or in collaboration with the RDA.

The monitoring report by RDA staff will be submitted to local authorities (Town and Municipality). A copy of this will be submitted to Somaliland Ministry of Environment and RDA. It will also be enclosed in the construction progress reports submitted by supervising engineers. Only in this way can RAP implementation be monitored and problems identified.

Monitoring Indicators

The following are some of the monitoring indicators to be used by the monitoring team following the implementation of the RAP.

Physical indicators

Size and extent of farm land affected
Number of farmers lost land
Amount of compensation paid
Number of housing structures affected
Number of businesses affected
Number of HH affected

Economic and Financial indicators

Number of businesses re-established
Utilization of compensation payment by PAPs
Income restoration measures and schemes
Project management costs

Grievance redress indicators

Number of grievances and mechanism adopted to resolve
Number of cases taken to court

Social indicators

Number of Districts/Towns level resettlement, valuation and grievance committees established
Involvement of PAPs in various committees
Representation of women and support to women
Support to vulnerable groups

External Evaluation

The external evaluation will be done in a predictable manner and period. The Somaliland Ministry of Environment and the Minstry of Transport and Road Development will be responsible for the external monitoring of the RAP. Both the Local and Country level Environmental Authorities have significant role in the external monitoring and evaluation of the RAP. The supervision missions will also serve as one of the external monitoring mechanisms.

The objective of the external monitoring and evaluation, which is also a post resettlement assessment will be done by an independent consultant (or an an NGO) commissioned by RDA, to ensure that the project affected persons have secured and able to maintain at least their livelihood prior to the upgrading of the project road.

Hence, at the end of all expropriation/compensation operations a household survey will be carried out to evaluate the impacts of the resettlement and other implemented social mitigation measures. During the survey, District, Municipalities and village level administrations will be consulted to provide their assessments of the impacts of the mitigation measures applied.

After completion of the resettlement/rehabilitation operations, it is expected that PAPs should be better off than prior to resettlement. Therefore, resettlement/rehabilitation operations need to be monitored as regard performance and compliance with the set goals.

The evaluation report will be used as a planning instrument to correct pending issues and suggest a post-project monitoring period in the aim to ensure that PAPs have not been subject to impoverishment induced by the RDA operations.

To assess the achievements and progress of the implementation of the RDA will organize project completion workshops with other Government agencies and representatives of PAPs. The findings of the survey and the workshops will be presented in the Project Completion report

PUBLIC CONSULTATION

Major stakeholders identified with whom consultation was made include: Ministry of Transport and Road development, Road and Tranport Agency (RDA), Boroma Region and major institutions (health, education, water) and Zeila District Administration.

Methods implemented to conduct consultaion was Focus group discussion (FDG) in Borama and Zeila stakeholders meetings and questioners and interviewing sectoral professionals was implemented to gather sectorial information in Boroma, the regional capital from March 17/20121 till March19/2021.

Major outputs of consolation both Zeila and Borama attendants underlined the route should go via Zeyila town as it is the historical port and Regional capital of Selal. Major outputs from Boroma Region sectoral instructions are also gazered and use to develop baseline information of this ESIA.

INSTITUTIONAL ARRANGEMENTS FOR THE IMPLEMENTATION OF RAP

Road Development Agency (RDA) is the implmenter of this road project, and it will be the primary responsible agency for ensuring that the RAP is implemented in accordance with the agreement reached with the bank. However, other relevant government agencies (national and state) will also be involved in the in the process. All involved will have roles to play in accordance with the authorities and responsibilities vested in them by the laws of the republic of Somaliland.

Ministry of Public Works, Land and Housing

The Ministry is responsible directing the compulsory land acquisition for the road project, and ensuring the necessary compensation has been properly effected to PAPs. The Ministry processes the request from the project promoter. In collaboration with state and county administrators, it handles the overall process of land acquisition; valuation, compensation and grievance redress mechanisms during implementation of the RAP

Awdal and Salal Region Government

Ensuring that community members of the states fully accept the provisions and directives of declarations of the, Republic of Somaliland about displacement of and compensation. They also fully participate in compensation, valuation and grievance committees once the road project started and vigorously work to make sure PAPs are properly compensated. Members of the state administration will also make sure that enough land is acquired to resettle PAPs.

District/Town Administration Units

Under the direction of their Regional governments, they are responsible for mobilizing the communities for smooth implementation of the RAP, and ensuring that PAPs are not adversely affected by the road project. As grassroots government representatives to the local communities, they know specific matters and they needs of their communities very well, are able to resolve disputes as they arise.

CONCLUSIONS AND RECOMENDATIONS

This Resettlement and Action Plan will be implemented by compensating the individuals affected by the proposed road activities. The compensation and assistance allowances will enable the PAPs to relocate and pave way for the road construction. To achieve the best results of the RAP, however, it is recommended that any planned displacement of the project affected persons be undertaken after compensation payments have been made before any construction activities are done and in accordance with the prevailing law. The project affected persons shall be given adequate notice, at least 3months to surrender and remove their property from the road corridor. And finally, displacement of PAPs shall take place during dry seasons, especially between December and January, where farming and other economic activities will be in a normal routine and less burdensome.

GENERAL OVERVIEW

1.1 Introduction

Despite these socio-economic benefits, however, road projects entail some changes on the current ways of life of the community, both negatively and positively. One of such changes occurring in most projects is displacement of people from their land and loss of properties. In light of this, it is found critical to prepare a resettlement action plan based on which the project owner shall be able to mitigate the impacts of the resulting displacements by the project.

1.2 Project Description

The road corridor traverses only two towns include Zeila and Asha Addo major towns. Description of project activities will highlight the location and extent of potential impacts on the socio-economic environment of the project area. On this ground, the principal project activities expected to be considered, among others, as causing either beneficial or adverse environmental impacts are:

Construction activity impacts on Right of Way (ROW) are expected to be miled on the rural section between the two towns. Camp site selection will be the task of the contractor who won this lot. The ancillary facilitates which will require additional land for construction in this project may include at least 4 camp sites, 4 crusher and a number of quarry sites and borrow pits and disposal of excavated unsuitable and surplus materials at designated disposal sites during construction.

Figure 1‑1:- Project Location (Zeila-Asha Addo points)

1.3 Objectives of the resettlement action plan

The main objective of the RAP for the Asha Addo Road project is to identify and assess the impact of the project on project-affected populations and formulate a RAP consisting of all appropriate measures and strategies which are necessary to mitigate the adverse effects of the project, restore and improve the income and livelihoods of PAPs.

1.4. AfDB Guideline on Involuntary Resettlement

The African Development Banks’ document entitled” Guidelines on Involuntary Displacement and Resettlement in Development Projects” (2003) stipulates that when people must be displaced; it is to be ensured that they are treated equitably and they share in the benefits of the project that involves their displacement. Efforts shall be made to minimize disturbances to their livelihoods, ensure that the displaced persons receive resettlement assistance to improve their living standards. Special attention shall be paid on the displacement of disadvantaged groups such as female headed households, elderly people, the poor and the marginalized communities. The borrowing country shall set up mechanism to monitor the performance of the Resettlement Plan. The guidelines further recognize that the borrowing country has laws and regulations dealing with various issues pertaining to displacement and compensation for loss of assets and rights that need not be violated.

1.4.Scope of the Study

While preparing this resettlement action plan, effort has been made to ensure that the integrated social safeguards guidelines of the African Development Bank’s Policy on Involuntary Resettlement, i.e. Involuntary Resettlement Policy (2003); have been followed. In this regard the following key elements have been addressed.

Clearly define the project affected persons, their eligibility for compensation, the types and cost estimates of assets to be affected and compensated and the cut-off date for eligibility
Provide a socio-economic Justification for identification of entitlements and strategies for mitigating the impacts
Establish rates for compensation on loss of assets.
Establish land acquisition and compensation process and establish grievance redress mechanism.
Review of institutional and policy frameworks to see if any gaps between AfDB guidelines and the laws of Republic of Somaliland on issues of involuntary displacement.

1.5.Methodology

Literature review documents reviewed include: ESIA of the Lowyaddo-Ferdha-Borama road project, Somaliland Country Report, summery report, 2016, Pastoral society of and transformational refugee: population movement in Somaliland, Augest2002, UNHCR,Somaliland food and water security strategy, Somaliland Interagency need assessment, Somaliland National policy by the land policy drafting group.
Socio Economic Surveys: for this a structured questionnaire was developed and applied to gather information through interviewing PAPs (see annex 1)
Review of documents and reports at project areas.
Public and Stakeholder Consultations
Key informant interviews
Observation along the road corridor on characteristics of the communities to be potentially affected by the road improvement.

1.5.1. Literature Review

For developing this resettlement action plan relevant documents were reviewed to give insights on the conditions of the project area. The literatures include similar Resettlement action Plan (RAP) documents and documents which deal about existing land use policies, guidelines, regulations, land proclamations, applicable international conventions and previous studies made on the Country where the project is located.

Key reports, policies and legislations that were reviewed include Constitution of the Republic of Somaliland, 25th May 1993, the people of Somaliland approved and proclaimed to the whole world on this 31st May, 2001, that this constitution has been adopted as the nation’s Constitution.

Land tenure policy as treated under the Constitution of the Republic of Somaliland, Africa Development Bank’s Involuntary Resettlement Policy 2003, the Africa Development Bank’s Integrated Safeguards System, (December 2013).

The review therefore was to:-

Review the Development Plans and strategies influencing land use patterns in the project area.
Review previous RAP documents and incorporate constructive measures to the document.
Review legal and policy frameworks on compensation and resettlement.
Identify and harmonize possible gaps in resettlement and compensation guidelines between laws and policies of the republic of Somaliland and the AfDB Guidelines on Involuntary Resettlement and other Social Safeguards.
Establish the land use rights of PAPs.

1.5.2. Socio-Economic Survey

Field visits were conducted to collect and assess primary data and information about the project area in general and the Project affected people in particular. The collection of socio-economic data was conducted through a structured questionnaire, administered in the field by the consulting staff. PAPs were interviewed to find out their livelihood and household characteristics. A census and inventory of assets were carried out and the data was compiled to come up with the total loss of assets of PAPs as a result of the project. The land considered for the assets inventory was based on the design of the road alignment and the areas earmarked for acquisition. The survey included categorization of the various socio economic activities in the project area that are occupied by the PAPs and will be displaced by the proposed road project. Other questionnaires were also developed to be administered by key experts of relevant offices in the two states, mainly the Ministry of Public works, Land and housing, Agricultural Development and relevant municipalities. The data collected from these offices are mainly price lists for constructing houses of different types, as well as current market prices of main agricultural products.

Figure 1‑2:- Conducting Interview of PAPs in Asha Addo village

1.5.3. Stakeholders Consultation

During the field visits consultations were made with various government officials at district and town levels, and community members that are identified as potentially affected by the road project. The dates of consultation are 14/03/2021-17/03/2021, 6/9/21 and April 15-May20/2022 with more details indicated under Table 6-1.

The team ensured that all those that have stakes in the project specially the communities in the project area were consulted to have better understanding of the declarations and provisions laid down in the constitution of the republic of Somaliland, as well as Land tenure policy as treated under the Constitution of the Republic of Somaliland. Effort has been made to ensure that discussants at all levels were made aware of their rights and obligations regarding displacement and equitable compensation due to mega development projects like road construction. They were also encouraged to give their views on the project, and their say have been incorporated in the document. Apart from consultations with stakeholders at states level, the consulting team conducted stakeholder meetings and interviews at district level, Town level and community levels targeting the executive administrators at district levels, traditional leaders, villagers in the project area, Business owners and representatives of community based organizations and NGOs. At community level, the consulting team conducted focus group discussions (FGD) and individuals interview with the identified stakeholders. The minute of consultations with stakeholders attached in Annex 2.

LEGAL FRAMEWORK

In this Chapter, relevant policies and legislations of the National Government of Somaliland and those of African Development Bank are discussed. This will enable implementers of the RAP to comply with the required national and AfDB policy requirements, as well as to use the policies and legislations to ensure that adequate mitigation measures are put in and to deal with any negative impacts on the project affected persons.

2.1 National Legal Frame work

2.1.1 Government of Somaliland Constitution

Article 12 says, “The land is a public property commonly owned by the nation, and the state is responsible for it”, and shall take all possible steps to explore and exploit the natural resources which are available in the nation’s land or sea. The protection and the best means of the exploitation of these natural resources shall be determined by law.

Article 31of the Constitution recognizes that every person has the right to own private property, if it is acquired lawfully, and that such property may not be expropriated except for reasons of public interests in the exchange of proper compensation. The private property ownership includes land in which Art. 2(1) of Law No. 8/1999, and 19(a) of Law No.17 established private ownership of land with the title deed. 12 Official versions to refer is the Somali and it has same meaning as in this English version (Somalilandlaw.com). Under the constitution, people have equal rights and obligations before the law, and shall not be discriminated on the grounds of clan, birth, gender, property, status or opinion (Art. 8).

Article 36 of the Constitution recognizes that women and men enjoy equally the rights, freedoms and duties laid down in the Constitution, “save for matters which are specifically ordained in Islamic Sharia”. It further provides that the government shall encourage and legislate for “the right for women to be free of practices which are contrary to sharia and which are injurious to their personality and dignity”; women have the right to “own, manage, oversee, trade in or pass on property in accordance with the law”. In light of this, women can legally own and control land but there are many cases in which customary rules prevail over statutory law, especially in rural areas where traditional social systems discriminate against women and impede them from owning and controlling land. This constitutional principle for women’s rights need to be interpreted into practice and mainstreamed into programs within the public sector delivery of services.

2.2.2 Legislative framework

As mentioned above, under Art. 12 of the Constitution, the state is responsible for land administration, but this part will examine how the administration is delegated to different authorities including Ministries and local authorities.

The lack of a comprehensive land policy, the desperate and to some extent inconsistent legal frameworks and weak institutional governance in land administration has shifted public trust from the public institutions to the clan system where communities feel their land is more secure through clan protection. For instance, elders have assumed crucial decision-making powers in land disputes. Sometimes, the police and judicial institutions redirect critical land cases to elder’s for the later to pass final judgments that are often enforced. However, even the decisions of elders may be rejected by a losing party and this can lead to unresolved clan disputes, especially among pastoral and agro pastoral communities where clashes over scarce resources lead to conflicts that are difficult to prevent or resolve.

2.2 The African Development Bank Policy and Procedures

2.2.1 The Integrated Safeguards Systems (ISS) of the AfDB, 2023

The updated ISS 2023 comprises:

• the African Development Bank Group’s Vision for Sustainable Development, which sets out the Bank Group’s approach and aspirations regarding E&S sustainability;

• the African Development Bank Group’s Environmental and Social Policy, which sets out the Bank’s commitments and the relevant principles and requirements that the Bank must follow regarding projects, activities, and initiatives that it supports;

• ten OSs, together with supporting annexes, which set out the mandatory requirements that apply to the projects, activities, and initiatives of Borrowers;

• the Environmental and Social Guidance Notes (ISS Guidance Notes), which are tools that provide technical guidance for the Bank and its Borrowers on specific methodological approaches, Good International Industry Practice (GIIP) and standards relevant to meeting the requirements of the OSs. The Bank’s ISS Guidance Notes are supplemented where necessary by the World Bank Group Environmental, Health and Safety (EHS) Guidelines, which were adopted by the MFI Working Group on Environmental and Social Standards.

Projects supported by the Bank shall meet the requirements of all the following E&S OSs, as applicable:

• OS 1: Assessment and Management of Environmental and Social Risks and Impacts

• OS 2: Labour and Working Conditions

• OS 3: Resources Efficiency and Pollution Prevention and Management

• OS 4: Community Health, Safety, and Security

• OS 5: Land Acquisition, Restrictions on Access to and se, and Involuntary Resettlement

• OS 6: Habitat and Biodiversity Conservation, and Sustainable Management of living Natural Resources

• OS 7: Vulnerable Groups

• OS 8: Cultural Heritage

• OS 9: Financial Intermediaries, not applicable to this project as it is funded by AfDB

• OS 10: Stakeholder Engagement and Information Disclosure.

Environmental and Social sustainability is a key to economic growth and poverty reduction in Africa. The Bank’s Strategy for 2013-2022 emphasizes the need to assist regional member countries in their efforts to achieve inclusive growth and transition to green growth.

Avoid adverse impacts of projects on the environment and affected people, while maximizing potential development benefits to the extent possible;

Help borrowers/clients to strengthen their safeguard systems and develop the capacity to manage environmental and social risks.

The Bank requires that borrowers/ clients comply with these safeguards’ requirements during project preparation and implementation. The Integrated Safeguards Policy Statement sets out the basic tenets that guide and underpin the Bank’s approach to environmental safeguards.

In addition, the Bank has adopted ten OSs required to achieve the goals and optimal functioning of the ISS. Given the proposed project nature and scope, most of the OSs are triggered with the major OSs being OS1 and OS5, that are directly related to Involuntary Resettlement Land Acquisition and Social impacts are discussed in the below section.

Operational Safeguard 1 (OS 1): Assessment and Management of Environmental and Social Risks and Impacts

This overarching safeguard governs the process of determining a project’s environmental and social Category and the resulting environmental and social assessment requirements. The objectives of this Operational Safeguard (OS 1) are to identify and assess the environmental and social impacts (including gender) and climate change vulnerability issues of Bank lending and grant financed operations in their area of influence; avoid or if not possible minimize, mitigate and compensate for adverse impacts on the environment and on affected communities; and ensure that affected communities have timely access to information in suitable forms about Bank operations and are consulted meaningfully about issues that may affect them. This OS 1 will be triggered if the project is likely to have potential (adverse) environmental risks and impacts on its area of influence.

Operation Safeguard 5 (OS 5): Involuntary Resettlement, Land Acquisition, Population Displacement, and Compensation

This safeguard consolidates the policy commitments and requirements set out in the Bank’s policy on involuntary resettlement and it incorporates refinements designed to improve the operational effectiveness of those requirements. In particular, it embraces comprehensive and forward-looking notions of livelihood and assets, accounting for their social, cultural, and economic dimensions. It also adopts a definition of community and common property that emphasizes the need to maintain social cohesion, community structures, and the social interlink ages that common property provides. The Objectives of this OS5 are to avoid involuntary resettlement where feasible, minimize resettlement impacts where involuntary resettlement is unavoidable, explore all viable project designs; ensure that displaced people receive significant resettlement assistance, preferably under the project, so that their standards of living, income earning capacity, production levels and overall means of livelihood are improved beyond pre-project levels; and set up a mechanism for monitoring the performance of involuntary resettlement programs in Bank operations and remedying problems as they arise so as to safeguard against ill-prepared and poorly implemented resettlement plans.

The safeguard retains the requirement to provide compensation at full replacement cost; reiterates the importance of resettlement that improves standards of living, income earning capacity, and overall means of livelihood; and emphasizes the need to ensure that social considerations, such as gender, age, in the project outcome, do not disenfranchise particular project-affected people. Given the nature of the proposed project that will have an impact on both economical and physical displacement, this OS 5 is triggered.

2.2.2 Environmental and Social Assessment Procedures, November 2015

The main purpose of the Environmental and Social Assessment Procedures (ESAP) is to improve decision-making and project results in order to ensure that Bank-financed projects, plans, and programs are environmentally and socially sustainable as well as in line with the Bank’s policies and guidelines. The ESAP intends to replace the actual procedures and integrate all crosscutting considerations into the new assessment process. The ESAP describes the various steps that shall be followed to mainstream cross-cutting issues along the project cycle, from country programming to post-evaluation. The first step consists in developing and updating baseline data on Regional Member Country’s environmental and social components, policies, programs, and capacities to better integrate environmental and social dimensions into lending priorities during country programming. During the project identification phase, the screening exercise focuses on the environmental and social dimensions of a project to categorize it into one out of the four categories (Cat 1, Cat2, Cat 3, and Cat 4). Given the nature of the proposed road project, the project is supposed to be classified under Cat 1 and discussed below.

Category 1: Bank operations likely to cause significant environmental and social impacts

Category 1 projects are likely to induce significant and/or irreversible adverse environmental and/or social impacts or to significantly affect environmental or social components that the Bank or the borrowing country considers sensitive. In some cases, projects are included in Category 1 because of their potential cumulative impacts or the potential impacts of associated facilities. Any project requiring a Resettlement Action Plan (RAP) like the Zeila-Asha Addo Road project under the provisions of the Bank’s policy on involuntary Resettlement is also deemed to be Category 1.

Category 1 investment projects require an ESIA, both leading to the preparation of an ESMP. Thus, given the nature and scope of the proposed Zeila-Asha Addo Road project, it is assigned under Category 1 and subject to the preparation of a full Environmental and Social Impact Assessment (ESIA).

2.2.3 African Development Bank’s Safeguard Policy and guidelines Involuntary Resettlement Policy, 2003.

The overall goal of the Bank’s Policy on Involuntary Resettlement is to ensure that when people must be displaced they are treated equitably, and that they share in the benefits of the project that involve their resettlement. The Policy has the following key objectives:-

To avoid involuntary resettlement where feasible, or minimize resettlement impacts where population displacement is unavoidable, exploring all viable project designs. Particular attention must be given to socio-culture consideration such as culture or religious significance of land, the vulnerability of affected population, or the availability of in-kind replacement for assets, especially when they have important intangible implication. When a large number of people or a significant portion of the affected population would be subject to relocate or would suffer from the impacts that are difficult to quantify and to compensate, the alternative of not going ahead with the project should be give serious consideration;
To ensure that the displaced people receive resettlement assistance, preferably under the project, so that their standards of living, income earning capacity, and production levels are improved;
To provide explicit guidance to Bank staff and to the borrowers on the conditions that need to be met regarding involuntary resettlement issues in Bank operations in order to mitigate the negative impacts of displacement and resettlement and establish sustainable economy and society; and
To set up a mechanism for monitoring the performance of involuntary resettlement programs in Bank operations and remedying problems as they arise so as to safeguard against ill-prepared and poorly implemented resettlement plans.

In order to achieve the goals of this Policy that involve Involuntary Resettlement, the Plan shall be prepared and evaluated according to the following guiding principles:-

The borrower should develop a resettlement plan where physical displacement and loss of economic assets are unavoidable. The plan should ensure that displacement is minimized, and that the displaced persons are provided with assistance prior to, during and following physical relocation. The aim of the relocation and of the resettlement plan is to improve displaced persons former living standards, income earning capacity, and production levels. The resettlement plan should be conceived and executed as part of development program, with displaced persons provided with sufficient resources and opportunities to share in the project benefits. Project planners should work to ensure that the affected communities give their demonstrable acceptance to the resettlement plan and the development program, and that necessary displacement is done in the context of negotiated settlement with affected community.
Additionally, displaced persons and host community should be meaning-fully consulted early in the planning process and encourage participation in the planning and implementation of the resettlement program. The displaced persons should be informed about their options and right pertaining to resettlement. They should be given genuine choices among technically and economically feasible resettlement alternatives. In this regard, particular attention should be paid to the location and scheduling of activities. In order for consultations to be meaningful, information about the proposed project and the plans regarding resettlement and rehabilitation must be made available to local people and national civil society organizations in a timely manner and in a form and manner that is appropriate and understandable to the local people. As well, careful attention should be given in the organization of meetings. The feasibility of holding separate women’s meetings and fair representation of female heads of households, in addition to mixed meetings should be explored. Also, the way in which information is disseminated should be cautiously planned as levels of literacy and networking may differ along gender liners;
Particular attention should be paid to the need of disadvantaged groups among those displaced, especially those below the poverty line, the land less, the elderly, women and children, and ethnic, religious and linguistic minorities; including those without legal title to asset, female head of households. Appropriate assistance must be provided to assist the disadvantaged groups cope with the dislocation and to improve status. Provision of health care services, particularly for pregnant women , and infants, may be important during and after relocation to prevent increases in morbidity and mortality due to malnutrition, the psychological stress of being uprooted, and increased risk of diseases;
Resettles should be integrated socially and economically into host communities so that any adverse impact on host communities is minimized. Any payment due to the hosts for land or other assets provided to resettles should promptly render. Conflicts between hosts and new arrivals may develop as increased demands are placed on land, water, forests, services, etc, or if the new arrivals are provided services and housing superior to those of the host. These impacts must be carefully considered when assessing the feasibility and cost of any proposed project involving displacement, and adequate resources must be reflected in the budget for the mitigation of those additional environmental and social impact.
Displaced persons should be compensated for losses at “replacement cost” prior to their physical displacement or before taking-over of the land and related assets or commencement of project activities, whichever occurs first; and
The total cost of the project as a result should be included in the full cost of all resettlement activities, factoring in the loss of livelihood and earning potential among affected peoples. This attempt to calculate the “total economic cost” should also factor the social, health, environmental and psychological impacts of the project and displacement, which may disrupt productivity and social integration. The resettlement cost should be treated against economic benefits of the project and any other net benefits to new arrivals should be added to the benefit stream of the project.

The policy defines the affected population in a resettlement program, describes the modes of identifying their loss of assets/income resources or access to assets, eligibility and entitlements within the context of a resettlement plan.

2.2.4 AfDB Gender Policy

The policy is based on the premise that Africa has pronounced, region-specific gender characteristics that are of direct relevance to its economic and social development. It takes into account the international agenda, which calls for transformation, aimed at achieving full and equal partnership between men and women. Gender has become an issue for development intervention. First, inequalities continue to exist between women and men despite significant improvement in the absolute status of women and gender equality in most African countries. The following guiding principles form the basis of Bank’s assistance in the area of gender/women empowerment:-

Gender analysis will be an integral part of all Banks’ policies, programmes and projects.

Gender analysis will be conducted for all Bank intervention in order to design intervention that respond to the needs and priorities of both men and women. Experience has shown that women and men differ in the way they respond to and/or benefit from development and in the absence of specific attention to differences between women and men, planning for “the people” can result in the exclusion of women or men as participant or beneficiaries of planned change.

Attention will be paid to the co-operative relation between women and men.

The concept of gender implicitly embodies a culture that entails cooperation and interdependence between men and women rather than separation. It is oriented towards an equitable and sustainable development with women and men as equal partners in decision making. Focus on women without taking into account their relations with men can undermine the objective of reducing disparities. Women do not live in isolation and by addressing them as such, development practitioners risk alienating must strive to empower both men and women to transform relations between them by taking into account the needs and interests of both genders and ensuring that all benefit equally from development.

Women’s economic empowerment will be considered as key to sustainable development.

Women in Africa are active in a variety of economic areas. Moreover they often shoulder the primary responsibility for the well-being of the family. However, due to legal and customary barriers women lack access to credit and this impedes their effective economic participation. Experience has shown that providing credit services to women enhances productivity and promotes efficient lab our allocation. In addition, relative to men, women who possess economic means, invest more in education and health of their children. Measures will therefore be taken to support Regional Member Country (RMC) initiatives that target women entrepreneurs and producers in both formal and informal sectors and which adopt innovative lending policies and practices;

Women will not be considered to be homogeneous group.

Although they may face some common difficulty due to the manner in which a particular society defines gender, other important factors such as class, race, ethnicity and religion also contribute to their position in the society. Thus, activities targeting an in differentiated category “women” may provide opportunities to some women and at the same time leave other groups disadvantaged. Program and project will take account of difference between women; and

A strategic choice will be made on the use of the mainstreaming strategy/target input.

Targeted projects for women or men and gender mainstreaming are not incompatible responses. The question is one of strategic and operational choice depending on a particular situation. Targeted intervention may be required to address the disadvantages and limitations experiences by women as a consequence of the way the gender concept is conducted in a specific context. Thus projects should be designed to address gender disparities, or, to target issues which specifically affect women such as ownership of land, access to credit or legal literacy. Similarly, activities could target the special gender division of lab our and male responsibility in reproductive health issues.

This policy codifies the Banks’ formal commitment to the gender mainstreaming approach. It seeks to define a more systematic approach to planning of development interventions so that they can address the priorities of women as well as men for greater efficiency, effectiveness and sustainability unlike the former Women in Development (WID) policy. The focus of this policy is gender relations, which shape outcome for both men and women. With introduction of the gender analytical framework, the fundamentally social nature and gender differences that result in inequalities between women and men gains greater visibility. The policy adopts the concept of “gender mainstreaming” as a key strategy for overcoming women’s exclusion from decision making and from access to any control over development resources and benefits.

2.3.5 Bank Group Policy on Poverty Reduction

The goal of the Bank’s poverty policy is to ensure that poverty in Africa is reduced. This involves development of strategies that facilitate national ownership, participation and an orientation towards improvements in the welfare of the poor, especially in the achievement of Millennium Development Goals (MDGs).

The objectives of the policy are to bring poverty reduction to the forefront of the Bank’s lending and non-lending activities and to support its Regional Member Country’s (RMCs) in their efforts towards poverty reduction. Support for country-owned Poverty Reduction Support Programmes (PRSPs) plays an important role in this respect. The following are the policy Guiding principles:-

Poverty Focus. Poverty reduction has become the overarching goal of the Bank for the last four years. The realization of this goal requires a more focused analysis of the incidence, depth and causes of poverty in Africa. Such focus on poverty reduction instance, it is necessary to go beyond a general support for agricultural, human resource and private sector development by designing and implementing pro-poor policies within these broad areas.
National ownership. Participation and outcome orientation. The principles of the new strategic framework form the basis for the policies discussed in this chapter. A number of policy measures such as support for national capacity building, promotion of the participatory approach development of new forms of partnerships and establishment of poverty monitoring systems relate directly to these principles.
Internal policy coherence. The importance of the priority areas and the cross-cutting issues has been discussed in the Banks sector specified policies. The purpose of the poverty policy is to strengthen existing sector policy prescriptions and to fill gaps on specific areas from standpoint of poverty reduction.
Country-led partnership. The policy also underscores the importance of a coordinated donor response to the demand from RMCs for supporting their PRSPs. A strong partnership ensures the consistency between the Bank’s poverty policy and the poverty reduction strategies of its RMCs as articulated in the PRSPs for African Development Fund (ADF) countries and similar planning documents for African Development Bank (AfDB) member countries.
Enriched conceptual framework. The policy takes into account the new conceptual framework which expands the concept of poverty beyond income measures and its causes. It also addresses the economic and non-economic causes of poverty.

2.3.6 AfDB Disclosure and Access to Information

This revised policy supersedes the AfDB Policy on disclosure of information dated October 2005.The Policy provides the Bank group with an improved framework within which to disclose information on policies and strategies and key decision made during project development and implementation.

Maximum disclose and access to information will increase public support for the Bank Groups Mission and enhance the effectiveness of its operations. The policy contains the following new elements:-

A strengthened presumption of disclosure, eliminating the positive list and emphasizing a limited negative list;
Introduction of an appeals mechanism;
Provision of simultaneous disclosure; and
Increased access to the broad range of stakeholders.

The policy aims to:-

Maximize disclosure of information within the Banks Groups possession and limit the list of expectations to reflect the Banks willingness to disclose information
Facilitate access to and share information on the Bank group’s operations with a broad range of stakeholders;
Promote good governance, transparency and accountability to provide leadership in this areas to RMCs;
Improve on implementation effectiveness and better co-ordinate the information disclosure processes;
Give more visibility to the Bank Group’s mission, strategies and activities to stakeholders
Support the Bank Group’s consultative process in its activities and stakeholders participation in the implementation of the Bank Group financed projects
Ensure harmonization with other Development Finance Institutions (DFIs) on disclosure of information.

During the RAP implementation it is strongly recommended that Somaliland RDA through the RC should embark on sensitization strategy that endeavors to keep the community and the PAPS fully informed on the progress being made in the implementation of the project.

2.3.7 Handbook on Stakeholders Consultations and participation on AfDB Funded Projects

Participation in development can be defined as the process through which people with an interest (stakeholders) influence and share control over development issues that affect them. Measures have to be taken to identify the relevant stakeholders and involve them in the process of formulating the project. This entails sharing with them the objective of the project and seeking their views for integration in the project design before decisions are concluded. It might be necessary to take the stakeholders through a process of training and thus empowering them not only to meaningfully to contribute to the project design but also for their future participation in the sustainability of the project.

According to the Handbook, many methods and technique have been developed to promote participation by stakeholders in development. Some of the methods and techniques used include:-

Participatory stakeholders analysis
Participatory meetings and workshops
Participatory research /Data collection.
Participatory planning

In some instances, it might be necessary to combine the above techniques depending on the nature of the project at hand and the complexity of the stakeholders involved.

POTENTIAL IMPACTS AND MITIGATION MEASURES

3.1 Project Affected Persons

Analysis of the data on the census of the project affected persons along the road corridor and the socio-economic survey has revealed that there were 40 private households and 4 governmental social services along the road who had right of livelihood by operating business along the road corridor. These people had a number of dependents making a total of about 40 PAPs. 100% of the PAPs are concentrated in Asha Addo settlement area.

3.2 Loss on incomes and Economic Livelihoods

Figure 3‑1:- Potentially Affected Trade and Business centers by the road project @ Asha Addo

3.3 Loss on Houses

As it has been observed during the field site observation and from the land acquisition plan the road project will affect about 2429 m² houses, 2106m² sheds,10m² tanks, 21m² toilets and 110 m² fences, which include residential houses and business houses in the transacted villages and Town Administration particularly in urban project road sections. Consequently, the affected households due to loss of residence and business houses will be dislocated and faced resettlement problems. The majority walls of affected houses are constructed with wooden or brickwork and their roofs are made of CIS (corrugated iron sheet).

Mitigation Measures

Compensate for lost houses (residential and commercial) as per the law
Provide land for PAPs so that they can construct houses

Involve PAPs in the property valuation committee

3.4 Loss of structures

4 governmental and 40 private properties are will be affected by the project road. Out of the total 40 households, 21 households will lose their residential houses and additional 19 households will lose their business/commercial houses from which they make a living by working on or renting them to others. These 40 households and 4 governmental affected properties have to be given reasonable compensation for reconstructing new houses.

Figure 3‑2:- Loss of Structures due to the road project @ Asha Addo

3.5 Impact on vulnerable groups

The survey conducted reveals that some of the project affected persons qualify to be categorized as vulnerable. These people include persons with physical disabilities and impairments (mostly war veterans), elderly and female headed households. Out of the 40 households surveyed, 07 were female headed households, 02 are disabled headed households, and other 04 headed by elders who are above the age of 60. Besides, 20 households have at least 1 member of the household who is vulnerable. In view of this, it is recommended that the Resettlement shall make special consideration to restore livelihoods of these households.

3.7 Impact on Public Social services

With respect to public social services some governmental offices (Customs office) structures and sheds are affected. Otherwise public utilities, such as, electric poles and water reservoirs, water pipe, water meter, water points, manhole, solar panel lines will not be affected due to the construction of the project road in any of the locations. The social servicea (governmental) units affected are depicted under Table 3-1.

Table 3‑1: Impacts on Social Services and Utilities

No.	Asset	Measurement	Number
1	Customs office sheds and structures (Governmental)	Number	4

No.

Asset

Measurement

Number

Customs office sheds and structures

(Governmental)

Number

Before the construction work commences, the above identified governmental social services need to be removed and its removal has to be discussed in advance with the concerned organizations, such as Municipalities of Asha Addo town.

Mitigation Measures

Compensate to the owners of utilities lines for the loss of utility lies before the commencement of the construction works and ensure that utility lines are not interrupted due to construction works.

Figure 3‑3:- Loss of Public structures due to the road project

3.8. Impact Due To the Construction of Workers’ Camps

Mitigation Measures

To limit such type of problems direct contacts between the local community and construction workers could be discouraged by putting up construction camps in distant locations from local people, and if the construction camp is built close to local people, admission to the camp should be limited to workers only.
The preconditions to choose the location of the construction workers camp should be more or less similar to any planned permanent settlement that is developed for residential purpose. The selection of camp sites should be done in good co-operation with Local administrations.
Construction camps should also be able to provide some services to its workers, which otherwise would overburden the local public utilities/facilities. Hence, the selection of camp sites should be done in good co-operation with the local population and administration.
Avoid creating construction camp sites on farm and grazing land or near farms.

3.9. Impacts on Air, Noise, and Dust Pollution

Construction vehicles and machinery will cause an increase in dust and exhaust emissions at the project site as well as on existing roads used for hauling materials. Dust and noise pollution problems are considered to be most significant along most sections of the road as many people live and work close to the road particularly in the towns and villages. Construction traffic, particularly the trucks used for the transport of construction materials, will increase traffic flows greatly, and this will proportionally increase the amount of dust and exhaust emissions as well as noise levels. The emissions will contain a large amount of pollutants due to the use of heavy machinery and vehicles.

In addition, excavation and earthmoving operations, mining of quarry and borrow materials and their haulage to the construction sites or processing plants, aggregate production and asphalt mixing activities will generate dust and gaseous emissions that will affect air quality. The dust, exhaust emissions and noise generated by all these activities could affect adjacent residential areas, businesses, crops, education and health facilities, water supply points and religious properties (mosques and churches).

Extraction of rock for aggregate production and masonry works may involve blasting activities, which is likely to generate dust and noise pollution problems around the quarry sites. In addition, operation of stone crushing plants for aggregate production is likely to generate significant dust emission to the surrounding environment. If the quarries and crusher sites are located in the vicinity of settlement areas and/or croplands, dust and nuisance noise can cause significant impacts on the residents around the sites as well as crop production. Continued exposure to dust can cause public health problems like infections of respiratory system and diminished crop yields as well as its quality.

The impacts are localized and on a shorter or medium term, depending on the complexity of the road works and the production of construction materials. In the towns and villages, the impacts are considered as significant whereas the impacts in other places are predicted to be moderate.

Mitigation Measures

Emissions of particulate matters, pollutant gases and noise shall be reduced to acceptable levels by adopting the following measures:

Use of modern and well-maintained equipment (with mufflers where appropriate), regular maintenance of diesel powered machinery and vehicles to reduce excessive exhaust emissions;
Restriction of traffic speeds and applying water regularly on dusty roads in a more stringent way in towns and villages as well as near other sensitive receptors such as schools, health care facilities and religious places;
Regular maintenance of emission intensive plants like stone crusher and bitumen mixer and application of dust suppressant mechanisms;
Locating the aggregate production and bitumen mixing plants at a minimum distance of 3 to 5km from sensitive areas such as residential areas, health units, schools, religious places, and drinking water supply sources;
Regular wetting/spraying water of quarry and stone crusher sites during their operations in order to reduce dust emission and its effects on local population and the surrounding environment;
Construction workers must comply with relevant health and safety standards pertaining to noise and emissions, such as wearing ear protection when operating plants or heavy machinery;
Implementing well-designed traffic management plan that considers traffic safety and working hours for materials transport thereby minimize transport-related disturbances to local residents and road users, and reduce traffic accidents;
Carrying out noisy construction activities during normal working hours, and
Avoiding burning of materials such as tiers, plastic, rubber products or other materials that creates heavy smock, hazardous smoke or nuisance odor and disposing of any volatile chemicals to the air.

The total number of Households and types of their properties and economic activities affected by the project is summarized in Table 3-2 below

Table 3‑2:- Summary of PAPs and types of properties and economic activities affected by the project

SN		Types of properties and/or Economic Activities	# of Households	%
Individual properties
	Residential Houses		40	52.5
	Commercial/Business		19	47.5
Business Houses/commercial type	Retail Shops		5	26.4
	Food and Beverages		12	63.3
	Stores		2	10.3
	Total		19	100%

RAP Implementation Process

RDA will set-up the Resettlement Committee to oversee the implementation of the RAP. The Committee will mobilize the PAPs provides them with all the necessary information at various stages. The main responsibilities of these committees include but not limited to the following

Identify relevant government agencies that are mandated to plan and implement the RAP before the commencement of the road project.
Acquire the land required of the road project
Ensure that resettlement compensation PAPs is fully implemented during the preconstruction period
Conduct regular monitoring and ensure that the objectives of the resettlement plan have met.

The following are steps of Implementation of the RAP:-

4.1. Notification

At this stage, PAPs will be notified about the cut-off-date of land acquisition for the road project. They will also be consulted on their rights and obligations, methods of compensation (land to land or cash payment), assistance entitlements, grievance procedures and participation in implementation.

4.2. Verification of properties of PAPs and losses

All PAPs will be identified and registered with all the necessary information such as records of addresses, type of property, type and level of losses.

4.3. Compensation and resettlement

During this stage, compensation is made in accordance with standard Government policies AfDB Guidelines and the procedures set out in this resettlement action plan. PAPs are entitled to demolish the structures belonging to them if they want to salvage the materials for their new settlements.

District/Town Compensation and Resettlement Committee of each project affected Towns will be established to facilitate and carry out land acquisition process and resettlement activities. At present the respective local administration and town municipality are responsible to identify suitable resettlement sites for displaced households.

Besides, the officials are engaged and committed to support the displaced households by allocating land to build new house at suitable area appropriate to carry out business.

The local administration and municipality committed to ensure the following. Resettlement sites are acceptable to the dislocated people; Allow ample time for planning and development of new sites/villages and the actual evacuation,

Resettlement areas will not be unsanitary so that the new villages will not be exposed to some debilitating diseases, and Resettlement sites will have the same access to public infrastructure as the original site. If additional investments are necessary for social services, RDA and Local Government Administrations will agree on how to finance and establish the service.

4.4. Preparation for clearance of the road corridor

At this third stage the PAPs are prepared for relinquishing their property. Once they got compensation it is important those PAPs should leave the place timely and leave the place for construction. They will be informed through written notification or individual consultations. Displacement of PAPs should be carried out during dry seasons, particularly between December and February, when relocation activities will be less difficult.

4.5. Membership and responsibility of Resettlement Committee

The RAP is implemented by a Resettlement Committee (RC), the formation of the Resettlement committee is initiated as directed by RDA. The membership of the RC shall be made up of representatives from the relevant government offices, include RDA, Town Musicality and District/town administrators who will work all the activities of the RAP together, both during pre and under construction phase of the road project.

Once the Resettlement Plan obtains approval from the Government and AfDB and the Implementation Budget is secured, implementation of the RAP may proceed in the following sequence:-

RDA will constitute a resettlement committee composed of representatives of RDA, The Ministry of Public Works, Land and Housing, Ministry of Agricultural Development, Awdal and Salal Regional governments, and other relevant national government agencies including Ministry of Telecommunication and Technology and Ministry of Environment and Climate Change and representatives from local community.
Members will be well trained on how to harmonize the policies of government of Somaliland to those of AfDB involuntary resettlement, and the provisions of this resettlement Action Plan
Sub Committees will be formed at Lowyaddo, Zeyila, Bon, Garissa and other relevant towns (urban and rural) to facilitate the RAP implementation process at grass roots level.
Grievance Redress Mechanism will be in place by setting-up Grievance Redress Committee;
Implementation of RAP.
Demolition and clearance of the Right off -Way (ROW)

4.6. Organization Structure for RAP Implementation

RDA is the responsible government agency to manage the road project under its project management unit, and all the activities of the project is coordinated with other government Ministries. As one of the many activities of the road project, RDA will oversee the operations of the Resettlement Committee which will be set-up to implement the RAP.

The Resettlement Committee will operate based on the guidelines and detail procedures given by RDA, in cognizance of the national and Banks’ policies on resettlement. The Committee will operate within the project area with frequent contact to regional level sub committees and the project affected persons. This will enable the RC to ensure the smooth implementation of the plan at grass roots level, to tackle possible challenges and to resolve disputes on time.

4.7. Resettlement Committee

The performance of the RC will be further enhanced through the setting up of District/Town level sub committees who will play a role of mobilizing the community, disseminating information and providing constructive ideas to the RC according to the objective conditions of their respective counties. The RC will also be supported by Grievance Redress Committee (GRC) whose main responsibility shall be to address grievances arising from the project implementation. The details of the Grievance Redress Committee are discussed in Chapter 7.

4.8. Implementation Schedule

Time frame for implementing the RAP is based on the assumption that the Road Construction will start to the latest on 2025, and the implementation process of this plan is estimated to last the duration of the road project lifetime. Preliminary works of this plan however should start at least six months before the beginning of the road construction. Schedule and summary of activities is presented in the Table 4-1 below.

Table 4‑1: RAP Implementation Schedule

SN	List of Activities	Calendar Year and Time table in Months
		2024								2025
		5	6	7	8	9	10	11	12		1	2	3	4	5	6	7	8	9	10	11	12
1	Conduct Inventory on PAPs
2	Asset Inventory valuation
3	Road Reserve Confirmation Survey
4	Establish District/town level sub committees and Grievance redress committees
5	Notify & reach agreement with PAPs
6	Vocational Training for PAPs
7	Implementation of Resettlements
8	Demolition and clearance of RAW
9	Grievance Redress
10	Monitoring

PUBLIC AND STAKEHOLDERS CONSULTATIONS AND COMMUNICATION

5.1. Consultation and community participation

A number of consultations have been held with various stakeholders from the very beginning of the design study. During this RAP reparation, the consultations were aimed at familiarizing the public along the project road on various aspects of design, creating awareness to the local community on how the project would impact on their daily lives during and after the road construction. Meetings were held with the Regions and District/Town government officials to sensitize on the project and its effect on social-economic aspect of the community. The issue of the project affected persons as a result of the project was highlighted and participants appraised on the mitigation measures proposed.

Public consultations were held at various locations as determined by administrative boundaries for ease of administration and management of the stakeholder’s composition and record keeping for future reference and analysis.

The meetings were moderated by experts from the consulting team and, to ensure the full understanding and participation of participants on the matter, communication with participants was made via interpreters knowing the local languages.

5.2. Objectives of Consultations

The overarching objective of the consultations was to disclose accurate project-related information to PAPs and other stakeholders encourage their participation in the project cycle as well as solicit information on their perceptions, views, and concerns about the proposed project and its impact on their communities and households. In line with the above general objective, a series of Focus Group Discussions (FGDs) and consultation meetings were held with PAPs and other stakeholders at local levels with the following specific objectives to:

assess the level of knowledge and information about and attitude towards the proposed project among members of project-affected communities, their representatives, i.e., local elected officials and other key stakeholders;
disclose accurate project related information to stakeholders and project-affected communities;
engage with, and ensure participation by, and solicit attitudes from PAPs, stakeholders and project-affected communities on beneficial and adverse impacts of the project and related enhancement and mitigation measures;
identify vulnerable groups and associated needs for special assistance;
identify and prioritize local development needs of project-affected communities;
gather information on preferred modalities for compensation payment and issues related to land acquisition;
gather qualitative as well as quantitative information on viable income generation and alternative livelihood activities including assessment of needs, constraints, and opportunities in which PAPs could engage in order to restore their income and livelihoods in a self-sustaining manner; and
lay the foundation for establishing and maintaining a platform for constructive dialogue and collaborative engagement with PAPs, local officials, and project-affected communities throughout the project cycle.

5.3. Consultation Strategies

Different methods/approaches/techniques were applied by the consulting team to collect information on the community along the project after the stakeholders’ consultations and participatory meetings. The consultative meetings have been interactive and as open as possible for all the participants including Focal Group Discussions (FGD) with the women, youth and vulnerable groups such as the elderly, women and children, orphans and those considered to be the poorest of the poor. The local leaders were encouraged to pay special attention on these categories of PAPs as they should be considered for special assistance under the project.

Approaches: All consultations kicked off with a presentation and disclosure of information about the project. Diversity and inclusiveness of the consultations by involving various key stakeholders and cross-sections of communities (representatives of community members, women, youth, and influential community elders). Separate FGDs were conducted with women. As far as consultations with local government officials are concerned, consultation meetings were held with key officials and relevant elected representatives at local levels.

Methods: A series of Public Consultation meetings were conducted with local government officials and cross-sections of project-affected communities including women and youth in all project-affected towns and districts. Consultative meetings and FGDs were used for Public Consultation meetings, consultative meetings were used for discussion with government officials at various levels, and FGDs were conducted with members of cross-sections of project-affected communities.

The public meetings entailed among others:-

Informing the project affected persons (PAPs) about the project and all its attributes and its’ effects on the community’s socio-economic and the environmental impacts.
Identify and confirm PAPs and establish basis for compensation.
Provide advice and counseling to PAPs to properly utilize compensation money, and use it solely for the purpose of resettlement and restoring their livelihoods.
Confirm the project affected person’s views and preferences on the compensation mode for the loss of assets and restoration of livelihoods.
How to deal with complaints and grievance procedures.

During the consultation, the study team ensured to disseminate the following information to all participants:

The project objectives and justification;
Potential impacts;
Compensation strategy and mitigation measures;
Entitlement categories;
Grievances mechanism; and
Livelihood restoration plan activities.

The FGDs and consultations were carried out primarily to obtain the views of the project-affected communities on various aspects of the project, background information relevant to impact assessment, and identification of mitigation measures. Key agenda points that were presented throughout the FGDs and consultation sessions included the following:

Knowledge and information about and attitude towards the proposed project;
Description of the project, its components, and location;
Anticipated beneficial and adverse impacts from the project throughout its various phases;
Stakeholders’ views and comments on the scope of impacts and identification of any project-related issues not included as well as any other concerns they might have;
Proposed measures for enhancing the perceived beneficial impact and mitigating adverse impacts of the proposed project;
Identification of vulnerable groups and associated special assistance needs; and
Identification and prioritization of community development needs.

5.4. Public Disclosure

Public disclosure of the RAP will be made to PAPs and other stakeholders for review and comments on entitlement measures and other issues in the implementation of the RAP. The purpose of the disclosure is to receive comments and suggestions from PAPs and incorporate appropriate suggestions.

The Public disclosure of this RAP will be made in English languages as well as in Somali Language. It will be disclosed by publishing it in the official Newspapers of Governmental Newspapers; depositing / posting it in a range of publicly accessible places; such as, Town offices, Municipalities and District administration office. Once it is disclosed, the public have to be notified through administrative, community and clan structures about the availability of the RAP documents and be requested to make their suggestions and comments. Comments and grievances made on the RAP by PAPs and other stakeholders will be taken by RDA for consideration.

5.5 Public Consultation

Public consultations as part of ESIA process is useful for gathering environmental data, understanding likely impacts, determining community and individual preferences, selecting project alternatives and designing viable and sustainable mitigation and compensation plans. Public consultation in the ESIA process is undertaken to disseminate information to interested and affected parties, solicit their views and consult on sensitive issues.

5.6 The Consultation Process

One or two days before carried out the consultation meeting, the respective local administration official was informed to arrange a meeting place and to announce the participants to attend the consultation meeting at the specified place, date and time.

The objectives of the public consultation process were:

To inform the public/stakeholders about the details of the proposed road construction project, and
To ask local residents and concerned bodies about the problems they anticipate with the proposed project and how these can be overcome.

The consultation process at the design stage was an initial consultation. More consultations are envisaged prior to project start up and during the project’s implementation and operation phases since the Government through the local administration, encourage community discussions during the implementation of development projects.

The stakeholders for the proposed project were categorised as follows:

1. 1. 1. National level stakeholders – relevant policy makers;
    2. Regional and District level stakeholders – relevant policy and project implementers; and
    3. Local community in the affected Districts/towns.

5.7.Consultation Processes and Outputs

As part of the social assessment public consultations were carried out in the study area, in the Hargeisa, the capital of republic of Somaliland at National level, Regional State and District and/or towns level including, Borama and Zeyila towns. Concerned stakeholders including representatives of the local communities, administrators, representatives of different sector bureaus and different offices of the above specified area were consulted. The main reasons, for carrying the consultation were:

To gather the opinions and attitudes of the community towards the project.
To ensure community participation in such development projects.
To identify anticipated project impact on the socio-cultural life of the community.
To obtain commitment of the respective offices/authorities in providing support and cooperation during project planning and through project implementation.
To ensure that their voices are heard and their views integrated with regard to the project

Discussions and/or meetings have been taken place in Borama (Awdal Region capital), Zyiela (Selel Region Capital). Moreover the benefit of the proposed project had been described to the local communities and administrators adequately and the issues and interest of the communities have been heard and incorporated. The discussions were facilitated by the team of consultants and the discussion points include:

Briefing about the development plan to implement the road project.
Propose possible routes and select the pest route
Discuss about the effect of road development on properties and compensation issues for the PAPs
Determination of town section width and length
Getting the opinions and attitudes of the local community towards the proposed project.
Anticipated positive impacts of the project on socio-economic life of the community.
The need of community participation at different stages of project activities.
The means to avoid and/or mitigate anticipated adverse impacts of the proposed project.

The outcomes of the meetings include:

In general, the consulted officials appreciated the planned road project and highlighted its benefits to the local communities. The meeting participant underlined that construction of the proposed road has a paramount importance for their economic and social development. The local officials’ and community representatives believe that construction of the proposed road will bring socio-economic improvement in the Region and in the country as a whole.
The participants of the community and states also present their interest concerning the route. They all insisted that we follow as much as possible the existing road underlining socioeconomic importance of the route that gives access to a larger settlement around the project route.

Although the discussions were held at different levels, very similar opinions were expressed with regard to most the points of discussion mentioned above. The discussions were also concerned on the negative and the positive impacts of the project. The following points reflect the general opinion of the consulted community on various positive and negative aspects of the project.

The envisaged Zeila-Asha Addo road project will solve the problem as it introduces asphalt road, which is safer and good riding quality road. People are looking for better access to get better health facilities, market and enhance their economy in general. The present road is impacting their desire because it was taking long time to get their neighbouring towns and State and County administration divisions. Hence they expressed that they are glad to see this development project becoming operational in the near future. Apart from employment opportunity, some of the expectation by the people from the project is that it would help in giving training on best income generating practices such as on diversification of smallholders business. Furthermore, the following positive and negative impacts were speculated by the local people /administrators and consultants’ elaborations.

5.8. Summery Consultation Outputs

The summery of consultation conducted in Ziela is summarized as below

Zeila

The Zeila attendants underlined the route should go via Zeyila town as it is the historical port and Regional capital of Selal.
We understand the benefits of the road; therefore they will work together to support this development in terms of security, society and environmental aspects
The centreline of the road should be designed so as to keep trees and houses; otherwise Project Affected Peoples (PAPs) need to get compensation.
The width and length of town sections shall be determined by the design consultant based on the RDA design manual.
The “cut of date” shall be decided after the alignment centreline is known.
PAPs need to be compensated by identifying, registering and implementing compensation process based on the Republic of Somaliland rules and regulations.

Figure 6‑1: Consultations with Local administration @ Zeila

Figure 6‑2: Consultations with Higher Level Government Stakeholders

Table 6‑1:- Public and Stakeholder Consultations Conducted In the Project Area

Date	Participants of Consultation	Place and Venue	Time	# of attendants
Date	Participants of Consultation	Place and Venue	Time	M	F
18/03/2021	Cabinet Members of the Awdal Region, in the presence of the governor.	State Secretariat Hall, Borama Town	11:00 AM	04
14/03/2021	Potential PAPs, community leaders and local administrative officials of Salal Region	Zayila Town	10 AM	16
April15-May 20/2022	Informal discussion, FGD, and consultation With all PAPS in all towns	Asha Addo	During land acquisition survey	600	30

5.9. Summary of Consultations

The idea of the road project was positively welcomed by participants of both Public and stakeholder consultation meetings. They all have expressed their readiness to contribute their share and utmost effort for the success of the proposed road project. Discussants have also expressed their concern regarding issues of displacement and compensation. Summary of Public and stakeholder consultations conducted in various places of the project area is presented as follows.

Table 6‑2: Summary of concerns, issues, fears, expectations, etc. rose by the consulted participants and provided responses by the Study Team

No.	Concerns raised by the project-affected community	Responses provided by the study team
1	PAPs said that they are suspicious of getting adequate compensation and timely	First the Asset Evaluation Committee is supposed to give estimated amount for the property being expropriated. If the PAPs assume this is not equivalent. There is grievance mechanism to appeal and they can appeal to Grievance Redressing Committee to consider it in detail. If this fails and the person thinks it serious they can go to legal court.
2	Is it possible to pick any material to re-use it during demolishment	Yes they can pick their salvage since priority is given to your local people and a certain amount shall be considered to remove and transport your property to the new reception area.
3	What social support do you give to very poor people because of social problem of the people adminsaring family	Female headed, disabled, children headed, aged people do require valuable support
4	Most of the PAPs income based on commercial and business as they are engaged with the same their business may be inturrupted even for a short period of time after getting the new reception area. What is your consideration for such problems	This really depends on the respective low of the country and we did not see any low indicating the same in Somaliland; however as per the funding organization’s low and other African Countries about 3 months incentive shall be paid as an incentive based on the incomes of the respective merchants from the local tax authority income.

5.10. Stakeholder Consultations

Consultations were made with senior administrative Officials of the National, Regional and the District/Towns. Moderated by members of the consulting team, participants were given briefings about the road project in general and the Resettlement action plan in particular. After thorough discussions made on the agendas, all meetings ended in unanimous consensus on the issues raised. Results of consultations conducted are summarized below. Regional and Town administrative officials shall, but not limited to:

have the responsibility of raising awareness of all community members of their respective administrative units on the provisions and directives of declarations of the Republic of Somaliland about economic and physical displacement and the respective compensation for project affected people (PAPs)
Fully participate in compensation, valuation and grievance committees and subcommittees prior and once the road project started and vigorously work to make sure PAPs are properly compensated.
Give special consideration for PAPs with difficult circumstances, e.g. elderly, orphans and vulnerable groups, female household heads, war veterans etc.
make sure that enough land is acquired to resettle PAPs
notify to District and Town officials and obtain their commitment to aware and mobilize PAPs for the appropriate displacement and relocation
include various activities in their annual plans to restore and enhance livelihoods of PAPs in a sustainable manner.

In addition, the consultations resulted in the following agreed action points:

As much as possible, PAPs shall be resettled closer to their previous places
For PAPs who lost their business centers, selection of resettlement areas shall take into account their conduciveness and proximity to markets and potential customers.
Additional plots of land which was private, community, or government held, shall also be acquired for the purpose of quarry sites, borrow pits, detour, crusher sites as well as camp sites during the construction phase of the road project.
PAPs shall be encouraged for membership and to actively participate in compensation, valuation and grievance committees
Religious sites shall not be displaced by the road project and be safely protected. In addition consensus has been reached on the idea that other similar ritual places such as trees, mountains etc. shall not be affected by the road project, and graveyards be given necessary protection from demolition by the road construction.
Water points in rural sections of the road corridor shall never be affected by the road project, and even if they are to be affected, alternative sources of water be developed by the project to provide sustainable access to safe and clean water to the local communities.
During implementation of the RAP, displacement shall be carried out during dry seasons, particularly between December and January, where the routine of farming and economic activities in urban and semi urban sections is relatively normal and less burdensome.

5.11. Public Consultations

People living along the road corridor have long been weary of the poor infrastructure facilities in their areas, and they have all expressed their readiness and relentless commitment to contribute their support for the realization of the proposed road project. During public consultative meetings they have also raised various related issues, and consensus has been reached with the consulting team on the following key issues.

The resettlement and compensation process shall be fair, just and responsive to the challenges they would be facing due to the displacement.
Various working opportunities and income generating schemes shall be designed for them so that they could be benefitted starting from the construction phase of the road project.
They shall be involved in various committees and working groups to have their concerns heard by relevant government authorities. Here they have underlined the crucial role of local chiefs and community leaders in synthesizing the issues and enforcing their practicalities.
Water points along the road corridor, particularly those in rural section shall never be affected by the road project. If possible, the road construction shall take into account upgrading potential water sources for sustainable use of the rural community for a long time ahead.
During resettlement, participants demanded that their housing and other facilities be reconstructed with a better quality, which would befit the road under study.

5.12. Information Dissemination

PAPs were given detail information about all relevant facts, and they have been consulted and regarding the nature and the negative and positive impacts of the proposed project, as well as enhancement and mitigation measures proposed to enhance the positive impacts and avoid and/or minimize the negative impacts. All the necessary information was disclosed to relevant stakeholders, in accordance with the National and AfDB’s Policy to Disclosure and Access to Information. Agreement has been reached with Region and District/Town government officials that PAPs will continue to be engaged through further awareness programs. They will be up-dated regarding nature of impacts on their livelihoods, assets, properties and grievance redress mechanism as well as compensation packages.

Grievances Redress Mechanism

6.1. Need for Grievance Redress

It is human nature people find it hard to lose property and livelihood, even if it is for the good of the public. This feeling of discontent would be further aggravated if their expectations are not met as anticipated or promised in the loss or delay in compensation. Implementation of involuntary resettlement is a complex process, which can involve conflicts, disagreements, and grievances on the part of PAPs and other stakeholders, mainly because it involves the expropriation and compensation of land and other assets. To deal with such emerging issues, a Grievance Redress Committee will be constituted with a membership inclusive of representatives of the PAPs and those of local administrative units.

Both the Government of Somaliland laws as well as the AfDB OS2 include procedures for dealing with concerns or complaints rose by individuals or groups about the project land acquisition and associated mitigations, such as payment of compensation and livelihood restoration measures.

Therefore, to ensure that the basic rights and interests of PAPs are protected, that concerns are adequately addressed and that entitlements are delivered, a Grievance Redress Mechanism has been designed for the Asha Addo road project presented in the following sections.

The most important step in conflict resolution is conflict avoidance. Therefore, the consultative and participatory nature of decision-making under the implementation of this RAP is aimed at reducing the occurrence of disagreements and conflicting positions. For instance, where disagreements do occur, it is important that they are resolved quickly before positions harden and the conflict escalates.

Different approaches may be required according to the level that any conflict has reached. Recognizing that the earlier a potential conflict is recognized and dealt with, the higher the chance of a successful outcome. These phases of conflict development and appropriate interventions can be summarized as follows:

i) Conflict avoidance	Consultation & participation in planning, decision making
Simple disagreements	Informal negotiation, discussion, and mediation
Early conflict development	Consult Regional, Towns/District Resettlement Committee Representative
Conflicting positions taken	Reference to Grievance Redress Committee
Intractable conflict:	Refer conflict to regular court

The best means of addressing any complaints or claims is through dialogue. Thus, when a PAP has a grievance, she/he will first discuss the issue with the Resettlement Committee (RC). If the RC is not able to address the grievance, the complaints should be passed on to the Grievance Redress Committee. The grievance redress system for the implementation of the RAP is outlined below.

6.2. Types of Grievances

It is recognized that, complaints are likely to arise which if not dealt with in a timely and fair manner, could lead to conflict between the community and other stakeholders, notably RAD, but also other Federal and Regional government entities.

Potentially, several types of grievances or disputes could arise that present a risk to a successful implementation of the Project. The following are some of the potential sources of project related grievances:

6.3. Sources of Grievances

In most road projects, the most common issues that can cause delays and calls for dispute resolution mechanism include:

Technical errors during data entry that leads to delays in processing of compensation for the PAP
Misidentification of assets or land owners due to registration errors or inaccurate or misleading information during assets surveys;
Disputes among PAPs over ownership of an affected asset.
Rejection of a compensation award by PAPs as inadequate or not representative of market value
disagreement over the valuation or quality of an asset where compensation is payable;
Emerging unprecedented cultural issues (e.g. relocation of graves, payment for compensation in a polygamous marriage etc)
rates applied for monetary compensation for affected property;
ownership disputes of the land and the assets affected;
Implementation of the livelihoods restoration program (e.g. eligibility and entitlements to restoration measures etc.);
disagreement over the type, quality and quantity of measures applied to achieve livelihoods restoration;
impacts of the construction and operation of Road Project; and
Disagreement over the cut-off date applied.

The grievance redressing procedure is developed to meet the Government of Somaliland legal requirements relating to grievance resolution and international requirements for grievance management and is in line with AfDB’s Operational Safeguards. The following section sets out the procedures to be followed to manage grievances caused as a result of Asha Addo road project implementation.

6.4. Grievance Management Approach

Although it remains largely informal and traditional, communities in the Project area have effective community-based conflict resolution processes. For some of the potential conflicts that may arise in relation to the Project’s land acquisition, it is both less expensive and more appropriate to consider the use of a traditional conflict resolution mechanism. For example, issues such as PAPs’ land ownership (title deed) and boundaries between plots owned by different PAPs can best be resolved through traditional conflict resolution processes within the community. To enhance the effectiveness of the community-based conflict resolution processes, RAD will work with Local administration and community elders and develop a detailed protocol for their use.

RAD shall also maintain a transparent process that is gender and special needs-responsive, culturally appropriate, and easily accessible. This system shall be available to all project-affected people at no cost and without retribution.

The proposed approach for grievance resolution provides multiple entry points to the system. For minor grievances between PAPs, or between PAPs on the one hand and other community members on the other, RAD will refer the matter to relevant community elders for resolution. If the grievances are deemed major, then RAD will facilitate mediation or negotiation between the parties.

Where a grievance relates to RAD’s management of the RAP process, the community-based resolution is not appropriate. Grievances relating to compensation will be dealt with in accordance with the grievance mechanism set out in this RAP. Project construction and operation impacts shall be managed in accordance with the grievance redress mechanisms prepared and presented below. Any grievances rose to RAD staff relating to construction or operational grievances will be referred to the appropriate entity in accordance with the grievance mechanism.

Based on consensus, the procedures will seek to resolve issues quickly in order to expedite the receipt of entitlements, without resorting to expensive and time-consuming legal actions. If the grievance procedure fails to provide a result, complainants can still seek legal redress procedures.

6.5. Grievance Redress Mechanism

Grievances relating to land acquisition, livelihood restoration, compensation, and related matters will need to be separated from grievances relating to the impacts of the project construction and operation on local communities. The former concerns the Project Office, the local government, and PAPs and/or their representatives. However, the latter mainly concerns the Contractor and subsequently, the developer (RAD), although the Project Office will continue to play a role in the resolution of such concerns.

Grievance Redress Committee (GRC) will be established with a membership consisting of representatives from PAPs, local administration units, RAD, etc. Grievances should be settled amicably whenever possible. The main function of the Grievance Redress Committee is to provide a forum for the PAPs to air their dissatisfaction arising from the compensation or implementation process of the project. This is an informal forum within the Resettlement Committee to fast-track addressing of emerging issues in a project that can derail a smooth implementation of a project. The Committee is to receive complaints from the PAPs through the project office either verbally or in writing and they endeavors to address the issue to the satisfaction of the complainant.

The redress committee will compile registers of all complaints received from the PAPs at the project office, the actions taken and the decisions arrived at. Initially, the Resident Engineer and his staff with secretariat of the GRC will handle the complaint. The GRC will examine the case (by hearing the testimonies of both parties) and pass its decisions and inform the PAP. If required, the GRC would undertake a site visit and ask for relevant information from the project Authorities, etc. Failure to arrive at a satisfactory answer, then the RE will refer the matter to the GRC that meets periodically. Whereas the GRC is constituted of people outside the Project Office of the Resident Engineer, the latter will be a coopted member together with the Contractors representative for expeditious resolution of the complaints regarding the project.

The GRC plays a critical role of providing PAPs with a fair playground to present their complaint over the compensation or its implementation process. Initially, the Resident Engineer and his staff with secretariat of the GRC will handle the complaint. If the matter is not resolved to the satisfaction of the complainant, then the RE will refer the matter to the GRC that meets periodically. This is an informal forum to fast-track addressing of emerging issues in a project that can derail a smooth implementation of a project. The Committee may receive complaints from the PAPs through office of the Resident Engineer verbally or in writing and it tries to address the issue to the delight of the complainant. If the issue could not be resolved amicably on time, the complainant then may have recourse to the Resettlement Committee. And if not yet satisfied by the decision of the RC, the complainant reserves the right to seek redress from the Court of law, but this option is lengthy and costly in most cases.

The findings of the GRC are binding on the RC. All complaints received by GRC will be recorded and logged into the complaints register. Under the proposed project, a set of forms are developed to be used for recording grievances, and the actions taken are prepared, as listed below (if required shall be translated into the local language).

Grievance Statement Form
Grievance Receipt Acknowledgement Form
Grievance Investigation Form
Grievance Investigation Outcome Form

The grievance mechanism applies to all complaints related to Asha Addo road project activities; and is comprised of the following steps:

Outline of the Grievance Redress Mechanism Steps

Step 1 – Receive and Record Compliant (using the Grievance Receipt Standard Form). The grievance shall be registered in a ledger/ log book at the project site.
Step 2 – Review Complaint and Allocate Actions (Complaints are screened, and actions then are allocated to investigate and resolve the grievance or refer the matter to the next level)
Step 3 – Notify Complainant of Proposed Resolution (notify the complainant that the complaint has been received, how it is being dealt with, by whom and an approximate estimate of how long the process might take (this must happen within 5 days).
Step 4 – Take Action and Update Complainant (undertake the proposed actions for resolution and update complainant when it is complete).
Step 5 – Closeout & Lessons Learnt (occurs when both parties are happy with the proposed solution).
Step 6 – Update Project Grievance Records (ongoing) (using standard forms, grievances will be maintained and stored including information for any outstanding actions)
Step 7 – Reporting (to concerned/ defined parties).

Detailed feedback and Grievance Redress Mechanism (GRM) will be prepared by RAD. It will ensure that the grievance mechanism will include the necessary procedures for disclosure and resolution of environmental and social-related grievances of the project.

Based on the AfDB’s Grievance Redress Service (GRS), project-affected communities and individuals may submit complaints regarding a Bank-financed project to the project grievance redress mechanism, appropriate local grievance mechanism, or the Bank’s corporate GRS. The broad procedures for dealing with grievances and complaints are illustrated schematically in Figure 9.

6.6. Dispute procedure

A PAP appeals grievance Local Grievance committee representative

Grievance addressed and PAP satisfied, no Further Action

Local Committee deals with the issue, makes decision and notifies to complainant within 1 week

Unresolved grievance referred to District Redress Committee by the Local PAP Committee or complainant

No Further Action

Grievance addressed and PAP satisfied

Town/District Redress Committee deals with the issue, makes decision and notifies to complainant within 1 week

Resettlement committee receives the grievance from the Grievance Redress Committee, deals with the issue, makes decision and notifies to complainant within 1 week

Complainant not satisfied-then LEGAL ACTION

Figure 7‑1: Typical Grievance Redress Procedures

6.7. Role of PAP’s Representatives in Grievance Redress Committee

The involvement of PAPs in Grievance redress committees is very important in resolving disputes and complaints locally through engaging with their fellow affected community members. Among the many, they play the following key roles.

Accept the grievances of the PAPs and provide an early solution to those they are able to;
Bring in serious matters to the attention of the RC; and

Inform the complainants about the progress of their grievances and the decisions made by the RC.

Socio-Economic Condition of the Project Area and Project Socio Affected Persons

7.1. Background

As part of the processes of preparing the RAP for Asha Addo road Project, a socio-economic baseline survey and census enumeration of Project Affected Households (PAHs) and registration of property affected by the proposed Road Project was completed between April15-May 20, 2022. The census and socio-economic baseline surveys of the project area involved 630 households.

7.2. Administrative Setting

The Zeila-Asha Addo road project route is envisaged to link two towns, within one Administrative unit namely the selal Region (newly established Region); which is not officially/legally approved as it was within the Awdal Region. There are 2 towns across the project road; some of them serving as district of each Regions. Zeyila is serving as Headquarters of the current Selal serve Regions.

Currently the Awdal Region is conducting the overall administration including Selal; however in terms of sector and sectorial administration Selal is taking responsibilities including all sectorial disciplines such as Education, Health, Fishery etc.

Table 8‑1: Settlement alongside the Road Corridor

Serial No	Village/Town Name	Geographical location UTM Zone 38N Datum WGS84
Serial No	Village/Town Name	Easting	Northing	Elevation(m)
1	Zeyila	333469	1255372	2
2	Ashado	329751	1235409	4

7.3. Population and Demography

The size and demographic features of population are important variables in the equation of the development process, for they determine the pattern of resource utilization. Accordingly, this section presents the population profile traversed by the road project.

There is no exact statistics defining the demography of the Country, according to the estimates prepared by the Population Department of the United Nations the population of 16,843,368 in the year 2019. The growth rate, birth rate, death rate and average life expectancy is 6.23% (2008), 25.27 births/1,000 population (2011 est.), 8.23 deaths/1,000 population (July 2011 est.) and 62.4 years (2008) respectively. The population of Awdal region, where the project road corridor is located is estimated at 673,264 (UNFPA 2014).

7.4. Economic Activities and Livelihood

Livestock rearing is the major source of wealth and prestige and power. Sale of livestock and livestock products provide the main financial capital for agro-pastoralists. This is practiced throughout the year due to the type of livestock reared and fed using crop fodder in paddocks (semi-zero grazing) even during the dry season. Normal rains ensured normal pasture, fodder and crop harvests, which translated to good livestock body conditions, improved livestock production, enhanced marketability of saleable animals and increased incomes and purchasing power of HHs. In spite of this, livestock production is constrained by lack of veterinary services, with agro-pastoralists relying on indigenous knowledge to manage parasites. In some instances, agro-pastoralists purchase drugs from veterinary centers. Women from all wealth groups sell most of livestock products. Those in the middle and better-off wealth groups engage in petty trade and in small business, like selling food, sea cucumber trade, charcoal selling and transportation.

The Coastal Zone dwellers: Livestock rearing in the coastal zone include rearing of camel, sheep and goats. During the summer seasons as the temperature of the coastal zone reaches up to 45^oc and the people move in to the mountainous zone.

After years of livestock losses from droughts and multiple crises, fish have become a lifeline source of food for nutrition and income for coastal communities. The coasts sandy soils are not suitable for crops, and fishing and livestock are the main livelihoods.

Other Economic Activities: - According to locals, livelihood of citizen at the project areas are also engaged on traditional construction materials mining , catering services and other small scale business which are largely practice by town residents.

Table 8‑2: Distribution of sources of income of respondents

SN	Sources of Income	# of Households	%
1	Trade	180	30.50847
2	Service Provision	114	19.32203
3	Pastoralist	169	28.64407
4	Wage Labor	44	7.457627
5	Public Service	61	10.33898
6	Others	22	3.728814
	Total	590	100

Source: Primary data obtained source based on structured questioner

7.5. Income Distribution

Despite the untapped economic potential in the area, economic transactions are very poor and the livelihood most of the people in the project area is below poverty line. In addition to the over twenty years of war for independence which ravaged the economy of the country, the project area is particularly constrained by the lack of infrastructure facilities specially road which inhibited the citizens from being engaged in various economic activities and improving their livelihood. Income distribution of respondents is summarizing in table 11 below.

Table 8‑3: Distribution of Annual income earned by responding Households

Income Range (USD)/annum	No. of respondents	Percentage (%)
<1,000	403	63.96
1,000-2,000	89	14.12
2,000-3,000	65	10.33
3,000-4,000	42	6.67
4,000-5,000	31	4.92
5,000+	0	0

Source: Primary data obtained based on interviewing

7.6. Social Services and Infrastructures

It has been observed during discussions in the consultation meeting that access to and utilization of services within the project area and its environs are very limited except telecommunication. In most cases people travel far to access almost any type of service, safe water supply points, health facilities, market centers, grain mill sites, access to credit facilities and the like, for example people living in the transaction area between Zeila and Asha Addo shouls travel 5-11kms to get those services. All these scenarios negatively impacted the health and wellbeing of family members in general and most importantly women including girls and children.

7.7. Transportation

All weather roads, mainly of loamy soils, form the main transport systems in project route corridor. These roads run across river beds, hills and mountainous terrain and are inaccessible during the wet seasons when flash floods render these roads impassable. The situation worsens where rivers/streams intersect. This consequently increases transport costs which indirectly affect the market prices of essential food commodities and a decrease in the general livelihoods of the local communities.

7.8. Telecommunication

Most of the villages have access to cellular services. About 4 cellular agencies (Telsom, Telecom, Somtel, and Nation link) operate in the Project route corridor. Communication services facilitate remittance flows, trade, information and local money transfers. Pastoralists benefit from the use of telecommunication services by receiving and passing information on rainfall and pasture availability, water tracking and market prices of commodities.

7.9. Water Infrastructure

The main water sources in the project route corridor are water catchments and shallow wells. Most of the better-off and part of the middle, particularly those bordering Coastal low lands, have at least 1 berkad. However, about 20-30% of the berkads were in poor condition (cracked) due to ageing and a small number had been rehabilitated. During most of the year, water is available freely for livestock and for human use, but in the dry (Jilaal) season, water is purchased (at sometimes high costs) for 3-4 months.

Table 8‑4: Availability of Different Water Schemes alongside the project road Towns

No.	Town/village	Hand dug well	Shallow well	Deep well	Ponds	Barked
1	Zeila			√
2	Ashado		√
Total

7.10. Health

Health and sanitation condition in an area is an indicator of the living standards of the communities concerned. However, the ratio of health facilities to population in the project is by far below the WHO's standard. The number of health institution in the same are also far below the required size, and accordingly become a major cause for a low health coverage. Locations of health institutions are other problems to improve health coverage. The long distance to the health institution and lack of transport facility seriously limit health coverage. Moreover, rapid population growth could not cop-up with the number of health institutions being constructed. A substantial size of health infrastructures are said to be not operational due to lack of health professional, lack of medical supply and equipment and in some case lack of repair and maintenance of facilities.

The prevalence of HIV/AIDs, which is one of the deadly diseases which have no cure so far, is in the project urban areas. It is believed that communicable diseases will be a major concern during construction since the construction activity attracts an influx of construction work force that will be intermingled with local community. More data and information will be collected to discuss in detail about health and sanitation situations of project affected area and the possible mitigation measures how to mitigate project induced health problems. Health Facilities alongside the road project is depicted under Table 7-5.

Table 8‑5: Health Facilities alongside the project road

No.	Town/village	Health Post	Health Centre	Clinics	Hospital
1	Zeila	0	1	2	0
2	Ashado	0	1	0	0
Total		0	2	2	0

Source: Awdal Region Health Office

Table 8‑6: Health Professionals alongside the road project

No.	Town/village	Doctors	Nurses (all type)	Pharmacist	Technician (all type)
4	Zeila	1	8	3	4
5	Ashado	0	3	1	1
Total		1	11	4	5

Source: Awdal Region Health office

7.11. Education

As per the preliminary assessments conducted during reconnaissance, the rural parts of Somaliland in general and that of the project route corridor in particular has limited access to education. The illiteracy rate was more pronounced among female community members than males.

Both formal and non-formal schools are available in most villages, although the quality of formal education is low due to lack of qualified teachers, limited equipment, limited access and poor educational infrastructure. Enrolment and attendance is regular for children in the better-off wealth group, while children in the poor and middle wealth groups attend school irregularly or do not attend school at all. More boys (60%) than girls (40%) attend formal schools. The better-off send at least 2 boys and 1 girl to school, whereas the poor and middle only send 1 boy or girl to formal schools. As much as children from the better-off wealth group access more educational opportunities, lack of secondary schools limit progression.

The distribution of schools and school facilities is therefore an indicator for the level of fulfillment of these basic rights of the communities concerned. The quality of education such as qualification of teachers, student-to-teachers ratio, student- to-classroom ratio, student-to-book ratio, commitment of teachers for their profession, etc. is also important parameters. According to previous studies, student-to-classroom ratios, qualification teachers and their commitment, school facilities, etc. are said to be not good. Data on this issue is not currently available and attempts will be made to collect those data and subsequent analysis will be made during detailed study phase of the project.

It may be good to reach the substantial number of pastoralist community through developing an alternative basic education centres in their areas. This strategy may help achieve a higher impact on the remote and marginalize communities.

Table 8‑7: Number of Schools of all category alongside the project road

No.	Town/village	Elementary	Secondary	Higher Education
1	Zeila	1	1	0
2	Ashado	1	0	0
Total		2	1	0

Source: Awdal Region Education office

ORGANIZATIONAL AND INSTITUTIONAL RESPONSIBILITY

Road Development Agency (RDA), under the Ministry of Transport and Road Development is the implmenter of this road project, and it will be the primary responsible agency for ensuring that the RAP is implemented in accordance with the agreement reached with the bank. However, other relevant government agencies (national and state) will also be involved in the in the process. All involved will have roles to play in accordance with the authorities and responsibilities vested in them by the laws of the republic of Somaliland.

8.1. Ministry of Transport and Road Development

This Ministry, for which RDA is accountable, is responsible for authorizing and approving the financial resources for the road project. It is also responsible for harmonizing implementation of the RAP with other government policies.

8.2. Ministry of Public Works, Land and Housing

8.3. Awdal and Salal Regional Governments

Ensuring that community members of the states fully accept the provisions and directives of declarations of the, Republic of Somaliland about displacement of and compensation. The Ministry through it’s the National Committee, also also fully participate in compensation, valuation and grievance committees once the road project started and vigorously work to make sure PAPs are properly compensated. Members of the state administration will also make sure that enough land is acquired to resettle PAPs.

Zeila-Asha Addo Road (22km)

2.2.2 Environmental and Social Assessment Procedures, November 2015

3.7 Impact on Public Social services

5.2. Objectives of Consultations

5.6 The Consultation Process

5.8. Summery Consultation Outputs

5.9. Summary of Consultations

7.3. Population and Demography

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