environmental and social management...

FINAL DRAFT MAY 2019

MINISTRY OF HOUSING AND LANDS | GOVERNMENT OF THE COMMONWEALTH OF DOMINICA

ENVIRONMENTAL AND SOCIAL

MANAGEMENT FRAMEWORK DOMINICA HOUSING RECOVERY PROJECT

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TABLE OF CONTENTS ACRONYMS ............................................................................................................................................... 3

FOREWORD............................................................................................................................................... 4

EXECUTIVE SUMMARY ........................................................................................................................ 5

SECTION 1: INTRODUCTION ......................................................................................................... 15

SECTION 2: PROJECT DESCRIPTION ......................................................................................... 16

2.1 Background ................................................................................................................................. 16

SECTION 3: POLICY FRAMEWORK FOR ENVIRONMENTAL AND SOCIAL ISSUES ..... 19

3.1 National Laws and Regulations .................................................................................................. 19

3.2 World Bank Safeguard Policies .................................................................................................. 20

3.2.1 Environmental Policies ....................................................................................................... 20

3.2.2 Social Policies ..................................................................................................................... 20

SECTION 4: PROJECT IMPLEMENTATION ARRANGEMENTS............................................ 22

SECTION 5: ENVIRONMENTAL AND SOCIAL CONDITIONS IN THE PROJECT AREA . 26

5.1 Environmental Conditions and Issues ......................................................................................... 26

5.2 Social Conditions and Issues....................................................................................................... 29

SECTION 6: ENVIRONMENTAL & SOCIAL MANAGEMENT - ADDRESSING SFEGUARD

ISSUES 38

6.1 Beneficiary Selection Process ..................................................................................................... 38

6.2 Informal Occupancy ........................................................................................................................ 42

6.3 Environmental and Social Management Plan (ESMP) for House Construction ............................. 42

6.4 Grant Agreements with Beneficiary Households ............................................................................ 43

6.5 Indigenous People – The Kalinago ................................................................................................. 45

6.6 Forest and Timber Resources .......................................................................................................... 46

6.7 Cultural Heritage ............................................................................................................................. 47

SECTION 7: COMMUNICATION: CONSULTATION, INFORMATION DISSEMINATION 48

SECTION 8: CAPACITY BUILDING .............................................................................................. 50

SECTION 9: GRIEVANCE REDRESS MECHANISM (GRM) ..................................................... 51

9.1 GRM Scope and Summary ............................................................................................................... 51

9.2 World Bank Grievance Redress System ......................................................................................... 53

SECTION 10: MONITORING AND REPORTING ...................................................................... 54

SECTION 11: BUDGET REQUIRMENTS FOR ESMF IMPLEMENTATION ........................ 56

Annex 1: Relevant National Legislation, Policies, and Plans ................................................................. 57

Annex 2: Map of Dominica’s Health Districts ....................................................................................... 61

Annex 3: Map of Dominica’s Village Districts ...................................................................................... 62

Annex 4: Guidelines for World Bank Code of Conduct for Contracted Entities .................................... 63

Annex 5: Role of Direct Players and Key Partners in the Implementation of Safeguards...................... 65

Annex 7: HRP Application Form ........................................................................................................... 67

Annex 8: HRP Environmental and Social Management Plan (ESMP) for Small Construction and

Rehabilitation Activities ......................................................................................................................... 72

Annex 9: Project Results Framework – Dominica Housing Recovery Project....................................... 93

Annex 10: ESMF Mitigation Table ........................................................................................................ 94

Annex 11: Housing Recovery Project ESMF: Consultations ............................................................... 106

3 | P a g e | E S M F F i n a l D r a f t 3 M a y 2 0 1 9

ACRONYMS

need to cross check on final review

BDA Building Damage Assessment

CCA Copper Chrome Arsenate (timber treatment chemical)

CDEMA Caribbean Disaster Emergency Management Agency

CPA Country Poverty Assessment

CREAD Climate Resilient Emergency Agency for Dominica

DSWMC Dominica Solid Waste Management Cooperation

EC$ East Caribbean Dollar

EIA Environmental Impact Assessment

ESMF Environmental and Social Management Framework

ESMP Environmental and Social Management Plan

EU European Union

FM Financial management

GDP Gross domestic product

GRM Grievance Redress Mechanism

GoCD Government of the Commonwealth of Dominica

HH Household

HRP Housing Recovery Project

HTF Housing Task Force

ICT Information and Communication Technology Unit (the Ministry of

Information, Science, Telecommunications and Technology)

IST Implementation Support Team

M&E Monitoring and evaluation

MIS Management Information System

MoF Ministry of Finance

MoHL Ministry of Housing, Lands and Water Resources

MoKA Ministry of Kalinago Affairs

MoP Ministry of Planning and Economic Development

NGO Nongovernmental organization

NP National Park

PAD Project Appraisal Document

PDNA Post‐Disaster Needs Assessment

PDO Project Development Objectives

PID/ISDS Project Information Document/Integrated Safeguards Datasheet

PIU Project Implementation Unit

PPD Physical Planning Division (Ministry of Planning and Economic

Development)

TAC Technical Assistance Center

ToR Terms of Reference

VNA Vulnerability Needs Assessment


FOREWORD

Adamant to resolve the people’s housing needs on island, the Honorable Prime Minister of Dominica with

Cabinet set forth an agenda to build the destination better with resilient homes, particularly for the more

vulnerable people. This would form part of the Housing Revolution set forth by the Government of the

Commonwealth of Dominica (GoCD) to accommodate residents who lost their homes following Tropical

Storm Erika in 2015, where villages in high risk locations were swept away from flooding and massive

landslides. The World Bank (WB) joined in this effort with a grant subsidy for a Housing Recovery Project

(P166537) to focus on home-owner driven rebuilding in-situ of destroyed houses for 1,700 of the most

vulnerable households, who will be mandated to apply the WB’s environmental and social safeguards in

light of constructing resilient homes. The Housing Recovery Project (HRP) complements the role of relief

and humanitarian partners who have been addressing the first phase of housing recovery with a focus on

temporary and transitional shelter, roof repairs, and minor repairs conducted by house owners.

The Environmental and Social Management Framework (ESMF) is one of many documents that guides the

implementation of Dominica’s Housing Recovery Project. It outlines the inclusion of environmental and

social safeguards of the World Bank from the preparation and readiness phase to the complete closure phase

of the project. In essence, the objective of the ESMF is to serve as a practical tool during project

implementation and monitoring, that will provide operational guidance regarding the management of

environmental and social issues in housing reconstruction to ensure compliance with the relevant laws and

regulations of Dominica and World Bank safeguards policies.

The ESMF overarching context remains applicable with the following supporting HRP main documents:

Project Appraisal Document (PAD); Project Operations Manual (POM); Indigenous People’s Plan (IPP);

Grievance Redress Mechanism (GRM); and a Communication Strategy. Numerous direct players and key

partners at the institutional and community levels are noted in the ESMF.

This document is the result of consultations between various government ministries and departments,

particularly the Ministry of Housing and Lands, the Physical Planning Division, the Kalinago Council, the

World Bank HRP Team and Consultants including the WB safeguards consultants and the IST Senior

Safeguards Advisor, CREAD, direct players and key partners. The ESMF was finalized based on review of

all feedback received by the HRP – Project Implementation Unit. Gratitude is extended to all who

contributed to this framework.

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PROJECT NAME: HOUSING RECOVERY PROJECT - HRP

PROJECT ID: P166537

DOCUMENT NAME: HRP ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK –

ESMF

PROJECT SLOGAN: REBUILD HOUSE, STRENGTHEN HOMES - AIDE’ WAGER KAI


EXECUTIVE SUMMARY

This document presents the Environmental and Social Management Framework (ESMF) for the Dominica

Housing Recovery Project (P166537), which is open to all residents of Dominica. The project overall

development objectives are to contribute both to the recovery of housing for households affected by

Hurricane Maria, and to improve the application of resilient building practices in the housing sector. The

objective of the ESMF is to serve as a practical tool during project development, implementation,

monitoring and reporting, that will provide operational guidance regarding the management of

environmental and social issues in housing reconstruction to ensure compliance with the relevant laws and

regulations of Dominica and World Bank safeguards policies.

Background

The Commonwealth of Dominica is a small upper‐middle‐income country covering 751 km2 with a

population of about 73,500 (2011 Census). On September 18, 2017, Hurricane Maria hit Dominica as a

Category 5 storm with catastrophic effects. A Post‐Disaster Needs Assessment (PDNA) from November

2017 estimated total damages at US$931 million and losses at US$382 million, amounting to 226 percent

of Dominica’s 2016 GDP. The identified needs for reconstruction and resilience interventions to ‘build

back better’ amount to US$1.37 billion. The storm affected 90 percent of the housing stock, with more

than 4,500 houses destroyed and over 20,000 partially damaged. The sector sustained US$354 million in

damages and US$28.5 million in losses, and the PDNA identified US$519.7 million in recovery needs.

The Need for ESMF in Housing

Critical to house stability or vulnerability is the type of structure, design, location and other environmental

and social considerations. It is for this reason that the World Bank environmental and social safeguards

alongside the nation’s governing framework form a fundamental role throughout the project development

and implementation phases. More specifically, the implementation of the ESMF will reduce grievances,

improve project design and implementation efficiency, and reduce excessive cost to the home owner.

Project Components

The Housing Recovery Project (HRP) complements the role of relief and humanitarian partners who have

been addressing the first phase of housing recovery with a focus on temporary and transitional shelter, roof

repairs, and minor repairs conducted by house owners.

The project has three components. Component 1 (US$3.5 million) provides support for housing recovery

systems and capacity building. This includes (i) the establishment of regional Technical Assistance Centers

(TACs) to provide both technical advisory services to homeowners on demand and planning control

functions, and (ii) development of management information and monitoring systems. Component 2

(US$33.5 million) will provide subsidies in the form of small grants for owner‐driven reconstruction or

replacement of houses that were classified as ‘destroyed’. Eligible homeowners would use the grant and

their own resources, if necessary, to undertake the rebuilding to a design of their choice. Approximately

1,700 households with completely destroyed homes (of which 35 percent are expected to be female‐headed)

will receive financial support in the form of a subsidy from the project toward a future house. Component

3 (US$3 million) will finance a Project Implementation Unit (PIU) under the Ministry of Housing and

Lands (MoHL) to be responsible for the overall implementation and coordination of the project activities

(including safeguards, procurement and financial management). It will also finance an Implementation


Support Team (IST) within the Ministry of Finance (MoF) to provide implementation support on

procurement and safeguards to the PIUs of all World Bank‐funded projects in Dominica.

Policy Framework for Environmental and Social Issues

The Government’s legislation, policies, plans (Annex 1), and guidelines applicable to the project fall into

three broad categories comprising (i) legislation, policies, and strategies related to overall environmental

protection, climate change mitigation, and disaster management, (ii) legislation, policies, and guidelines

related to land and physical development, and (iii) World Bank (WB) environmental and social safeguards,

including for indigenous peoples (the Kalinago). During project appraisal, the following WB safeguard

policies were found to apply to the project. Environmental safeguards are: OP/BP 4.01 Environmental

Assessment, OP/BP 4.09 Pest Management, and OP/BP 4.11 Physical Cultural Resources. Social safeguard

is: OP/BP 4.10 Indigenous Peoples.

OP/BP 4.10 Indigenous Peoples is triggered since the Kalinago are recognized as indigenous people by the

Government of Dominica, and also meet the World Bank criteria for applying the Indigenous Peoples

Policy. Consultations have been held in the Kalinago Territory, and an Indigenous Peoples Plan for the

Kalinago Territory has been drafted, and has informed this ESMF.

Project appraisal found that OP/BP 4.12 on Involuntary Resettlement is triggered on a precautionary basis

to address instances of economic displacement and/or temporary involuntary resettlement. Nevertheless,

currently there has been no justification to apply it. The project will be providing grants to households based

on an ‘owner-driven’ housing reconstruction model, where the beneficiary is involved in and agrees to the

specifics of the design and siting of reconstruction activities in-situ, and not requiring temporary relocation,

and has the option of choosing not to receive project assistance. The project’s housing reconstruction

activities are all demand-driven, thus totally voluntary, and will therefore not involve involuntary land

acquisition or resettlement. Similarly, the instances of economic displacement and/or temporary

involuntary resettlement that could potentially require application of the Policy are not possible to

materialize. This could be the case where a new core house is to be built on a different footprint on the

same site to mitigate site hazards, since this could affect its own crops or other assets. Under a demand-

driven approach where a house owner is voluntarily agreeing to reconstruct a house on his/her own land,

the potential affectation of its own crops or economic trees is not considered economic displacement eligible

for compensation. If a house owner considers the requirement to site a new house for safety reasons in a

different location on his/her land to be onerous, he/she has the option to refuse project assistance to rebuild

the house.""

Project Implementation Arrangements

The Government of Dominica has the overall responsibility for implementing the project, including its

social and environmental management, with the PIU guiding project activities. The PIU will include

environmental and social specialists for providing oversight of and compliance with environmental and

social requirements of the contracted entities, project beneficiaries and contractors. This will be aligned

with the housing construction laws of Dominica as per requirements and processes of the Physical Planning

Division and their supporting framework in the Ministry of Housing and Lands. Where feasible, they will

be supported by the IST and guided by the Climate Resilient Emergency Agency for Dominica (CREAD)

with high level oversight by the Housing Task Force.


In the localities where the project financed housing reconstruction activities will take place, the institutional

counterpart will be Village Councils (in the Kalinago Territory the Kalinago Council and Hamlet

Development Committees). The councils are popularly elected bodies empowered by law to regulate and

administer affairs in their respective areas. Health and Village Districts island wide are mapped in Annexes

2 and 3 respectively. Contracted entities under the project and beneficiaries have various roles in the

execution of safeguards throughout the project implementation that are outlined in this framework. Major

contracted entities to support implementation include: (i) Technical Services (architects, engineers) who

will support eligibility screening processes prior to construction, and will also facilitate the home owner

driven process once the beneficiaries are identified; (ii) the firm responsible to set up a database to support

the housing program through MIS and other services, who will commence before and continue during

construction phases; and (iii) the Design and Supervision Firm who will commence once beneficiaries are

known and throughout decommissioning of site/closure of construction. Other key partners include but are

not limited to government departments, statutory bodies, banking institutions, NGO and civic organizations,

religious, and academia/professionals. All consulting entities will follow a code of conduct directed by the

PIU noted in Annex 5.

Environmental and Social Conditions in the Project Area

Environmental Conditions and Challenges

Environmental conditions and challenges of relevance for the housing reconstruction activities derive in

part from Dominica’s vulnerability to natural disasters from weather-related and geophysical events due to

its topographic features and location within the Atlantic hurricane belt. This is compounded with the seismic

and volcanic risks associated with tectonic plates bordering the island chain. Moreover, the island’s

mountainous, rugged landscape and extensive hydrological system creates significant engineering

challenges to reducing infrastructure vulnerability to natural disasters and climate change.

Separate from this important challenge that results for instance in landslides and flooding are important

risks that must be minimized on location of houses. In addition, important environmental challenges involve

disposal of debris including the possibility of safe handling and disposal of asbestos and access to aggregate.

Another important challenge includes pest control. Though least likely, chance finds of physical cultural

resources as well as buried bodies may be found.

Hurricanes. The project’s support for ‘building back better’ through technical assistance and advice on

hurricane resilient building techniques for both the house reconstruction directly funded by the project, and

for home owners undertaking repairs on their own, will contribute to mitigate the destructive impacts of

future hurricanes and tropical storms. Separate from this, during the hurricane season, there is the possibility

of a storm occurring during construction which may cause temporary disruption on project implementation.

Volcano and Seismic Risks: In addition to risks associated with hurricanes, volcanic activity and

earthquakes present a historically minor, but continuous hazard to the housing sector.

Geotechnical and Hydrological Risks (landslide or flooding). The exposure of specific housing sites to

geotechnical and hydrological risks (landslide or flooding) will be appraised during the building

assessments to determine potential eligibility for housing reconstruction assistance, and if the risk is

assessed as unacceptable, even after site remediation, the house owner will be referred to other housing

programs.


Access and Sustainable Use of Aggregate and Timber (use of forest and river resources). Dominica

has the most extensive forests in the entire Eastern Caribbean covering about 60 percent of the island and

365 rivers. National Parks and Forest Reserves cover about 22 percent of Dominica, and approximately 27

percent of the island’s forests are designated as protected, inclusive of a UNESCO World Heritage Site,

Morne Trois Pitons National Park. Hurricane Maria’s winds and intense rainfall caused widespread damage

to the forest system and increased material deposit throughout the island river bed. An estimated 10 to 20

percent of the forest trees were knocked down.

Timber is one of the basic construction materials used in the more remote rural areas. Use of downed trees

or local logging for housing reconstruction must be guided by the Forestry, Wildlife and National Parks

Division to reduce the risk of unregulated deforestation, and would at the same time reduce dependency on

imported lumber and create local employment.

To avoid negative environmental impacts from quarrying in the vicinity of the communities where project

activities take place, the aggregate (sand and gravel) required for house construction will only be supplied

from existing approved quarries. Another natural resource at risk during the construction is the use of river

stones. Following the hurricane, the GoCD embarked on extensive dredging of some rivers. Material

removed in the dredging of rivers may be used, provided that government approves the quality and quantity

by the respective entities. The Forestry, Wildlife and National Parks Division is a key partner in this process.

Debris Management. Disposal of the debris from damaged and destroyed houses, as well as the debris that

will be generated during reconstruction, will need to be managed through arrangements involving the

Dominica Solid Waste Management Corporation, private waste disposal contractors, and the communities

receiving assistance, to ensure that all debris is disposed of at the Fond Cole sanitary landfill (or other

location approved by the GoCD and the PIU).

Pest Control and Asbestos Handling. Pest control and the potential of safe handling and disposal of

asbestos are possible environmental issues that may arise during the demolition and construction of the

houses. For safe handling, the necessary channels to address pest control depends on the nature and may

require partners like Forestry, Wildlife Division, Pest Control Board and approved pest management

companies.

Chance Finds (Physical Cultural Resource and Skeletal Remains): While the civil works undertaken

under the project are small scale, and while most house reconstruction will be undertaken in situ, the

possibility nevertheless exists of archaeological chance finds from both pre-Colombian and later colonial

and Creole settlements in Dominica. There is as yet no archaeological legislation in Dominica, but the

project will apply chance find procedures to ensure that any finds are reported and handed over to Dominica

Museum in Roseau (the national museum of Dominica). In addition, in situ works may result in chance find

of skeletal remains, which will require reporting to the Dominica Police Force Central Investigation

Department.

Social Conditions and Challenges

Damage Assessment. A Building Damage Assessment (BDA) conducted in December 2017 showed that

medium‐size houses (500 to 1,200 sq.ft) dominate the housing stock with 9,825 units, and of these 40

percent sustained major or total damage. However, small house units (less than 500 sq.ft), which comprise

31 percent of the housing stock (7,525 units), sustained a higher level of major or total damage, affecting

62 percent of that group. Of the destroyed houses, only 2 percent were insured. When the project starts

implementation during 2019, the damage status of many homes will have changed due to repairs undertaken


by the owners or with support from other programs, though likely less so for destroyed homes that were

occupied by the vulnerable households that are the primary target group for the project. Updated

information on same will be captured during the demand-driven application process and the subsequent site

assessment to determine beneficiary eligibility selection.

Home Ownership. There are no recent data on private land ownership, but available information indicates

that about 80 percent of residents have either a registered title, a registered deed, or an unregistered deed.

Among the remaining 20 percent are households who have not been able to pay registration costs to obtain

a title document, and others who reside under informal arrangements as tenants or leaseholders in houses

they do not own, or in houses they own, but on land owned by somebody else. Eligible households will

need to source these documents and the project may facilitate same where required. The project will not

support tenants or leaseholders since there are other housing programs suited to this need and the project

does not support commercial property.

Poverty and Vulnerability. Rural poverty continues to represent a major challenge, with 75 percent of the

poor living in rural areas. The project’s prioritization criteria for identification of eligible beneficiaries for

housing reconstruction assistance include (i) households that are still in hurricane displacement centers, and

(ii) particularly vulnerable households comprising single parent households with children under 15 years,

households with a disabled household head, and households with an elderly household head. Women

represent 39 percent of the heads of households in Dominica, and the Vulnerability Needs Assessment that

was prepared after the hurricane highlighted, that there were over 1,100 single mothers with uninsured

houses that had either been destroyed or severely damaged. Female headed households with dependent

children include grandmothers as caregivers for grandchildren, and they make up a large proportion of those

still in temporary shelters. Since these categories of prioritized beneficiaries are likely to have limited

access to information about the project, and also limited ability to act on such information, the HRP

Communication Strategy will seek to disseminate information on the project including social services, local

government and shelter managers to create awareness and engage these persons in the self-driven

application.

Construction Labor Agreement. While the owner-driven model for house reconstruction will involve

beneficiary house owners/occupants in reconstruction activities assisted by other community members with

appropriate skills, the house reconstruction will also involve pre-qualified building contractors along with

modest labor influx. To manage the community-contractor relationship, the project will follow an approach

which has been successfully applied in other civil works projects in Dominica using local contractors. It

involves a meeting held before the start of physical works between the concerned local governance entity

and the contractor, where the PIU will be represented, and where issues related to the work and the

contractor’s presence are discussed and agreed upon in writing.

Indigenous Kalinago. Dominica was originally populated by Amerindian peoples, known as Caribs or

Kalinago, and is the only island in the Caribbean still to possess distinct communities of these indigenous

people. The Kalinago inhabits a territory of 3,782 acres stretching over 9 miles on the East coast of

Dominica with eight hamlets and a 2011 population of 2,145 consisting of 652 households. A Carib

Reserve Act was enacted in 1978, the year of Dominican independence, and its name amended to the

Kalinago Territory Act in 2015. A Department of Carib Affairs was established in 2000 and upgraded to a

Ministry of Kalinago Affairs in 2014. The Kalinago Territory Act describes the establishment of the office

of the Kalinago Chief and the powers of the Kalinago Council. All land in the Territory is under the custody

and management of the Kalinago Council, and no individual can buy or sell parcels of land or use land as

collateral for loans. The Council is solely responsible for allocating land for all purposes. Hurricane Maria


wrought very extensive damage on housing in the Kalinago Territory, which has a much higher poverty

rate (at 49.8 percent) compared with the national level (at 28.8 percent). Figures on the damage level varies

between different assessments, but there is agreement that the proportion of totally destroyed houses is

more than twice as high as the national level. The BDA will be used to verify and validate such information

in the selection of beneficiaries, as well as decisions regarding the choice of locations where the project

will start physical implementation.

Addressing Environmental and Social Safeguard Issues

Rather than separate the consideration of environmental and social issues as they relate to beneficiary

selection, house design and planning, and civil works, these issues and the associated measures to mitigate

and manage them are dealt throughout the project implementation process. The implementation cycle will

commence with outreach and communication on the environmental and social safeguards, the intake and

application process that progresses to the beneficiary selection and then to the civil works for housing

reconstruction and closure.

Outreach and Communication on Safeguards: The HRP Communication Strategy will inform of the

ESMF and its’ application on safeguards throughout the project cycle. It will also include capacity building

to homeowners, contractors and government entities on same that will improve planning processes to

mitigate and manage environmental, social, health and safety risks.

Eligible Beneficiary Application Process: A call for application will be made using the HRP

Communication Strategy. The HRP Application Form (Annex 7) will include the eligible criteria on

environmental safeguards to ensure that homes will be constructed in safe conditions away from flood and

landslide prone areas. The application form will also include socio-economic criteria to be completed by

the applicant. The process is demand-driven.

Beneficiary Selection: To enable the selection of individual beneficiary households for reconstruction

assistance, four preparatory activities will have to be undertaken: (i) a national information campaign to

inform the population about the project approach, the criteria for beneficiary selection, the deployment of

technical services/TACs and building contractors, and the Grievance Redress Mechanism, (ii) set up of a

Beneficiary Selection Review Committee, (iii) set up of a Grievance Committee to address complaints on

the Project, and (iv) a site visit to assess the environmental risks.

The eligibility criteria that will be applied in the beneficiary selection process (Section 6.1) involve both

environmental and socio-economic considerations. The selection will comprise three ‘steps’, with Step 1

covering a set of eligibility criteria that determine whether home-owner applicant meets the physical and

socio-economic criteria of the project as a potential beneficiary, and which involve on-site assessments.

Step 2 will enable a categorical prioritization among the potentially eligible beneficiaries based on socio-

economic and demographic vulnerability criteria, which address protracted displacement, poverty status,

gender, and disability considerations. Step 3 will consist of verification and validation involving a review

of the final list of the beneficiaries by the HRP Beneficiary Selection Review Committee, who will produce

a list of confirmed beneficiaries. This list will be made public locally and on-line (project website at MoHL)

as a final step in the validation and confirmation.

The HRP Beneficiary Selection Review Committee will comprise no more than seven members, involving

representatives from local government, religious, NGO or other civic group, prominent local citizen, and

professional/academia. Specifically, the composition of the will include:


Grant Agreements with Beneficiary Households: The project will enter into a Grant Agreement with the

selected beneficiary households regarding the reconstruction of their house. Prior to the finalization of the

Grant Agreement, the PIU supported by the Design & Supervision Firm will inform each beneficiary of the

procedures involved in the housing reconstruction support under the project, will assist with a house design

within their individual financial resources, and will assist with obtaining a building permit and title

documentation, if needed. A subsidy of EC$50,000 will be provided to the eligible home owner. In addition

to technical assistance that will be provided to the home owner, the financial support will cover the cost to

build a small future home approximately 500 sq. ft in size.

Environmental and Social Management Plan (ESMP): During the assessment of environmental hazard

risks for potential beneficiary housing sites that was undertaken during Step 1 of the beneficiary selection

process, all destroyed houses found to be exposed to such risks have been excluded as ineligible for

reconstruction assistance (unless they could be re-sited to a location without environmental hazard risks on

the beneficiary’s property). The environmental impacts to be considered during construction therefore

involve only those related to good practice management measures for small-scale construction works. To

manage these impacts, along with health and safety issues and social risks, a standard house level ESMP

will be developed based on a standard ESMP for small civil work (Annex 8). Compliance monitoring of

ESMPs inclusive of standard operating procedures will be done by the Design & Supervision Firm and

managed by the PIU. In addition to the individual house site specific social risk management activities

indicated in the ESMP, the project will engage at the community level with the Village Councils to manage

broader social risks such as those regarding the presence of building contractors.

Indigenous Peoples Plan – The Kalinago: All consultations regarding the preparation and implementation

of the Housing Recovery Project in the Kalinago Territory will be conducted through the elected Kalinago

Council and the Ministry of Kalinago Affairs. Thus, the institutional framework exists for ensuring free,

prior, and informed consultation resulting in broad community support to the project by the Kalinago people

as required by OP 4.10 on Indigenous Peoples, and such support has been expressed during the initial

consultations already held in the area. The project’s overall approach to community engagement would

also, with a few adaptations, suit conditions in the Kalinago Territory. Adaptations that would need to be

agreed by the Kalinago involve inter alia the beneficiary selection criteria and process, and the GRM

arrangements and process. An Indigenous Peoples Plan (IPP) will be prepared to support the unique needs

of the Kalinago in Dominica under the HRP.

Beneficiary Selection Review Committee

Representative of the Village / Kalinago Council

Representative of Religious Organisation

Representative of a Credit Union, Financial Institution or Cooperative Association

Representative of any NGO's or other Civic Group in the region

Other Prominent Citizen e.g. Justice of Peace, community activist

Professionals/Academia

Shelter Managers


Communication: Consultation, Information Dissemination

During the preparation of this ESMF, consultations were held about the project’s environmental and social

aspects with relevant departments of the Government, potential beneficiary groups, and with the Kalinago

Council and MoKA. Prior to that, initial consultations were held with the Kalinago community during

project preparation in February 2018, and by the Government in connection with preparation of a draft

Indigenous Peoples Plan.

Project implementation will be preceded by nation-wide information campaigns on the project and its

approach using radio and/or television among other media channels. Following the deployment of project

staff to the geographical locations where village level activities will take place, consultations will take place

with Village Councils regarding the project approach, procedures and work plan, the beneficiary selection

process, the GRM, and the presence and mandate of the PIU contracted entities, and building contractors

with a ‘code of conduct’ for contractor staff. Subsequently, a meeting with the HRP Beneficiary Selection

Review Committee will be held to review, verify and validate the list of identified beneficiaries of the

housing grant.

Follow-up meetings between local government entities (and interested beneficiaries), contractor(s), the

PIU, and staff from TAC/Design & Supervision Firm will be held at regular intervals to review the status

of construction, and to discuss and if possible, resolve complaints received through the GRM. In the

Kalinago Territory, similar meetings will be held at the level of the Kalinago Council and with the Hamlet

Development Committees in locations where project implementation is taking place.

Capacity Building

Capacity building will be important for the implementation of the safeguard-related activities described

above, and will be required at different levels of the institutional set-up for the project. Safeguards staff

from the PIU (supported by their counterparts from the IST) will provide safeguards related capacity

building for the entities contracted by the PIU, beneficiary homeowners, contractors and the workers,

including their designated safeguards staff, as well as to relevant staff of the Physical Planning Division

and the Division of Housing in the form of orientation meetings and trainings. The meeting and training

sessions will take place before construction and during construction. Local government entities comprising

the Village Councils, and the Kalinago Council and Hamlet Development Committees in the Kalinago

Territory will also be oriented on the safeguards implementation process outlined in the HRP

Communication Strategy. Overall, capacity building on the construction of houses that are stronger and

more resilient to multiple risks will be conducted through orientation meetings, workshops and training

sessions prior and during construction works. Capacity building in the: implementation of: safeguards;

handling of complaints and resolutions; free prior and informed consent; improved planning processes

including data recording and analysis will form part of project implementation.

Grievance Redress Mechanism

The project will establish a GRM to receive and process complaints and grievances related to project

activities, and to provide the public with an avenue to provide feedback on the reconstruction activities

supported by the project. The PIU will manage grievances and resolutions based on the HRP GRM

document. This includes administrative responsibility for the GRM, including the formation and

management of a Grievance Committee(s).


Further, the PIU will conduct orientation sessions on the GRM with all entities contracted under the HRP,

as well as the beneficiaries, the GRM Committee(s), direct players and key partners. The Design &

Supervision Firm will be responsible to set up a database to record complaints and appeals and the decisions

taken on them for GRM management and reporting. Training sessions on same will be conducted by the

Design & Supervision Firm to PIU staff and other appropriate personnel identified by the PIU. It is

expected that the bulk of complaints will be received at the local level particularly during construction or

otherwise filed on the Grievance Complaints and Logging System that will be established under the project,

and that a large portion of these can be resolved at that local level by the Design & Supervision Firm through

regular meetings with local government entities and appropriate stakeholders in accordance with evolving

complaints. The PIU Grievance Committee will address all complaints that could not be resolved at the

local level with a clear process for decisions taken. The proposed HRP Grievance Redress Committee

structure will comprise representatives from the following but not limited to:

The diagram below describes the process that will be used to resolve any grievances:

Details on the system to log complaints and to resolve them are noted in the HRP Grievance Redress

Mechanism document.

HRP Grievance Redress Committee







Follow up and Close out

Act

Investigate

Acknowledge

Screen

Record

Receive Grievance


Monitoring and Reporting

The overall monitoring and evaluation (M&E) for the project will be managed by the PIU, with high level

oversight by the Housing Task Force. A project Management Information System (MIS) will house the

data to be used in the generation of periodic reports and updating of indicator results. The core of this MIS

will be a registry database, which will contain the data from the housing recovery program including the

beneficiary selection and the physical planning and implementation process as well as the grievance

complaints and resolutions. The primary data for the MIS will be collected on site using tablets for direct

data entry by the Technical Services (engineers, architects) hired by the PIU and subsequently by the Design

and Supervision Firm for generation of consolidated reporting covering the entire project. Support for the

project implementation will also be provided at the level of each of the communities (Village Councils and

Hamlet Development Committees). The MIS would contain the data for progress reporting by the Design

& Supervision Firm on achievement of construction targets and possible bottlenecks in reaching these. It

would also allow comparisons between results in different Districts, and between the Kalinago territory and

elsewhere in Dominica. Separate from the database, site visits will also be conducted by the PIU to verify

safeguards implementation. At critical stages throughout the project, including key milestones, reporting

by each contracted entity is required as guided by the PIU.

Budget Requirements for ESMF Implementation

The budget requirements for implementation of the ESMF are covered by (i) the funding allocated for the

project components that include the planning, technical assistance, consultation and information

dissemination, and monitoring of housing repair and construction (Sub-Component 1.1, 1.2, 2.2 and

Component 3), and (ii) the costs of construction of individual house undertaken in compliance with the

house-level ESMP (Sub-Component 2.1).

SECTION 1: INTRODUCTION

The Environmental and Social Management Framework (ESMF) is developed to protect people and the

environment in investment projects supported by the World Bank (WB). It responds to new and varied

development demands and challenges that have arisen overtime. It makes important advances in areas such

as transparency, non-discrimination, public participation and accountability, including expanded roles for

grievance mechanisms.

This document presents the ESMF for the Dominica Housing Recovery Project (P166537). The objective

of the ESMF is to serve as a practical tool during project implementation and monitoring, and to provide

operational guidance on both what needs to be done, and how what is needed should be done regarding the

management of environmental and social issues in housing reconstruction. The framework is intended to

ensure that for all activities financed by the project, efforts are made to identify and avoid or minimize

adverse environmental and social impacts, and where these cannot be avoided, that necessary mitigation

measures are developed and implemented following the relevant laws and regulations of Dominica and

World Bank safeguards policies. The ESMF provides information about the project, its environmental and

social context, social and environmental risks and mitigation measures, institutional arrangements,

monitoring indicators, and capacity building and training requirements to ensure that the potential negative

environmental and social impacts of project activities are minimized or mitigated, and positive impacts are

encouraged and enhanced.

Other documents of the HRP aligned with the ESMF are: Project Appraisal Document (PAD); Project

Operations Manual (POM); Indigenous People’s Plan (IPP); Grievance Redress Mechanism (GRM); and a

Communication Strategy.

SECTION 2: PROJECT DESCRIPTION

2.1 Background

The Commonwealth of Dominica is a small upper‐middle‐income country, which is one of the Windward

Islands in the Lesser Antilles archipelagos. Dominica’s land area is 751 km2, and its population in 2011

was about 73,500. With a gross domestic product (GDP) of US$581.48 million, Dominica’s economy

depends predominantly on agriculture and tourism. Poverty remains a pervasive development issue, with

a poverty headcount of 28.8 percent at the time of the last Country Poverty Assessment (CPA) conducted

in 2009.

Dominica is particularly vulnerable to natural disasters from weather-related and geophysical events. Due

to its location within the Atlantic hurricane belt, high-intensity weather events such as high wind, excess

rainfall and hurricanes, continue to have adverse effects on vulnerable populations and the productive

sectors of the country’s economy. Moreover, the island’s mountainous, rugged landscape creates significant

engineering challenges to reducing infrastructure vulnerability to natural disasters and climate change.

On September 18, 2017, Hurricane Maria (Category 5) hit Dominica with sustained winds of 170 mph that

resulted in catastrophic effects. As the hurricane passed over the center of the island, Dominica was

exposed to extraordinary winds for more than three hours, accompanied by intense rainfall, which triggered

flash floods and landslides. According to official sources, 30 persons lost their lives and 34 persons were

declared missing. The Prime Minister declared a state of emergency on September 20, 2017.

A Post‐Disaster Needs Assessment (PDNA) led by the World Bank in collaboration with the United

Nations, the Eastern Caribbean Central Bank, the Caribbean Development Bank, and the European Union

(EU) estimated total damages at US$931 million and losses at US$382 million, amounting to 226 percent

of Dominica’s 2016 GDP. The identified needs for reconstruction and resilience interventions to ‘build

back better’ amount to US$1.37 billion. The hurricane affected 90 percent of the housing stock, with more

than 4,500 houses destroyed and over 20,000 partially damaged. The sector sustained US$354 million in

damages and US$28.5 million in losses, and the PDNA identified US$519.7 million in recovery needs.

2.2 Project Description

The Housing Recovery Project (HRP) complements the role of relief and humanitarian partners who have

been addressing the first phase of housing recovery with a focus on temporary and transitional shelter, roof

repairs, and minor repairs conducted by house owners.1 It also leverages the Bank’s global experiences in

post‐disaster housing reconstruction in Haiti, Nepal, the Philippines, Tonga, and Indonesia as well as post-

hurricane emergency recovery loans in small island states. The project will contribute strategically to the

housing sector in Dominica and address critical gaps by focusing on rebuilding destroyed homes and

supporting the resilience of the housing stock against a Category 5 hurricane standard.

The Project Development Objectives (PDOs) are to contribute both to the recovery of housing for

households (HH) affected by Hurricane Maria and to improve the application of resilient building practices

in the housing sector. Direct project beneficiaries are expected to make up approximately 50 percent of the

households which experienced some level of damage, and comprise approximately 12,000 households

1 The partners include the United Nations Development Programme (UNDP), the International Organization for

Migration, the International Federation of the Red Cross, Samaritan’s Purse, Is There Not A Cause, Caritas, Catholic

Relief Services, All Hands and Hearts, Emergency Architects, IsraAid, Caribbean Disaster Emergency Management

Agency, and the United Nations Children’s Fund.

17 | P a g e E S M F F i n a l D r a f t 1 4 M a y 2 0 1 9

(32,400 persons, of whom 15,500 are women), who will be assisted through a package of technical services

for resilient rebuilding of houses. Of these, approximately 1,700 households with completely destroyed

homes (of which 35 percent are expected to be female‐headed) will receive financial support in the form of

a subsidy from the project toward a future house.

Project components: The HRP consists of three major components with sub-components. Environmental

and social safeguards fall mainly under Component 2 of the HRP. Equally important to effect efficiency

on reconstruction of houses is the incorporation of safeguards in Components 1 and 3 in order to set the

processes in place and to build capacity routed in the environmental and social elements.

Component 1: Support for Housing Recovery Systems and Capacity Building (US$3.5

million) This component will set up systems to manage, expedite, and monitor the housing recovery program and

will build capacity and a sustainable framework for development planning in the housing sector. For sub-

components 1.1 & 1.2, safeguards will form part of work processes, reporting and capacity building. For

sub-component 1.3, safeguards will be incorporated in the technical design.

Subcomponent 1.1: Development Planning Support to Technical Assistance Centers and the Project at the

Local Level (US$2.7 million). This sub‐component will support the establishment and operation of regional

Technical Assistance Centers (TACs) which have a dual function of technical advisory services and

planning control functions. The TACs will provide technical advisory services to homeowners on demand,

facilitate processing of planning and building controls, conduct building assessments, facilitate technical

training on the application of resilient building practices, and monitor the compliance with building codes

and processing permits. The purpose of the TACs are to guide and encourage resilient practices in

construction and to strengthen planning control capacity at a local level. Where feasible, the TACs may

also support the Project Implementation Unit (PIU) in the collection of demographic information required

for administering eligibility under the project. The project will provide support to expand the staffing and

the number of TACs and sustain operation through the project implementation period. This support will

include contracting of a consulting services firm to support the TACs and the Physical Planning Division

(PPD) under which the TACs operate.

Subcomponent 1.2: Development of Management Information Systems to support planning and monitoring

processes in project agencies (US$0.6 million). Management information and monitoring systems will be

developed under the project to support the housing recovery program and the physical planning process.

The systems will provide support to Ministry of Housing (MoHL) and Ministry of Planning (MoP) and will

be implemented in conjunction with the Information and Communication Technology (ICT) Unit for

ongoing technical support and operation. A consulting firm will be engaged to supply and install IT

services, and this will include development of electronic systems for (i) a registry of households and

homeowners, including demographic and personal identification data, aligned inter alia with verification

from the Building Damage Assessment (BDA) and other relevant databases for social support, vulnerability

assessment, and Government services; (ii) administration of beneficiaries eligible for support under the

project; (iii) M&E of project activities, outputs, and results; (iv) project and MoHL communication

strategies; and (v) project financial management and reporting.

Subcomponent 1.3: Technical Design of a New Physical Development Planning Office (US$0.2 million)

will finance the preparation of detailed designs of a new building for the Physical Development Planning

Office on the same site of the previous building which was completely destroyed by the hurricane.

Environmental and social consideration will be incorporated in the design.


Component 2: Support for Reconstruction of Houses (US$33.5 million).

This component will provide subsidies in the form of small grants for owner‐driven reconstruction or

replacement of houses that were classified as ‘destroyed’. Eligible homeowners would use the grant and

their own resources, if necessary, to undertake the rebuilding works to a design of their choice. Safeguards

form part of the eligibility criteria for risk mitigation and for socio-economic vulnerability assessment under

subcomponent 2.1, while subcomponent 2.2 focused on monitoring of safeguards.

Subcomponent 2.1: Support for Reconstruction of Houses (US$31.45 million). This sub‐component will

provide Housing Grants to eligible homeowners for reconstruction or replacement of housing destroyed by

Hurricane Maria. A subsidy up to a US$18,500 (approximately EC$50,000) fixed grant will be provided to

around 1,700 homeowners for either reconstruction or replacement of the destroyed building. Eligible

homeowners will select the scope and approach to reconstruction and fund the activity with the support of

the fixed grant and own resources. The grant will be conditional on the construction having a valid building

permit, certified Physical Planning Division (PPD) inspections, and a completion certificate verifying that

the building complies with the applicable Building Code and Guidelines. The grant would be disbursed to

the homeowner’s banking institution in tranches, aligned with major stages of completion, for payment to

the home owner who undertakes the house construction.

Subcomponent 2.2: Design and Supervision of House Reconstruction (US$2.05 million). This

subcomponent will provide design and supervision services for the reconstruction works for eligible

beneficiaries, including inter alia, those needed for the construction to meet building guideline requirements

for resilience to Category 5 hurricane events and applicable environmental, social, and health and safety

safeguards requirements. A consulting firm will provide support for design and supervision services for

the house reconstruction works by eligible beneficiaries undertaken under Subcomponent 2.1.

Component 3: Project Management and Coordination (US$3 million)

This component will finance the establishment and operation of the Project Implementation Unit (PIU)

under MoHL to serve as the unit responsible for the overall implementation and coordination of the project

activities, and for the associated safeguards, procurement and financial management (FM) responsibilities.

Component 3 will also finance the setting up of an Implementation Support Team (IST) to be established

within the Ministry of Finance (MoF). The IST will provide close implementation support on procurement

and safeguards to the PIUs of all World Bank‐funded projects. The Project will finance (a) incremental

dedicated staff for the establishment and operations of the IST and the PIU; (b) the hiring of other technical

experts needed for project preparation and implementation; (c) the preparation of environmental and social

safeguards studies and instruments including development of a communication strategy, and a complaints,

feedback and grievance system; (d) the carrying out of the fiduciary aspects of the project including audits;

(e) the provision of training and workshops; (f) the financing of the necessary goods, equipment, and

operating costs; and (g) the implementation of safeguards instruments.

This initiative augments and bolsters the GoCD drive for improved planning controls and increased

compliance to resilient construction practices. Further, it supports the GoCD’s long-term plan for

improving the coordination between services relating to development and physical planning, land

management and housing by advancing the design of a new building which would co-locate the relevant

services.

SECTION 3: POLICY FRAMEWORK FOR ENVIRONMENTAL AND

SOCIAL ISSUES

3.1 National Laws and Regulations

The GoCD has introduced legislation, policies, plans, and guidelines, and has signed international treaties

and conventions, that have provisions regarding social development and safeguards issues relevant for the

Housing Recovery Project. The existing national legislation and international agreements related to social

development and safeguards of Indigenous Peoples (IPs) have been reviewed to streamline the safeguard

requirements of the government regarding the Kalinago People for this project. The national legislation is

the Kalinago Territory Act of 2015, and the international agreements are the ILO Convention No.169 on

Indigenous and Tribal Peoples enacted in 1989 and ratified by Dominica in 2002, and the United Nations

Declaration on the Rights of Indigenous Peoples (2007) ratified in 2007.

The legislation, policies, plans, and guidelines relevant to safeguards in the context of this project can be

categorized broadly into the following three groups:

1. Policies, strategies, and legislation related to overall environmental protection and climate change

mitigation, and disaster management.

2. Legislation, policies, and guidelines related to land and physical development.

3. Safeguards for Indigenous Peoples.

The key policies, strategies, and legislation related to overall environmental protection are the Dominica

Climate Change Adaptation Policy of 2002, the National Climate Change Adaptation Strategy of 2009, and

the Climate Change, Environment, and Natural Resources Management Bill of 2014, which has been

approved but not yet adopted by the House of Assembly. The planning related to emergency management

include the National Emergency Management Policy of 2009, and the Disaster Management Plan of 2009.

Regulation of physical planning and land tenure are covered by the Physical Planning Act of 2002, the Title

by Registration Act of 1980, the Solid Waste Management Act of 2002, and the National Land Use Policy

of 2014. Land acquisition is regulated by the Land Acquisition Act of 1946;2 and resettlement to mitigate

climate hazards by the Dominica Resettlement Strategy of 2015. With regard to housing reconstruction,

the Guide to Dominica’s Housing Standards of 2018 updates and amends earlier building regulations

(Building Code and Building Guidelines). The Kalinago Territory Act of 2015 defines the rights of the

Kalinago People,3 and gender issues are addressed by the National Policy and Action Plan for Gender

Equity and Equality of 2006. These acts and regulations, as well as the international agreements on

indigenous peoples together provide an overall regulatory framework that defines both process and

procedures for environmental and social protection, mitigation, and management (see Annex 1 regarding a

description of the relevant legislation).

Enforcement of legislation is a problem throughout all sectors. Some of the constraints being experienced

are linked to insufficient financial and human resources. Additionally, in some cases responsibilities for

enforcement is not clearly mandated or spread over two or more ministries.

2 The Act has been amended in 1966, 1971, and 1986. 3 The Kalinago Territory Act of 2015 is an amendment of the Carib Reserve Act of 1978, which in turn reaffirmed the

territorial boundaries first established by colonial authorities in 1903, and which legally established common

ownership of land within the reserve.


3.2 World Bank Safeguard Policies

The applicability of the following World Bank policies identified during project appraisal is considered

below: OP/BP 4.01 Environmental Assessment, OP 4.09 Pest Management, OP/BP 4.10 Indigenous

Peoples, OP/BP 4.11 Physical Cultural Resources, and OP/BP 4.12 Involuntary Resettlement. All activities

financed by the project will comply with safeguards requirements. In addition, activities without direct

adverse safeguard impacts including the detailed technical design of a new Physical Development Planning

Office financed under Subcomponent 1.3, and ToR for any studies to be conducted under the project will

consider relevant environmental and social issues in order to reflect the principles of World Bank

safeguards.

3.2.1 Environmental Policies

OP/BP 4.01 Environmental Assessment: Given the nature of the proposed program, this policy is triggered.

The overall project is classified as Category B, based on the potential level of impact as it involves the

reconstruction of houses that were classified as ‘destroyed’. The civil works will take place in different

locations across Dominica, and impacts will be small scale, site-specific, and temporary for the house

reconstruction. The small-scale construction works will have minor risks related to health and safety.

Negative impacts and risks will be listed in a house-level Environmental and Social Management Plan

(ESMP), and mitigated through the application by the works contractor(s) of good construction and

management practices, with close supervision from the PIU, and the Design & Supervision Firm. Since

extraction of construction material (sand, gravel) will only take place from approved active quarries, there

would be no risk of increased local vulnerability to landslides and soil erosion in project areas. Disposal of

debris including the possibility of asbestos from destroyed houses and debris from construction will be to

Dominica’s principal landfill in Fond Cole near Roseau (or other approved by the GoCD and the PIU). The

requirement to acquire aggregate from approved active quarries, and disposing all debris to the Fond Cole

(or other approved by the GoCD and the PIU) landfill, as well as managing other environmental issues

noted in the ESMF will be included in works contracts, and compliance will be monitored by the PIU and

the Design & Supervision Firm.

OP 4.09 Pest Management: This policy is triggered as pesticides may be required for pest control (termites)

during demolition and in the rehabilitated or newly constructed houses. Proper procedures for storing and

applying small quantities of termite control pesticides are included in the house-level ESMP, and will be

included in the works contracts with building contractors, so that such activities are only undertaken by

licensed and registered pest control professionals. Compliance will be monitored by the PIU and the Design

& Supervision Firm.

OP/BP 4.11 Physical Cultural Resources: While no significant impacts are expected on physical cultural

resources, the policy has been triggered as a precaution and the project will include a ‘chance find’

procedure in all works contracts with building contractors.

3.2.2 Social Policies

OP/BP 4.10 Indigenous Peoples is triggered since the Kalinago are recognized as indigenous people by the

Government of Dominica, and also meet the World Bank criteria for applying the Indigenous Peoples

Policy. Consultations have been held in the Kalinago Territory, and an Indigenous Peoples Plan for the

Kalinago Territory has been drafted, and has informed this ESMF.

OP/BP 4.12 Involuntary Resettlement: . OP/BP 4.12 on Involuntary Resettlement was triggered in the PAD

on a precautionary basis to address instances of economic displacement and/or temporary involuntary


resettlement. Nevertheless, currently there has been no justification to apply itThe project will be providing

grants to households based on an ‘owner-driven’ housing reconstruction model, where the beneficiary is

involved in and agrees to the specifics of the design and siting of reconstruction activities, and has the

option of choosing not to receive project assistance. The project’s housing reconstruction activities will

therefore not involve involuntary land acquisition or resettlement. . Under a demand driven approach

where a house owner is found eligible for project assistance to reconstruct a hurricane destroyed house

located on his/her own land, the decision to alter its footprint/location due to environmental hazard

considerations would be made voluntarily by the house owner/beneficiary as part of the agreement

regarding the assistance. This should therefore not – even if crops or economic trees are affected by the

new location - be considered economic displacement eligible for compensation. If a house owner considers

the requirement to site a new house for safety reasons in a different location on his/her land to be onerous,

he/she has the option to refuse project assistance to rebuild the house. 4

Moreover, the World Bank’s use of the concept of ‘temporary impacts’ was historically conceived and used

for very different situations such as adverse impacts in connection with dam projects, where people on the

periphery of a reservoir could lose access to land every few years as a result of high flooding – that is a

situation where the impact is the result of decisions made by external actors and beyond the decision-making

powers of those affected.

4 The argument for not triggering OP 4.12 for the Housing Recovery Project would also reflect practice in World Bank

supported disaster housing reconstruction projects. Thus, while the recent Nepal Earthquake Housing Reconstruction

Project (P155969) did trigger OP 4.12, it was not to address the kind of impacts identified in the PAD and PID/ISDS

for the HRP, but to deal with situations where: “Land taking maybe needed due to limited relocation of

settlements/households that are no longer habitable due to ground fissures and high risks of seismic and landslide

hazards” (PID/ISDS). Moreover, regarding the scope of land acquisition and involuntary resettlement, the

Resettlement Policy Framework for the Nepal project states that: “Since the project will be providing grants to

households based on ‘owner-driven’ housing construction modality, project activities are not expected to cause

involuntary resettlement as defined by the World Bank’s OP/BP 4.12.” (p. 11).

SECTION 4: PROJECT IMPLEMENTATION ARRANGEMENTS

The MoHL has overall responsibility for the implementation of the project through the Project

Implementation Unit. At the highest level, the Housing Task Force will provide strategic oversight and

ensure policy coordination, guided by a housing reconstruction strategy that aims to coordinate efforts in

the sector and standardize approaches to recovery. This strategy is being implemented by the MoHL in

collaboration with the MoP. Under the strategy and in addition to the Housing Recovery Project, the

Government has an ongoing housing revolution to carry out major housing reconstruction projects,

including the construction of 1,000 housing units in new sites, and is also receiving support from

international agencies and nongovernmental organizations (NGOs) for housing repair. These are the

programs and projects that households can be referred to, when they are not found eligible under the

beneficiary selection criteria of the Housing Recovery Project.

World Bank: The World Bank will serve to guide the design of the project in accordance with the needs

of Dominica in the application of environmental and social safeguards for investment financing of the HRP.

The Bank is responsible to provide “no objection” on project implementation at appropriate milestones.

Project Implementation Unit: A PIU established under MoHL with the Housing Division as the Focal

Point of the project, will serve as the unit responsible for the overall implementation and coordination of

project activities, including fiduciary (procurement and financial management) and safeguards

responsibilities. The PIU’s safeguards responsibilities comprise oversight and advise on safeguards

compliance, management of the GRM, capacity building in safeguards management for TACs, local

government entities, contractors and other key players and partners and support regarding the project’s

communication with beneficiary communities and the public. In addition, the PIU’s role in selection of

beneficiaries for housing reconstruction assistance also includes safeguards responsibilities (see Section 5).

If needed, the PIU can access assistance from an Implementation Support Team (IST), that will be housed

within the Ministry of Finance (MoF), and will provide implementation support to the PIUs of all World

Bank‐funded projects in Dominica as a shared service in the areas of procurement, safeguards, and fiduciary

aspects. The project will provide the necessary implementation support by bringing experts to the IST

through an international recruitment process.

Districts and Technical Assistance Centers: The MoHL plans to coordinate repair and reconstruction

activities within each of Dominica’s seven Health Districts (see Annex 2 - Map of Health Districts), which

will serve as the zones for housing recovery assistance. Each District will have one TAC, with the exception

of the Roseau District, which due to its size and population will have two additional satellite TACs, and the

Castle Bruce District which will have one satellite TAC for the Kalinago Territory. The TACs will serve

as a decentralized extension of PPD to support and improve community outreach and provision of technical

advice, guide construction practices, and strengthen development control capacity. Thus, the TAC will

have a dual function comprising both technical advisory services and building controls. In addition, the

TACs may also support the PIU in the collection of demographic information required for administering

eligibility under the project. By focusing on the setup of the overall delivery mechanism, the project ensures

that all activities are scalable so that other donors could easily adopt or contribute to the program.

Through the TACs, the project will address existing capacity gaps in planning controls and compliance,

and assist homeowners as follows:

1. Streamline the building permit application and approval processes through the use of electronic

systems.


2. Streamline the site inspection and compliance evaluation processes with field and office electronic

systems.

3. Shift much of the technical responsibility for ensuring compliance with required building standards

upstream to field supervision consultants employed under the project.

4. Provide technical advisory services to homeowners on demand, and facilitate technical training on

the application of resilient building practices.

Local Governance Entities: In the localities where the project financed housing reconstruction activities

will take place, the institutional counterpart will be Village Councils (in the Kalinago Territory the Kalinago

Council and Hamlet Development Committees). The councils are popularly elected bodies empowered by

law to regulate and administer affairs in their respective areas, and their responsibility for development

work include the construction and maintenance of local infrastructure. In addition, they serve as the central

Government’s agents for the distribution of public assistance to destitute community members, and as a

channel through which information on Government policies and programs are conveyed to the local

communities (see Annex 3 - Map of Village Districts).

Meetings with Village Councils, and the Kalinago Hamlet Development Committees/Kalinago Council will

be held (i) before start of implementation to provide information on the project, the approach to beneficiary

selection, the GRM, and to agree on a ‘code of conduct’ for building contractors, (ii) participate in the

beneficiary selection committee to review, verify and validate the list of eligible beneficiaries, and (iii) to

conduct recurrent follow-up meetings involving project representatives and the contractor to review

progress, complaints submitted through the Grievance Redress Mechanism (GRM), as well as any other

issues that might arise in connection with the project activities.

HRP Committees: Two committees will facilitate work on safeguards: (i) Beneficiary Selection Review

Committee and (ii) Grievance Redress Committee. The Beneficiary Selection Review Committee will

review the listing of applicants who have met the criteria with a view of verifying same at the local level,

while the Grievance Redress Committee will focus on solving recurring complaints.

The HRP Beneficiary Selection Review Committee structure will comprise no more than seven members,

involving representatives from local government, religious, NGO or other civic group, prominent local

citizen, and professional/academia. Specifically, the composition of the will include:

Similarly, the proposed HRP Grievance Redress Committee structure will comprise representatives from

the following but not limited to:

HRP Beneficiary Selection Review Committee







Shelter Managers


The current HRP Grievance Mechanism (GM) is included in the PIU Operations Manual and the

Environmental and Social Management Plan (ESMP) with the objective to formalize the management of

grievances at the PIU level, to minimize the environmental, health, safety and social risks to the Project and

avoid triggering the Bank’s corporate Grievance Redress System (GRS). Consult the HRP GRM document

for details.

Project Consulting Entities: Through the project implementation period, the project will provide support

to expand the staffing and the number of TACs. In the absence of this support at the initial implementation

of the project, the contracting of Technical Services (architects, engineers) consultants will screen for

eligible criteria as part of the beneficiary selection process at the initial stage of the HRP before

reconstruction works. A checklist will be prepared by the WB Flood Hazard Experts to support the work

of the Technical Services. The Technical Services consultants will also facilitate eligible home owners in

executing the project.

In addition, a consulting services firm (Design & Supervision Firm) will provide support to the TACs and

the PPD. The firm’s services will include building design specialists, building construction specialists, and

specialists on environmental, social, health, and safety matters. The firm will provide for each eligible

homeowner (i) a review of the building and site assessment, and of the documentation certifying eligibility,

land title and financial capacity; (ii) a customized design, scope of works, and cost estimate in compliance

with requirements of the Building Guidelines for resilience to Category 5 hurricane events; (iii) technical

supervision of site works and building works to ensure that the contractor has obtained the requisite

compliance certifications at various stages of work, and also complies with applicable environmental and

social safeguards as specified in the ESMP; and (iv) certification of satisfactory completion following the

completion of works at each site.

In addition to the safeguards staff at the PIU, specialists on environmental and social safeguards will be

part of the Design & Supervision Firm staff at the District level. However, the Design & Supervision Firm

will not have personnel to staff each TAC. To ensure adequate day-to-day safeguards management at the

implementation level of Village Councils and Hamlet Development Committees, each TAC or satellite

TAC will need to have one of its staff designated as responsible for these issues. The ongoing support for

such designated staff by the Design & Supervision Firm’s specialists on environmental and social

safeguards will contribute to build capacity within PPD to manage safeguards and social development

matters in housing reconstruction beyond the project period.

Separate from this, another firm will be hired to implement the management information system (MIS) to

set up a database to collect and manage beneficiary data.

All consulting entities will follow a code of conduct directed by the PIU based on WB guidelines noted in

Annex 4.

HRP Grievance Redress Committee








Key Partners: Meetings with various key partners to discuss and agree serve to guide sustainable use of

resources and safe practices in accordance with national legislation, policies and plans for managing

environmental, social, health and safety risks for HRP implementation. The multitude of key partners at

the institutional and community levels, as well as direct players are noted in Annex 5-Table 1 comprise the

direct players and their role and Annex 5-Table 2 lists key partners, their role, and a list of respective

Standard Operating Procedures to follow.

Implementation Stages: Implementation of the environmental and social safeguards of the World Bank

under the HRP requires three main stages throughout the entire project process with reporting at key stages.

This involves:

1. Before Construction – Preparation and readiness for (i) safeguards screening for eligibility as a

beneficiary before construction and (ii) safeguards monitoring and implementation during and close of

construction.

2. During Construction – Monitoring, supervision, evaluation and reporting of compliance with the

ESMP.

3. Closure of Construction – Decommissioning of each construction site as per adhering to the ESMP

requirements.

SECTION 5: ENVIRONMENTAL AND SOCIAL CONDITIONS IN

THE PROJECT AREA

This Section describes environmental and social conditions and challenges relevant for the housing

reconstruction activities. Implications for the project’s approach to managing and mitigating environmental

and social conditions and impacts are briefly noted, and will be fully described reflecting Government and

World Bank policies noted in Section 6 on approaches to address environmental and social safeguard issues.

In brief, the environmental conditions include: hurricanes, earthquake and volcano risks; geotechnical and

hydrological risks; access and sustainable use of natural forest and river resources for construction; debris

management; pest control, asbestos handing; and chance finds involving physical cultural resource and

skeletal remains. Social issues relate to: current damage assessment; home ownership; poverty and

vulnerability assessment and verification; construction labor; and indigenous people, the Kalinago.

5.1 Environmental Conditions and Issues

Like most of the islands in the Eastern Caribbean, Dominica is geologically young. The island has nine

active volcanoes, which accounts for its rugged topography. A chain of mountains extends through the

center of the island, creating ridges and steep river valleys. The geological character of Dominica’s

mountains poses unique challenges for slope stability because of their high clay content and easily erodible

nature, which increase local landslide hazard level. The shape and orientation of the island combined with

its elevation results in a rainfall distribution that ranges from 1,500mm on the west coast to over 8,750 mm

annually in parts of the interior. As a result of its location and topography, Dominica as a whole and

therefore potentially all project locations are exposed to several natural hazards, including extreme

precipitation and flooding, strong winds, and landslides. Estimates anticipate that a potential increase in

the severity and frequency of such events is likely.

Hurricanes: The island has experienced several damaging hurricanes and tropical storms since formal

monitoring began in the 1970s: Hurricane David (1979), Hurricane Luis (1995), Hurricane Dean (2007),

Tropical Storm Erika (2015), and most recently Hurricane Maria (2017). During these events extremely

strong winds, flooding, and landslides damaged buildings, agricultural outputs, and road infrastructure.

During hurricanes, coastal zones are vulnerable to storm surge of 3-5 meters, causing flooding and erosion

from wave energy and throughout the island’s interior as a result of the steep topographical landscape and

expansive hydrological network. Mindful that the project will carry into a few hurricane seasons over the

course of implementation, disruption may occur to construction works temporarily.

The project’s support for ‘building back better’ through technical assistance and advice on hurricane

resilient building techniques by the entities contracted by the Project, the Physical Planning Division and

Ministry of Housing and Lands including TACs for both the house reconstruction directly funded by the

project, and for home owners undertaking repairs on their own, will contribute to mitigate the destructive

impacts of future hurricanes and tropical storms.

Volcano and Seismic Risks: In addition to risks associated with hurricanes, volcanic activity and

earthquakes present a historically minor, but continuous hazard. The last recorded eruption was a 1997

steam (phreatic) eruption in the Valley of Desolation, near the active Boiling Lake, but the last eruption of

lava occurred approximately 500 years ago. Earthquakes of a magnitude large enough to be recorded by


seismographs on nearby islands occur at an average rate of one to two per year.5 A major earthquake of

magnitude 6.5 in 2007 collapsed a church tower in the town of Portsmouth and resulted in damage of at

least twenty houses.

Geotechnical and Hydrological Risks (flooding, erosion, slope stability and landslide risks): Most

landslides and soil erosion events are triggered by high intensity rainfall, which can happen without a

hurricane, volcano or seismic activity. After Hurricane Maria, an inventory of landslides caused by the

hurricane recorded a total of 9,960 landslides. These landslides stripped the soil of productivity and

sedimentation, and resulted in siltation of rivers and debris obstruction of natural drainage and waterways.

Almost all rivers flooded due to intense precipitation, inundating an area of 13.03km2, or 1.74 percent of

Dominica’s total land area. Although substantial infrastructure damage was caused by flooding and heavy

debris flows in the rivers, the distribution of damage to housing was fairly similar across risk and non‐risk

areas. From a high‐level analysis, it is estimated that 25–30 percent of houses could be located in flooding

or landslide‐risk areas, with little variation across house sizes and in the incidence of levels of damage. The

preferred approach under the project will be to mitigate any site hazards identified using project or home

owner resources. In cases where public works are required to mitigate the site or relocation is the only

option, the house and site will not be eligible for project assistance, and the Government will assume

responsibility under another housing program. Of the 4,503 totally destroyed homes, 70–75 percent are

expected to be located in areas with low flood or landslide risks. With a funding allocation of US$31.45

million for works for about 1,700 affected households, the project could cover up to 56 percent of all

destroyed houses in low‐risk areas, or 82 percent of small destroyed houses in low‐risk areas.

Geotechnical and hydrological risks do not derive from the civil work activities themselves, but from the

characteristics of the construction site. The susceptibility of specific housing sites to geotechnical and

hydrological risks (landslide or flooding) will be appraised during the building assessments that will be

conducted by the Technical Services team of architects/engineers. The project’s eligibility criteria for

destroyed homes exclude house sites from receiving housing reconstruction assistance, if the risk is assessed

as unacceptable even after site remediation. In that case, the house owner would be referred to other housing

programs.

However, within the area of a particular village, the landslide and flooding risk may vary between the

different house sites that make up the village, and may even vary within particular properties. If a destroyed

house was located in a risk spot on a particular property, but if the property is large enough to enable the

siting of a replacement house that mitigates the risk, it would be potentially eligible for assistance. In this

context, two additional aspects need to be considered when assessing eligibility vis-à-vis hazard risk. First,

if an otherwise eligible home owner with a destroyed house on a site deemed ineligible due to environmental

hazard risk can self-identify an alternative site, which is risk free and for which he/she can document

ownership, this should suffice for eligibility. Second, in the Kalinago Territory land is not private property,

but subject to allocation by the Kalinago Council. Thus, where the hurricane destroyed house is on a plot

with environmental hazard risk, the Council may be able to allocate a different risk-free house plot to a

beneficiary who would otherwise be excluded.

Aggregate: Sand and gravel will be required for construction of house foundations, and there are three

approved active quarries for aggregate in Colihaut, and one for sand (and pumice) in Layou, all on the west

coast north of Roseau. The Physical Planning Division is responsible for the periodic monitoring of quarry

operations in the country and is the focal point of the cabinet-approved quarry monitoring team, which is

also made up of representatives of the Fisheries, Forestry, Environmental Health Division as well as the

5 http://www.dpsninc.org/index.php/seismicity

http://www.dpsninc.org/index.php/seismicity


Environmental Coordinating Unit. Opening a new quarry requires approval by PPD following a process

involving an environmental impact assessment and consultations with affected communities.

To the extent possible, recycling of material dredged from the river if desired and feasible must only be

used if there are approved government processes in place, given the wide array of dredging of rivers that

continues to take place following the hurricane to avoid negative environmental impacts from excavation

and to ensure the use of good quality aggregate in construction.

Forest and River Damage: Dominica has the most extensive natural forests in the entire Eastern Caribbean

covering about 60 percent of the island, and ranging from dry scrub woodland on the west coast to lush

tropical rain forest in the interior. There are four National Parks and two Forest Reserves which together

cover about 22 percent of Dominica, 6 and approximately 27 percent of the island’s forests are designated

protected areas. Dominica is therefore home to the most diverse assemblage of wildlife among the smaller

Caribbean islands with 179 bird species and 18 species of mammals. In 1994 the Government ratified the

UN Convention on Biological Diversity. However, threats to the forest cover and biodiversity continue

and include deforestation, hunting and capture of wildlife, agro-chemical pollution, and invasive species.

Added to this is the threat of extreme weather events. Hurricane Maria’s winds and intense rainfall

produced widespread damage to the forest system. Much of the forest was stripped of leaves, and trees

were extensively damaged and downed throughout the island. It is estimated that 10 to 20 percent of the

trees in the forests were completely flattened. For the remaining 80 percent of the forest area, it is expected

that the trees that survived the hurricane will be able to re-establish a closed canopy. Any use of local

timber either from downed trees or logging must follow the management procedures of the Forestry,

Wildlife and National Parks Division.

This would reduce the risk of unregulated deforestation, and would at the same time reduce dependency on

imported lumber and create local employment through the conversion of downed trees into building

materials if feasible. This is particularly relevant in the Kalinago Territory.

Building Debris: As Hurricane Maria passed over Dominica, the extreme winds, landslides, flash floods

and storm surges all contributed to wreak havoc on buildings and other structures generating large amounts

of debris. For houses receiving project assistance, this debris will have to be disposed of, both because it

may present a health risk,7 and because its negative aesthetic impacts affect quality of life. Dominica has

its principal landfill in Fond Cole near Roseau. The Dominica Solid Waste Management Cooperation

(DSWMC) provides waste collection services throughout the island and operates the Fond Cole sanitary

landfill.8 Due to the distances and the lack of transfer and storage facilities, the service is costly by

international standards. The PDNA found that before the hurricane, the service was in a critical situation

with severely depleted equipment, unreliable private contractors, and lack of storage containers or transfer

facilities.

For the project, disposal of the debris from damaged and destroyed houses as well as the construction debris

that will be generated during reconstruction constitutes one of the more significant environmental

6 Dominica National Biodiversity Strategy and Action Plan 2014-2020, Ministry of Environment, Natural Resources,

Physical Planning and Fisheries, December 2013. The four National Parks (NP) are Morne Trois Piton NP (a

UNESCO world heritage site), Morne Diablotin NP, Cabrits NP, and Soufriere Sulphur Springs NP. The two Forest

Reserves are Central and Northern Forest Reserve. The total area covered by the NPs and Forest Reserves is 16,716

hectares. 7 Stagnant water in building and household debris such as fridges and stoves can be a source of mosquito borne illness. 8 The Fond Cole sanitary landfill of 18 acres is inter alia designated to receive (i) industrial waste including

construction and demolition waste, (ii) green waste including wood, and (iii) commercial waste including metals. The

Fond Cole landfill is filled near capacity, and a new landfill location for building debris is being considered.


challenges, that have to be managed during implementation. This will require arrangements that involve

the DSWMC, private waste disposal contractors, and the communities receiving assistance that are best

suited for various locations of project implementation best suited to easily dispose and recycle the waste.

Pesticide Application: Pesticides may be required for pest control (termites) in the rehabilitated or newly

constructed houses. If termite treatment or vector control treatment is to be utilized, appropriate chemical

management measures must be used to prevent contamination of surrounding areas, and only licensed and

registered pest control professionals with training and knowledge of proper application techniques can be

engaged. Any use of pesticides shall be approved by the Design and Supervision Firm to the area in

question, and all pesticides to be used shall conform to the list of acceptable pesticides that are not banned

by the relevant authority.

Asbestos Handling: Asbestos may be present in destroyed homes. The safe handling and disposal

procedure during the demolition will be applied with respective authorities including the Environmental

Health Department and the Dominica Solid Waste Management Corporation.

Chance Finds:

Physical Cultural Resources. While the civil works undertaken under the project are small scale, and while

most house reconstruction will be undertaken in situ, the possibility nevertheless exists of archaeological

chance finds from both pre-Colombian and later colonial and Creole settlements in Dominica. There has

been little research on and documentation of pre-Colombian settlements in Dominica, and only one known

site near the village of Soufriere in southern Dominica appear to have been excavated.9 However,

archaeological reconnaissance surveys in 2009 involved some excavation and systematic collection of

surface artifacts at six sites located across Dominica, and in 2010 more intensive investigations were

undertaken in the area around Castle Bruce on the east coast. Thus, pre-Colombian artefacts may be found

across the island as may physical cultural remains of later occupation. There is as yet no archaeological

legislation in Dominica, but the Physical Planning Act of 2002 states that PPD may impose conditions on

a grant of development permission (building permit) to arrange for “the preservation of any buildings or

sites of importance to the cultural heritage of Dominica.” In case of archaeological chance finds during

housing reconstruction activities, the location of the find will be reported to PPD and to the Dominica

Museum in Roseau (the national museum of Dominica), to which the find will be handed over.10 Should

the find appear to be part of a larger archaeological site, both PPD and the Museum in Roseau should be

consulted before civil works progresses.

Handling Skeletal Remains. The small-scale construction may result in a chance find of skeletal remains

on site. A chance find procedure will be used for handling the remains found with the Dominica Police

Force Central Investigation Department to take over the matter and construction would continue thereafter.

5.2 Social Conditions and Issues

Population: The 2011 census in Dominica found the total population to be 71,293, which represents a

decline of 0.6 percent since the 2001 census. The cause of this decline is an estimated out-migration of

9 Benoit Berard: The "South-Dominica" archaeological mission: the Soufrière site, Paper presented during the XXIIth

Conference of the International Association of Caribbean Archaeology, 23-29 of July 2007, Kingston, Jamaica. 10 The Dominica Museum is located at Dame Mary Eugenia Charles Boulevard in Roseau.


about 4,000 persons per year. This out-migration may also explain the sex ratio of 104.4 with 36,411 males

and 34,882 females. The census found that the total number of households in the country was 26,085

representing an 8.5 percent increase over the previous census. The reason for this increase is a decline in

the average household size from the 3 persons per household in 2001 to 2.7 persons per household in 2011.

Due to Dominica’s mountainous terrain, about 62 percent of the population are settled along its

approximately ninety miles of coastline.11

Housing Damage by Hurricane Maria: The Building Damage Assessment (BDA) conducted in

December 2017 covers about 24,300 private, commercial, and public buildings. The data shows that of

private homes, 18 percent (4,503 houses) were totally destroyed and requiring rebuilding, while 26 percent

(6,284) sustained major damage needing full roof replacement. A further 29 percent (6,996 houses)

sustained minor damage requiring minor roof and other repairs, and 27 percent (6,514 houses) sustained

only minimal or superficial damage, as shown in the table below. Medium‐size houses (500 to 1,200 sq.ft)

dominate the housing stock with 9,825 units, and of these 40 percent sustained major or total damage.

However, small house units (less than 500 sq.ft), which comprise 31 percent of the housing stock (7,525

units), sustained a higher level of major or total damage, affecting 62 percent of that group. Although only

a small percentage of large houses were totally destroyed, 30 percent sustained major roof damage.

Insurance penetration varied significantly. Of the destroyed houses, only 2 percent were insured; whereas

for all other damage categories, 15–20 percent were insured.

Distribution of Level of Damage and House Size for Private Houses and Home/Business Units

House footprint

House size

sq.ft

Destroyed Major

Damage

Minor

Damage

Negligible

Damage

Sub-Totals

Extra small

<200 836 304 271 248 1,659

Small

200 < 500 2,179 1,381 1,417 889 5,866

Medium

500 < 1200 1,225 2,740 3,059 2,801 9,825

Large

1200 < 2500 211 1,362 1,717 1,919 5,209

Extra large

> 2500 52 497 532 657 1,738

Subtotals

4,503 6,284 6,996 6,514 24,297

Source: HRP Project Appraisal Document based on the BDA database, MoHL, and UNDP,

January 2018.

In terms of the regional distribution of hurricane damage, the East Coast including the Kalinago Territory

and the South of the island were extremely impacted by the hurricane based on the percentage of damage.

These locations include some of the places with the highest rates of poverty and people still in emergency

11 The PDNA (p.16) assesses that 90 percent of the population lives along the island’s coastline.


centers as visualized in the map of Dominica showing the geographic distribution of buildings damaged

from Hurricane Maria.

Geographic Distribution of Building Damages

The BDA data were received from the UNDP in January 2018. It should be noted that when the project

starts implementation of housing reconstruction activities in 2019, the damage status of many homes will

have changed due to repairs undertaken by the owners or with support from other programs, though likely

less so for destroyed homes that were occupied by the vulnerable households that are the primary target

group for the project. The data is considered representative as a basis to cross-check the damage status

combined with site inspection checks of potentially eligible applicants. Moreover, the project could

consider to start implementation in one or two initial implementation areas with the highest levels of

destruction of houses below 500 sq..ft, and high levels of vulnerability and poverty (e.g. the Kalinago

Territory). This is charted in the following map showing damage disparities by building size and geographic

location.


Damage Disparities by Building Size and Geographic Location

The future home of 500 sq.ft, which is an option for households selected as beneficiaries of reconstruction

assistance, would adequately serve as initial replacement housing for those selected from the 3,015

households, who lived in hurricane destroyed homes smaller than 500 sq.ft. Moreover, with a national

average household size of 2.7 persons, the small home should provide basic accommodation for most

beneficiary families from this sub-set.

Land Ownership: There are no recent data on private land ownership, and the only available information

dates back to 2003.12 It describes access to private land as more widespread in Dominica than in other East

Caribbean nations, although the distribution of land is uneven. Of the farming population, 74 percent owned

parcels of land of 5 acres or less, but accounted for only 23 percent of the agricultural land. At the other

extreme, 1.3 percent of the farming population controlled about 35 percent of the agricultural land in parcels

exceeding 50 acres.

12 Dominica: Land Policy, Administration and Management: Country Experience by Allan N. Williams. In: Land

in the Caribbean – Proceedings of a Workshop on Land Policy, Administration and Management in the English

Speaking Caribbean, Land Tenure Center, University of Wisconsin-Madison, USA, October 2003.


While squatting on private land is relatively uncommon, squatting on state lands for farming and housing

has confronted Dominica’s Governments for many years. The number of squatter settlements on the island

is not known, but the majority of residential squatter areas are on state lands close to the two main urban

centers of Roseau and Portsmouth. State lands remain the primary source of land distribution, and the

Government actively regularizes squatters or works to prevent squatting from occurring. The State Lands

Act vests the President with the power to dispose of state lands by grant, sale, exchange or lease, and the

legislation has provisions for recognizing squatter rights (twelve years of undisturbed / unchallenged

occupation of land). Since the 1980’s, there has been regular interventions by successive Governments to

regulate squatter settlements. Under a public sector ‘Housing Revolution Program’ squatter settlements

have been regularized and the land sold at the concessionary price of EC$1.00 per square foot to

beneficiaries, notwithstanding the much higher open market value of land in the localities.

About 80 percent of residents including regularized (former) squatters have either a registered title, a

registered deed, or an unregistered deed. 13 Among the remaining 20 percent are households who have not

been able to pay registration costs to obtain a title document, and others who reside under informal

arrangements as tenants or leaseholders in houses they do not own, or in houses they own, but on land

owned by somebody else. The BDA recorded 418 households who were tenants or leaseholders, but the

PPD considers that the number is likely higher. Of these 418 households, about 25 percent had totally

destroyed homes. Tenants or leaseholders, who are likely to be among the poorer and more vulnerable, are

not included as potential project beneficiaries and would revert to other government housing programs.

Disadvantaged and Vulnerable Groups. Rural poverty continues to represent a major challenge, with 75

percent of the poor living in rural areas. Poverty rates are similar among men (28.8 percent) and women

(28.9 percent). The indigenous Kalinago people that represent 3 percent of the total population have a

particularly high incidence of poverty at 49.8 percent (approximately 1,600 individuals).

The specific focus of the project in terms of prioritization criteria is on (i) households that are still in

hurricane displacement centers, (ii) households that are recipients under the Public Assistance Program,

and (iii) particularly vulnerable households comprising single parent households with children under 15

years, households with a disabled household head, and households with an elderly household head. The

circumstances of these households are discussed below. Since these categories of prioritized beneficiaries

are likely to have limited access to information about the project, and also limited ability to act on such

information, the HRP Communication Strategy outlines multiple media channels to reach them and the

local government will be included to ensure they are aware of the project in order to apply. Further, a

Beneficiary Selection Review Committee will be set up to verify that home owners selected are the most

vulnerable who require assistance under the HRP.

Single Parent Households: While this section speaks to statistics on women, it is equally important that

men also fall into the category of single parent homes, taking into consideration the vulnerability factors.

There needs to be a careful balance with the household composition while women are prioritized. Women

represent 39 percent of the heads of households in Dominica. Although Dominica has made significant

strides towards gender equality, the impact of Tropical Storm Erika and Hurricane Maria have exacerbated

the challenges the country faces in this context. These challenges include increasing levels of gender-based

violence especially in lower socio-economic sectors. The PDNA notes that observational evidence suggests,

that there is a predominance of women, elderly persons, and children in the temporary shelters. Most of

13 The most recognized and common forms of tenure are (i) sole proprietor, (ii) joint tenants and tenants in common,

(iii) land held in common (family land), (iv) Communal land (Kalinago Territory), (v) qualified and possessory

proprietor, (vi) reserved encumbrance, and (vii) lease.


these elderly women (over 65) are also the head of household, and these households comprise five persons

on average. Most of the elderly men in the shelters were on their own. Site visit interviews highlighted

that many women, particularly the elderly women head of households, did not have housing insurance, and

they also were unable to move out of the shelters because they did not have access to housing material,

knowledge of where to source the material, or money to pay the labor needed to rebuild. Many of these

women are caregivers for grandchildren. Overall, the Vulnerability Needs Assessment prepared following

the storm highlighted that there were over 1,100 single mothers with uninsured houses that had either been

destroyed or severely damaged.

The project’s eligibility procedure prioritizes female headed households with dependent children. The

procedure comprises two steps, with the second step including criteria that accord priority in terms of

eligibility to households that are still in shelters and to single parent households with children below 15

years of age. In light of the situation reported from the shelters where grandmothers are caregivers for

grandchildren, the criteria should be tweaked to assign the same priority to such households. When the

HRP site verification is made to determine the level of house damage, effort should be made to identify

completely destroyed houses that were occupied by single parent households with children below 15 years,

including those still in shelters, and including households where grandmothers are caregivers for

grandchildren. The situation of elderly men in shelters noted by the PNDA may also call for an assessment

in terms of vulnerability.

Persons with Disabilities: Roughly 5.2 percent of Dominicans reported some kind of disability, of which

approximate 86 percent were medically diagnosed. A Disability Statistics Publication (2018) prepared by

the Central Statistics Office indicates that among people with disabilities, mobility (37.8 percent) and sight

(32.1 percent) are the most prominent forms of disability. When disaggregated, there is no significant

gender difference, but persons aged 35 and over are mostly challenged (79 percent). Chronic lifestyle

diseases, including hypertension, diabetes, obesity, and cancers were reported by 14.1 percent of males and

21 percent of females.

As in the case of households that are still in shelters and single parent households with children below 15

year of age, disability is also prioritization criteria. Applicants will be required to provide supporting

documents, including certification of a severe disability from a doctor, so that the presence of the disabled

person is flagged for attention at the outset. Notably, for beneficiaries with either mobility and sight

disabilities, the design of replacement houses need to accommodate their specific needs.

Health and Safety: Project activities will have potential impacts on the health and safety of the local

inhabitants, laborers and others involved in the housing reconstruction. Although the construction works

will be small in scale and distributed across the island, accidents can happen in connection with

transportation and storage of construction materials and debris, felling of trees, and construction activities

at house sites, and there are associated but minor impacts regarding increased levels of dust, noise, and

vibration. Therefore, appropriate personal protective equipment (PPE) must be used on site, and must be

provided to authorized visitors. In addition, on determination by the PIU, contractor camps need to be

provided with adequate sanitary/toilet facilities to avoid pollution, among other standard requirements. In

addition, workers will be required to follow a Code of Conduct to avoid conflict with neighbor

communities.

To minimize the risk of accidents on construction sites, access need to be restricted and controlled through

fencing and oversight (in particular, children should not be able to access building sites). Use of protective

clothing/equipment appropriate to the different activities associated with the housing reconstruction will be

defined in the Operational Manual and included in the contract with building contractors. Measures to


reduce construction related levels of dust, noise, and vibration are prescribed in the ESMP, which will be

part of the Operational Manual and also will be included in the contract with building contractors.

A specific issue concerns timber treated with Copper Chrome Arsenate (CCA), which acts as a preservative

and anti-pest (termite) treatment. CCA is found in the older timber housing stock, and is also used for new

construction in communities that prefer timber construction (e.g. Kalinago). Persons are not at risk of

arsenic poisoning from casual contact with CCA, as the level of arsenic exposure is not significant enough

to cause harm. However, care must be taken when working (sawing, sanding, machining, etc.) with CCA-

treated timber in a way that produces saw-dust. Appropriate personal protective equipment should be worn,

and these activities should take place outdoors. Disposal of CCA-treated timber debris from destroyed

houses and from construction should be done under the arrangements described above in the section on

‘building debris’ involving disposal at the DSWMC operated sanitary landfill at Fond Cole (or other

approved by the GoCD and the PIU).

Measures to deal with the health and safety issues and the handling/disposal of CCA-treated timber are

described in the ESMP, which will be included in the contracts with building contractors and contractors

disposing of debris.

Labor Influx. Although the owner-driven model for house reconstruction will involve beneficiary house

owners/occupants in reconstruction activities assisted by other community members with appropriate skills,

the house reconstruction will also involve pre-qualified building contractors along with modest labor influx.

Some of these contractors may come from other islands in the Caribbean. To manage the community-

contractor relationship, the project will follow the approach which has been successfully applied in other

civil works projects in Dominica using local contractors. This approach involves a meeting held before the

start of physical works between the Village Council14 and the contractor, where the PIU and the Building

Design & Supervision Firm if where feasible, TAC, will be represented, and where issues related to the

work and the contractor’s presence are discussed and agreed upon in writing. At this orientation meeting,

the Village Council is also informed about the HRP Grievance Redress Mechanism (GRM), and how

complaints relating to activities by the contractor and staff can be submitted and acted on by the PIU. As

a follow-up, quarterly meetings will be held involving the Village Council (and interested beneficiaries),

the PIU, and staff from the consulting firm that will support design and supervision services.

With regard to contractor ‘camps’, these will not be needed where contractors operate close to their home

base. If a ‘camp’ is needed, this would either be on Government or private land. Where suitable

Government land is available, an agreement is entered into between the contractor and Ministry of Housing

and Ministry of Public Works. If the ‘camp’ is located on private land, the agreement is between contractor

and land owner, and is submitted to the PIU. Due to the small size of Dominica, local contractor staff in

‘camps’ will be able to go home daily. When closing and dismantling work ‘camps’, contractors will

remove all equipment, dispose of debris (to the landfill at Fond Cole, or other approved by the GoD and

the PIU), and restore the site to the extent possible to pre-occupancy conditions. These requirements will

be included in works contracts and are included in the ESMP.

Indigenous People: Dominica was originally populated by Amerindian peoples, known as Caribs or

Kalinago, and is the only island in the Caribbean still to possess distinct communities of these indigenous

people. The Carib Reserve Act was enacted in 1978, the year of Dominican independence. It reaffirmed

the territorial boundaries first established by colonial authorities in 1903, and legally established common

14 In the Kalinago Territory, such meetings will involve the relevant Hamlet Development Committee and

representatives from the Kalinago Council.


ownership of land within the reserve. In March 2015, an amendment was made that changed the name to

the Kalinago Territory Act. Prior to that, the Government of Dominica had ratified the Indigenous and

Tribal Peoples Convention (ILO 169), and signed the UN Declaration on the Rights of Indigenous Peoples

in 2007. 15 A Department of Carib Affairs was established in 2000 and upgraded to a Ministry of Kalinago

Affairs in 2014.

The Kalinago Territory comprises 3,782 acres stretching over 9 miles on the East coast of Dominica in the

Parish of St. David. There are eight hamlets with a 2011 population of 2,145 consisting of 652 households

with an average size around 3 persons. 16 The population exhibits an even more pronounced imbalance

between males (56.5 percent) and females (43.5 percent) than Dominica in general.

The Kalinago Territory Act describes the establishment of the office of the Kalinago Chief, the Constitution,

and powers of the Kalinago Council. All land in the Territory is under the custody and management of the

Kalinago Council, and no individual can buy or sell parcels of land or use land as collateral for loans. The

Council is solely responsible for allocating land for all purposes including housing, public conveniences,

Government projects, and community projects.

Hurricane Maria wrought very extensive damage on housing in the Kalinago Territory. In addition, a much

higher poverty rate (at 49.8 percent) compared with the national level (at 28.8 percent) diminishes the

capacity of the Kalinago to undertake repairs with their own resources, and access to finance is practically

non-existent since land cannot be used as collateral for loans. Figures on the exact level of damage from

Hurricane Maria varies between the BDA and a housing damage assessment in the Kalinago Territory by

the Caribbean Disaster Emergency Management Agency (CDEMA), but both find the proportion of totally

destroyed houses to be more than twice as high as the national level. The BDA and the CDEMA assessment

also differ regarding the number of homes (and by implication households) in the Kalinago Territory. With

an increase in the number of households at 10 percent comparable to the growth recorded by the Census

between 2001 and 2011, the total households in 2018 would be around 700.

Damage Assessments for Kalinago Territory and Nationally

Impact on houses

BDA CDEMA Assessment BDA National

Houses % Houses % Houses %

Negligible damage

89 10 131 17 6,514 27

Minor damage

181 20 108 14 6,996 29

Major damage

128 14 169 22 6,284 26

Destroyed

487 56 363 48 4,503 18

TOTAL

885 771 24,297

15 http://www.ilo.org/dyn/normlex/en/f?p=1000:11200:0::NO:11200:P11200_COUNTRY_ID:103311 16 The hamlets are Sineku, Gaulette River, Mahaut River, St. Cyr, Salybia, Crayfish River, Bataka and Touna Concord.

In addition, the village of Atkinson outside the Kalinago Territory is also inhabited by Kalinago.

http://www.ilo.org/dyn/normlex/en/f?p=1000:11200:0::NO:11200:P11200_COUNTRY_ID:103311


The discrepancies between the BDA and CDEMA assessments highlight the need to conduct verification

of house damage level that will be conducted by the Technical Services (architects/engineers) consultants

hired under the HRP during the beneficiary selection assessment process that inform the selection of

beneficiaries. This update should serve as the basis for an allocation of the number of houses to be

reconstructed in the Kalinago Territory, and this should consider the very high level of damage together

with the constraints described above that limit local capacity for housing repair. It should further be

considered to deploy the Technical Services consultants and the Design and Supervision Firm early to the

Kalinago Territory to expedite the start of civil works.

As mentioned above, the Kalinago Council is responsible for allocating land for all purposes including

housing. An implication of this is, that the exclusion clause in the beneficiary eligibility criteria regarding

house site hazard risks can be amended for the Kalinago Territory for cases where the Council can allocate

an alternative housing plot without hazard risks for the reconstructed house. As required by OP 4.10 on

Indigenous Peoples, this and other issues regarding the selection of beneficiaries, and the practical

implementation arrangements (e.g. involvement of local labor, location of contractor camp(s), and disposal

of debris) should be decided in consultation with the Kalinago Territory Housing Committee. 17

17 The Kalinago Territory Housing Committee comprises representatives from the Kalinago Council, the Ministry of

Kalinago Affairs, and the Ministry of Housing & Lands.

SECTION 6: ENVIRONMENTAL & SOCIAL MANAGEMENT -

ADDRESSING SFEGUARD ISSUES

Both the environmental and social impacts and risks of the project are related to Support for Reconstruction

of Houses (Component 2), which will take place in different locations across Dominica. Project activities

will involve new construction of about 1,700 destroyed houses, and technical advisory services to the

beneficiaries of these houses, and to homeowners undertaking repairs without project financing. The

selection of beneficiaries for housing reconstruction assistance, the house design and agreements with

beneficiaries on construction of replacement houses, and the subsequent civil works all involve

consideration of environmental and social issues. Therefore, rather than separate the consideration of

environmental and social issues as they relate to beneficiary selection, house design and planning, and civil

works, these issues and the associated measures to mitigate and manage them are dealt with below as part

of the implementation process that progresses from beneficiary selection to the civil works for housing

reconstruction. The link between the predicted environmental impacts, the needed mitigation measures

identified during the screening and assessment process, provisions for budgeting the costs of such measures,

and the roles of those responsible for ensuring that the mitigation measures are carried out are summarized

in Annex 6 – Mitigation Table, Responsibilities and Costs.

6.1 Beneficiary Selection Process

Before the selection of individual beneficiary households for reconstruction assistance can be done, the

following activities have to be undertaken.

• Communication and outreach on the project, the application process, and the call for application.

First, an information campaign island wide should be conducted to inform the population about the

project approach, the criteria for beneficiary selection, and the deployment of the Technical

Services (architects/engineers) consultants to conduct the site assessment for eligibility, the

responsibility of the Design and Supervision Firm and that of both the building contractors and the

homeowner, as well as the GRM available to address complaints and resolutions. The information

campaign should inter alia use a range of media channels such as radio, village meetings (Village

Council / Hamlet Development Council), and printed materials with an easily understandable

rendering of the approach from beneficiary selection through construction (e.g. a flyer/leaflet)

where suitable. Since the project intends to refer households that were not eligible under its

beneficiary selection criteria to other projects and programs providing housing reconstruction

assistance, it is important that the result of this effort is also made public at the Village Council

office and on-line at the end of the selection.

• Intake and registration of applicants.

• Application by interested persons with required supporting documents.

• Cross-checking of the eligibility criteria 2 in Step 1 based on the physical damage and the

production of list of applicants that meet these criteria (using the existing BDA and other

databases).

• A preliminary identification of ‘destroyed’ residential houses will be done by the PIU based on

BDA data.

• In cases where applicant’s information could not be cross-checked and where hazard risk needs be

cross-checked, on-site building assessments will be conducted by the Technical Services

(architects/engineers) consultants to verify their status as ‘destroyed’. A report on flood hazard


assessment conducted by the World Bank Flood Hazard Assessment Specialists will be submitted

to the PIU for use by the Technical Services consultants to inform further assessment on same at

the specific applicant’s home. These assessments also need to include the eligibility criteria under

Step 1 and 2 in the table on the following page, such as environmental hazards involving slope

stability, landslide and flooding risks, and demographic data on household composition. Effort

need to be made to establish whether any ‘destroyed’ homes were occupied by households that are

still in displacement centers (of which the PDNA found many were female headed with

dependents).

• Cross-checking of eligibility criteria based on the data in the application form (Annex 7 – HRP

Application Form) and supporting documents on socio-economic vulnerability, including

verification of public assistance support on the Public Assistance Program that the homeowner is a

beneficiary among other criteria.

• List of eligible applicants compiled. Based on the assessments and information collected by the

Technical Services (architects/engineers) consultants, the PIU will compile a list of eligible and

prioritized homeowners after completing the Beneficiary Household Score for each applicant.

• Verification and validation by a Beneficiary Selection Review Committee which includes no more

than seven members, involving representatives from local government, religious, NGO or other

civic group, prominent local citizen, and professional/academia representatives for the respective

area. This list will be subjected to a verification and validation by the Beneficiary Selection Review

Committee who will produce a list of confirmed beneficiaries. Section 4 under HRP Committees

lists the specific composition of the said committee.

• Publication and notification of selected beneficiaries. The beneficiary list will be made public at

the Village Council office and on-line (project web-site at MoHL) as a final step in validation and

confirmation.

• Processing of appeals and other grievances.

If construction will be implemented sequentially, another planning activity should involve identification of

the Districts and project implementation locations, where the Design & Supervision Firm and contractors

will start operations based on considerations of the relative severity of housing damage in different areas

drawing on the results from the beneficiary HRP application assessment.

The eligibility criteria that will be applied in the beneficiary selection process including the household score

sheet involve both environmental and socio-economic considerations. The selection will comprise three

‘steps’, with Step 1 covering a set of eligibility criteria that determine whether home-owner applicant meets

the physical and socio-economic criteria of the project as a potential beneficiary, and which involve on-site

assessments. Step 2 will enable a categorical prioritization among the potentially eligible beneficiaries

based on socio-economic and demographic vulnerability criteria, which address protracted displacement,

poverty status, gender, and disability considerations. Step 3 will consist of verification and validation

involving a review of the final list of the beneficiaries by the HRP Beneficiary Selection Review

Committee, who will produce a list of confirmed beneficiaries. This list will be made public locally and

on-line (project website at MoHL) as a final step in the validation and confirmation.


Houses/households that comply with all eight eligibility criteria would be potentially eligible, and would

be considered in terms of the prioritization criteria under Step 2. However, if criteria #5 under Step 1 on

‘low hazard risk’ receives a ‘no’, the site should be assessed to determine whether a potential re-siting

within the property could mitigate the risk and make the house/household eligible. For households in the

Kalinago Territory, the question to be asked if criteria on ‘low hazard risk’ receives a ‘no’, is whether the

Kalinago Territory’s Housing Committee can allocate an alternative housing plot without hazard risks for

the reconstructed house.

Criteria under Step 2 will be used to prioritize selection of the potential beneficiaries that complied with all

the criteria under Step 1. With the exception of 1.a and 1.b , the attributes under Step 2 are not mutually

exclusive. Thus, a household may still be in a hurricane shelter, be a recipient of the Public Assistance

Program, and be either a single parent or caregiver (e.g. grandparent) with a household including children

below 16 years, or have a disabled or elder head of the household. Households that meet eligibility criteria

for each of the three attributes would obviously qualify for prioritization. However, since the listing of the

three attributes does not signify a ranking in terms of priority, a decision is required on how to rank

households that do not meet eligibility criteria for all three attributes. The simplest solution would be to

group household into four descending levels of priority and apply numeric weights to the criteria: (1)

households that meet eligibility criteria for each of the three attributes, (2) households that meet eligibility

criteria for two attributes, (3) households that meet eligibility criteria for one attribute, and (4) households

that do not meet the eligibility criteria for any attribute. With respect to applying numeric weights, for

instance, more weight is given to persons in shelters, more weight to households with children, and so forth.

The weights can be expanded to also include another category for household composition. Hence, in

addition to weights for the household head (an indicator of capacity difficulty to finance their own home

reconstruction – captured in 3a 3b and 3c); a new vulnerable subcategory can be added on household

composition to weight households with children, a disabled member (certified severe disability) and

elderly). This is outlined in a separate prioritization scoring sheet and beneficiary ranking table not included

in this document.

It is critical that the first two steps of the beneficiary selection process, and in particular the attributes and

eligibility criteria for prioritizing and ranking potential beneficiaries, is communicated in a transparent,

clear and understandable terms to the public. This will eliminate (or at least significantly reduce) uncertainty

about who gets selected as beneficiaries. As a result, the outcome of the verification and validation under

Step 3 would be less challenged, and the volume of complaints to the Grievance Redress Mechanism

(GRM) regarding beneficiary selection would be reduced.


ELIGIBILITY CRITERIA, PRIORITIZATION & VERIFICATION

STEP 1: APPLICATION OF ELIGIBILITY

CRITERIA

STEP 2: CATEGORICAL PRIORITIZATION

AMONG ELIGIBLE HOUSEHOLDS

STEP 3: VERIFICATION

AND VALIDATION

PHYSICAL

Attributes Criteria Complia

nce

Attributes Prioritization Complia

nce

Activit

y

Source

Y

E

S

N

O

Y

E

S

N

O

1. House si

ze

Up to 500 sq. ft. 1. Protract

ed

displace

ment

a. Household is still living in a shelter

Verific

ation

List of eligible beneficiaries

(criteria verified by

local

inter‐sector committee)

2. Damage

Level

Completely destroyed

(BDA or site visit

where needed)

b. Household is still

living with others

Validat

ion

Information on the

application from

homeowner

3. Primary

Residen

ce

House is primary

residence prior to

hurricane

2. Demogra

phic

Vulnera

bility

a. Single parent hous

ehold with childre

n under the age of 16

Validat

ion

Final list is publish

ed for

transparency and feedback

4. Right to

the land

Ownership of the

property or

documented permission to use the property

b. Disabled head of h

ousehold

(including sight, mobility, speech,

mental)

5. Locatio

n

and risk

Low hazard risk area c. Elderly head of household

6. Not

impacti

ng

protecte

d area

or forest

reserve

Location must not be in protected area (PA) or

within 200 metres of

the PA

d. Existence of elderly dependent

SOCIO-ECONOMIC

7. Prior su

pport

Applicant has not recei

ved direct

reconstruction/structural

restoration of their

homes through Government or

donor housing program

3. Poverty

Status

a. Household is a reci

pient of

any Public Assistance

Program

8. Insuran

ce

coverag

e

Home is uninsured b. Part of house was

used as a source of livelihood/income

c. Unemployed due

to Hurricane Maria

6.2 Informal Occupancy

According to the BDA, of the 418 households who were tenant or leaseholders, about 25 percent had been

tenants in homes that were totally destroyed. Consultations with villagers have confirmed that there are two

distinct situations of tenancy. One is where the tenant/occupant owned neither the house or the land, and

the other where he/she owned the house but not the land. The HRP does not provide support to tenants

who do not have titles to house or property. Further, the project does not support commercial property. The

project however supports owners of the house who may not own the land, provided that the homeowner

can furnish official documents to proof ownership of the house. An agreement would be required between

house owner and the land owner.18

The intended beneficiary of project assistance must also be the occupant of the house as his/her primary

dwelling at the time of the hurricane. In addition, there is the need to define some form of secure home

owner in the replacement house. This period cannot be the economic life of the house (e.g. about 30 years),

because that would amount to expropriation of the land from the owner, and trigger OP 4.12 on Involuntary

Resettlement. The alternative is an agreement between the land owner and the home owner regarding

security of occupancy in the reconstructed house for a period considered long enough for the home owner

to recover economically and socially from the hurricane (e.g. 4-5 years), and occupancy during that period

should be under the same conditions as in the original arrangement of the house prior to the hurricane (that

is, if there is a rental fee for use of land, the fee should not suddenly increase beyond the existing fair market

rate in the area).

An agreement must be drawn between the land owner and home owner regarding legal ownership of the

reconstructed house after the period of secure occupancy. In the situation where the tenant had owned the

hurricane destroyed house, but not the land, he/she would also own the reconstructed house. At the

expiration of the period of secure occupancy, the landholder would negotiate with the tenant as to whether

(a) he/she continues occupation of the land, or (b) the landholder purchases the building at the fair market

value of the building at the time of the eviction. Moreover, in the second scenario where the beneficiary

owned the hurricane damaged house, he/she would at the planning stage be able to have the new

replacement house constructed on a different self-identified plot of land (e.g. a plot of land assessed as

hazard free, that he/she owns somewhere else in situ). This would need to be in good standing with the

current applicable laws in Dominica.

6.3 Environmental and Social Management Plan (ESMP) for House Construction

The houses/households that have been selected for the project housing reconstruction grant will receive

technical assistance from the project (the TACs with support from the Design & Supervision Firm funded

under Sub-Component 2.2) to decide on a house design that is within their financial resources (the project

grant and the beneficiary’s own resources), and to prepare the building design along with specifications and

cost estimate. The value of the grant will be equivalent to the estimated cost of building a modular core

house (about EC$50,000), with basic specifications and an area of approximately 500 sq. ft. The technical

standards to be applied under the project are based on a revised version of the Guide to Dominica’s Housing

Standards (2018) which are applicable to seismic and Category 5 hurricane events. 19 These standards will

be applied by the TACs/Design & Supervision Firm and the contractors to all rebuilds receiving direct

support under the project. Achievement of the standards will also be evaluated and monitored by the

18 Consultations with villagers also suggested that many land owners live abroad, and would need to be contacted

there concerning their consent to an agreement on reconstruction and security of home occupancy arrangements. 19 The Guide to Dominica’s Housing Standards updates and amends the building regulations (Building Code and

Building Guidelines) and the Physical Planning Act of 2002 to adequately and effectively respond to the need for

recovery in the housing sector. The 303 sq.ft area is defined as adequate for a basic modular core house.


TACs/Design & Supervision Firm. The design options comprise reconstruction of the existing house

incorporating design features to make it hurricane resilient, a prefabricated structure erected on site, a

modular house model (partially prefabricated or standardized) erected or built on site, and a fully custom-

designed house.

During the assessment of environmental hazard risks for potential beneficiary housing sites that was

undertaken during Step 1 of the beneficiary selection process, all destroyed houses found to be exposed to

such risks involving erosion or slope stability and landslide risks have been excluded as ineligible for

reconstruction assistance (unless they could be re-sited to a location without environmental hazard risks on

the beneficiary’s property). The environmental, social, health and safety impacts to be considered during

construction therefore involve only those related to good practice management measures for small-scale

construction works.

For the houses/households that have been selected, verified and validated, and for which the hurricane

resilient building design has been finalized and agreed to, the format for a simple environmental and social

management and plan (ESMP) guided by the HRP PIU safeguards specialists outlined in Annex 8 will be

used. The Design & Supervision Firm will be required to conduct compliance monitoring of the ESMP

before, at start, during and upon closure of site/decommissioning of site.

The Design & Supervision Firm will discuss and manage issues, including the Code of Conduct related to

the Contractor’s work with Village/Kalinago Councils and the beneficiaries. The Code of Conduct and

other standard operating procedures will be included in the ESMP. At this meeting, the Village Council

will also be informed about the Grievance Redress Mechanism (GRM), and how complaints regarding the

project including those relating to activities by the contractor and staff can be submitted and acted on by

the PIU.

Moreover, before construction activities start in selected implementation locations, the Design &

Supervision Firm will provide training and awareness to the beneficiaries (if involved in house

construction), skilled labor (e.g. masons, carpenters), and unskilled laborers on (i) the use of construction

equipment and the associated risks and safety issues, (ii) safety precautions when working on demolition,

debris removal, and housing construction activities, and (iii) other activities required to ensure compliance

with the ESMP.

If a ‘camp’ is needed, this would either be on Government or private land. As noted in Section 5.2 on

Health and Safety, Contractor ‘camps’ will not be needed where contractors operate close to their home

base. Where suitable Government land is available, an agreement is entered into between the contractor

and Ministry of Housing and Ministry of Public Works. If the ‘camp’ is located on private land, the

agreement is between contractor and land owner, and is submitted to the PIU. When closing and

dismantling work ‘camps’, contractors will remove all equipment and dispose of debris (to the landfill at

Fond Cole or other approved by the GoD and the PIU), and restore the site to the extent possible to pre-

occupancy conditions. These requirements will be included in works contracts.

6.4 Grant Agreements with Beneficiary Households

The project will enter into a Grant Agreement with selected beneficiary households regarding the

reconstruction of their house. This agreement will record:

• Names and unique identifier of all project beneficiaries and contact information

• The location data of the house (including geo-reference data), the type of title document, and that

a building permit has been obtained.


• Copies of accompanying documents of proof of identification and ownership / right to occupy

site/property.

• Acceptance letter.

• Site assessment report.

• Agreement regarding any re-siting of the replacement house on the beneficiary’s property to

mitigate natural hazards, which posed a risk for reconstruction in the original site.

• Banking details. Information on the beneficiary’s banking institution, the National Bank of

Dominica, a mandatory requirement specific to the HRP.

• The contribution committed by the beneficiary towards the construction in terms of funding, labor,

and materials, as well as the financial ceiling to be applied to the house reconstruction and site

works. A beneficiary may choose an option costing more than the grant, and the agreement will

verify that the resources available including the project grant are sufficient to construct the selected

house design.

• The mode of payment of the project grant in two or three tranches, and the milestones in the design

and construction of the house that will trigger payments.

• Design/construction documents. The beneficiary’s choice regarding the design of the house to be

built (type, size, features). A full set of construction drawings, and as the project advances, the

agreement should be amended to include change orders, and then upon completion the as-builts

should be included.

• The beneficiary’s choice of construction approach. That is whether construction by building

contractor, or managed by the beneficiary with local labor.

• Copies of all communications (electronic communication, call logs, meeting notes, etc.)

• Associated filed grievances.

Prior to the finalization of the Grant Agreement, the Technical Services (architects/engineers)

consultants/Design & Supervision Firm will inform each beneficiary fully of the procedures involved in the

housing reconstruction support under the project, the design and supervision assistance, and the options

available to them. Alternatively, it may be simpler to have enrollment sessions in each district with selected

beneficiaries, at least to convey the essential information initially. The assistance to be provided by the

project will include:

• Consultation with each beneficiary on the house design options available within their individual

financial resources, and preparation of a design, specification and cost estimate for the preferred

option (utilizing simplified documentation as much as possible).

• For disabled beneficiaries, the chosen design must include features that make the house disabled

friendly.

• Compilation of available legal information on the beneficiary’s property (a registered title, a

registered deed, or an unregistered deed), and if neither of these are available, assistance to the

beneficiary to obtain a title document (if not waivered for beneficiaries of the housing

reconstruction project, registration costs may be paid from the grant). Particular effort may be

required to assist beneficiary households headed by single parent, disabled, and elderly.

• For selected beneficiaries that are house owners on land that is owned by someone else, assistance

with contacting the land owners to obtain their consent to the reconstruction, and to the

conditionalities regarding security of home ownership.

• Assistance to the beneficiary to apply to PPD for the required building permit (free of cost).


• Where required, assistance to the beneficiary to shop for quotations from certified (pre-qualified)

building contractors or certified suppliers of building materials, and with review of a draft contract

or supply arrangement, prior to signing by the beneficiary.

• Assistance and information to the beneficiary regarding construction supervision comprising

regular site inspections and supervision of building works (including instructions for remedial

actions) and ESMP compliance, certification at key stages to ensure compliance with the design

specifications and resilience requirements, and reporting on the progress and stage compliance to

the beneficiary’s banking institution, and the PIU. This would also include assistance with the final

inspection for the Certificate of Completion from the PPD, and explanation of the rights of the

beneficiary during the Defects Liability Period. Here too, particular effort may be required to assist

beneficiary households headed by single parent, disabled, and elderly.

6.5 Indigenous People – The Kalinago

As described in Section 3.2, the Kalinago Territory Act of 2015 vests ownership of the Kalinago Territory

with the Kalinago people. All consultations regarding the preparation and implementation of the Housing

Recovery Project will be conducted through the Kalinago Council and the Ministry of Kalinago Affairs

(MoKA). The Council comprises seven elected members including the elected chief. Moreover, all land

within the territory is communally owned by the Kalinago, and under the Kalinago Council, the Kalinago

Territory Housing Committee, which comprises representatives from the Council, MoKA, and MoHL, is

responsible for allocation of land for housing. The Kalinago Territory of 3,782 acres comprises eight

hamlets organized into seven Hamlet Development Committees (two hamlets are covered by one

committee). In addition, the village of Atkinson, which is populated by Kalinago, but is not part of the

Kalinago Territory, is also included under the charge of MoKA.

Thus, the institutional framework exists for ensuring free, prior, and informed consultation resulting in

broad community support to the project by the Kalinago people as required by OP 4.10 on Indigenous

Peoples, and such support has been expressed during the initial consultations already held in the area. The

project’s overall approach to community engagement would also, with a few adaptations, suit conditions in

the Kalinago Territory:

1. The Kalinago Council and MoKA are the principal counterparts during preparation and

implementation of the project in the Kalinago Territory.

2. Hamlet Development Committees instead of Village Councils would be the entry-point for the

project’s information dissemination and local operational arrangements in the Kalinago Territory.

3. While the three-step selection process for project beneficiaries appear to suit conditions in the

Kalinago Territory, it should be reviewed in consultation with the Kalinago Council and MoKA,

and be adapted as required.

4. There are three areas where the beneficiary selection criteria and also the Grant Agreement with

beneficiaries would need to reflect Kalinago land tenure arrangements (consult the IPP for land

tenure process).

a. Under Step 1 of the beneficiary selection criteria, households would be excluded if their

destroyed house is located on a site assessed to have high hazard risk (and where it cannot

be re-sited within the property). Such cases would need to be referred to the Kalinago

Housing Committee, which would then confirm whether an alternative plot without hazard

risk can be allocated to the household.

b. Whereas the housing reconstruction Grant Agreement applicable to the rest of Dominica

will require confirmation from PPD that the beneficiary has documentation of ownership,

the requirement in the Kalinago Territory would be confirmation from the Housing


Committee that the plot where the replacement house will be constructed was duly

allocated to the occupant (or ancestors) at some point in the past.

c. The Housing Committee normally reviews and approves building permits in the Kalinago

Territory, and it would likely also see a role for itself regarding review and clearance of

the application for building permit under the project.

5. Finally, the project’s GRM arrangements and process would also have to be discussed with the

Kalinago Council and MoKA to ensure that they fit with the culture and governance arrangements

in the Kalinago Territory.

An initial activity in the engagement with the Kalinago Council and MoKA should be to review and agree

on the beneficiary selection criteria and process that would apply in the Kalinago Territory. During

consultations, both the Kalinago Council and MoKA have made the point that since poverty is widespread,

and since even the preliminary damage data indicate that the proportion of totally destroyed houses in the

Kalinago Territory was more than twice as high as the national average, consideration should be given to

an early start of project implementation in the Kalinago Territory.

Finally, the Kalinago Council has emphasized that as much as possible the housing reconstruction work

should be done involving local labor, which would help address the high unemployment in the area. In this

regard the project could assist with training and technical assistance.

6.6 Forest and Timber Resources

Dominica does not have any large-scale forest operations. The island’s steep topography limits access to

its forests, and timber processing is largely for local consumption. Hurricane winds and intense rainfall

produced widespread damage to the forest system, and the PDNA estimates that 10 to 20 percent of the

trees in the forests throughout the island were completely knocked down. For the remaining 80 percent of

the forest area, it is expected that the trees that survived the hurricane, although stripped of leaves, will be

able to re-establish a closed canopy.

Total forest damages are estimated to amount to EC$80.24 million (US$29.72 million). The forest area

with trees usable for construction is estimated to cover 9,552 ha (23,593 acres). Based on a PDNA field

visit in October 2017 it is estimated that approximately 20 commercial trees species were blown over or

destroyed by the Hurricane. These figures suggest that there would be about 47,000 hurricane destroyed

trees of which a proportion would be useable for construction lumber, where they can be accessed.

Timber is one of the basic construction materials used in the remote rural areas. The reconstruction of

houses will increase demand for timber, and measures to make use of available downed trees and manage

the risk to Dominica’s extensive forests could include:

• In addition to the re-use of salvaged timber from demolished buildings, the project could wherever

possible, promote the re-use of trees downed by the hurricane (removal and salvage clearing of

fallen forest trees to supply construction timber). The quality of such timber should be verified with

the Forestry, Wildlife and National Parks Division.

• The Government could consider facilitating a distribution and selling process of fallen trees in the

various forest areas of the country for the reconstruction to simplify the supply of necessary timber.

At a consultation in the Kalinago Territory, members of the Kalinago Council proposed that a

process be established to enable that fallen trees in nearby forest areas are utilized for house


reconstruction (they argued that most of the hurricane destroyed houses in the area were built with

imported lumber which was inferior to that harvested locally).

• A practice commonly used in Dominica to salvage fallen trees and to convert round logs into

building material is chain-saw lumbering.20 The Forestry Division maintains a list of 120 chainsaw

operators, to whom it has sold trees in the past. The PDNA suggests that chainsaw operators could

be encouraged to salvage as much wood as possible, and that operators who do not have a saw

could be provided with one through a lease agreement. Upon completion of any such task the saw

and sawmill would be returned to the Forestry Division in order to establish management control

of the milling activity beyond the project.

6.7 Cultural Heritage

The likelihood of archaeological chance finds is limited since most houses will be reconstructed on the

original foot-print. However, pre-Colombian artefacts may be found across the island as may physical

cultural remains of later occupation. There is as yet no archaeological legislation in Dominica, but the

Physical Planning Act of 2002 states that PPD may impose conditions on granting a development

permission (building permit) to arrange for “the preservation of any buildings or sites of importance to the

cultural heritage of Dominica.” In case of archaeological chance finds during housing reconstruction

activities, the location of the find will be reported to PPD and to the Dominica Museum in Roseau (the

National Museum of Dominica), to which the find will be handed over. Should the find appear to be part

of a larger archaeological site, both PPD and the Museum in Roseau should be consulted before civil works

progresses.

20 This is done by so-called Alaskan mill lumbering, which involves cutting boards with a frame-mounted chain-saw.

SECTION 7: COMMUNICATION: CONSULTATION,

INFORMATION DISSEMINATION

During preparation of this ESMF, consultations were held about the project’s environmental and social

aspects with relevant ministries and departments of the Government, potential beneficiary groups, and with

the Kalinago Council and MoKA. Notes from these consultations are attached in Annex 11 of this

document. Prior to that, initial consultations were held with the Kalinago community during project

preparation in February 2018, and by the Government in connection with preparation of the draft

Indigenous Peoples Plan.21 The finalized Indigenous Peoples Plan was disclosed and can be found at the

following link: http://dominica.gov.dm/notices/870-indigenous-peoples-plan-housing-recovery-project .

Nation-wide Information Campaign: Project implementation should be preceded by nation-wide

information campaigns using radio, television, online media, and community information sessions and

other communication channels.22 The focus should be on informing the public about the scale of the project

(1,700 destroyed houses to be reconstructed), the geographical locations where TAC/Design & Supervision

Firm staff will be deployed to start implementation, the eligibility criteria and beneficiary selection process,

application procedures and locations; the technical assistance and advice that will be available to project

beneficiaries, and the Grievance Redress Mechanism (GRM). A brief (preferably one page) flyer/leaflet

giving a simple illustrated portrayal of the approach from beneficiary selection through construction should

also be considered.

Local Level Consultations: Following the deployment of TAC/Design & Supervision Firm staff to the

geographical locations where village level activities will take place, consultations will take place with

Village Councils as follows:

• A meeting should be held before the start of physical works with participation by the Village

Council, the contractor(s), the PIU (including environmental and social staff), and the TAC/ Design

& Supervision Firm. Issues related to the work and the contractor’s presence should be discussed

and agreed upon in writing. This would inter alia include (i) agreement on a ‘code of conduct’ for

contractor and staff, (ii) a commitment to conduct activities which generate noise or involve

movement of heavy trucks during the periods of the day that will result in the least disturbance, and

(iii) location of the contractor camp, if a camp is required.

• At this meeting, the Village Council should also be informed about the GRM, and how complaints

can be submitted and will be acted on by the project.

• After the project’s identification of beneficiaries, a meeting of the Beneficiary Selection Review

Committee involving representatives of the Village Council, religious, civil society, among other

groups, will be held to review, verify and validate the list and agree on the confirmed beneficiary

households. This list, which will include both project beneficiaries and households referred to

assistance from other projects and programs, will be made public at the Village Council office and

on-line (project website at MoHL) as a final step in validation and confirmation.

• Follow-up meetings between Village Council (and interested beneficiaries), contractor(s), the PIU,

and staff from TAC/Design & Supervision Firm should be held at least monthly to (i) report on the

21 Finalization of the ESMF will require further consultations with the relevant stakeholders including the Kalinago

Council and interested members of the public. 22 The Project Results Framework stipulates three information campaigns in the first year of implementation, and at

least one campaign a year in the following years.

http://dominica.gov.dm/notices/870-indigenous-peoples-plan-housing-recovery-project


status of construction, (ii) discuss and if possible, resolve complaints received through the GRM,

and (iii) deal with any other issues of importance for implementation progress and project-

community relations.

In the Kalinago Territory, similar meetings should be held at the level of the Kalinago Council and with

the Hamlet Development Committees where project implementation is taking place. Consultations held

before the start of civil works between the project and the Kalinago Council and MoKA include:

• As described in Section 5.5, consultations should be held with the Kalinago Council and MoKA

before the start of civil works to agree on the modifications that may be required for the beneficiary

selection criteria and process to ensure compatibility with the decision-making processes and land

tenure arrangements in the Kalinago Territory. Additionally, it should be considered in which areas

the project’s GRM would need to be modified to fit with the Kalinago culture and governance

arrangements.

• Another early exercise to be undertaken before the start of civil works comprises collaboration on

updating and verifying the information on housing damage (the BDA), in order to enable the

identification and selection of beneficiaries based on the project methodology (or a modified

version of this).

• Meetings to review, validate, and confirm the list of selected project beneficiaries that met the

criteria of Step 1 and 2 will take place at the level of the Hamlet Development Committee with

representation from the Kalinago Council. Here too, the list will include both project beneficiaries

and households referred to assistance from other projects and programs, and will be made public at

the Hamlet Development Committee’s office and on-line.

• Issues related to the contractor’s presence and work should be discussed and agreed upon in writing

at the level of the Kalinago Council and MoKA. Where needed, the Kalinago Council should help

identify locations for contractor ‘camps’.

Similar to elsewhere in Dominica, consultations should be held at the start of project implementation at the

level of the Hamlet Development Committees, and with participation of representatives from the Kalinago

Council, to inform about the agreements reached concerning the approach to beneficiary selection,

grievance redress procedures, and the presence and conduct of contractors and workers. Follow-up

meetings on the progress of civil works, complaints, and other issues similar to those involving Village

Councils should be held at regular intervals.

SECTION 8: CAPACITY BUILDING

Capacity building will be important for the implementation of the safeguard-related activities described

above, and will be required at different levels of the institutional set-up for the project. Safeguards staff

from the PIU (supported by their counterparts from the IST) will provide safeguards related capacity

building for the TACs, for local government entities comprising the Village Councils, and the Kalinago

Council and Hamlet Development Committees in the Kalinago Territory. The capacity building in

environmental and social safeguards will cover three aspects.

Project Safeguards Staffing: In addition to the PIU level safeguards staff, each of the TACs and satellite

TACs will, as described above in Section 8, need to have one of its staff designated as responsible for day-

to-day safeguards management at the implementation level of Village Councils and Hamlet Development

Committees. The tasks of such designated TAC safeguards staff will include (i) collection of demographic

data on potential beneficiary households to assist updating of the BDA, (ii) participation in meetings that

will be held at different stages with Village Councils and Hamlet Development Committee (on the project

approach, on verification and validation of beneficiaries, on project progress and issues), (iii) participation

in the monitoring of ESMP compliance, and (iv) being the local focal point for the GRM and responsible

for data entry into the GRM database on complaints and complaints resolution within the area of the TAC

or satellite TAC in question.

Training Materials: Based on the Operations Manual and this ESMF, three types of training programs on

safeguards and social development will need to be developed:

1. An overall introduction to all staff at the PIU and TAC levels on the project’s approach to

management of environmental and social issues with focus on the process and criteria for

beneficiary selection (including adaptations to address conditions in the Kalinago Territory), the

grant agreement with beneficiary households, the ESMP, and the GRM.

2. A training course for the designated TAC safeguards staff, which covers the same topics as the

overall introduction, but with much more detail to make the participants fully conversant with the

approach to management of environmental and social issues, and with the MIS databases (registry

and GRM) that they will be working with.

3. An introduction to local government entities comprising the Village Councils, and the Kalinago

Council and Hamlet Development Committees in the Kalinago Territory, and other beneficiary

selection committee members identified previously on the project approach covering the process

and criteria for beneficiary selection, the grant agreement with beneficiary households, the GRM,

and the meetings at different stages between the project (the TACs/Design & Supervision Firm)

and the local government entities on verification and validation of beneficiaries, relations with

contractors, grievance redress, and overall project status and issues.

Community Level Technical Training: The TAC/Design & Supervision Firm will provide two types of

training in the selected implementation locations:

• Free technical advisory services to homeowners on demand, including technical training on the

application of resilient building practices.

• Training and awareness before start of construction activities to beneficiaries involved in house

construction, skilled laborers (e.g. masons, carpenters), and unskilled laborers on (i) the use of

construction equipment and the associated risks and safety issues, (ii) safety precautions when

working on demolition, debris removal, and housing construction activities, and (iii) other activities

required to ensure compliance with the ESMP.

SECTION 9: GRIEVANCE REDRESS MECHANISM (GRM)

9.1 GRM Scope and Summary

The project will establish a Grievance Redress Mechanism (GRM) to receive and process complaints and

grievances related to project activities, and to provide the public with an avenue to provide feedback on the

reconstruction activities supported by the project. A well-functioning GRM is central to the project’s ability

to be responsive to the population in general and the hurricane affected population in particular.

Purpose: The GRM will formalize the management of grievances of external stakeholders to minimize

the environmental, health, safety and social risks resulting from the Housing Recovery Project (HRP).

The grievance process, outlined in the document, provides an avenue for external stakeholders to voice

their concerns and gives transparency on how grievances will be managed internally, which aims to

reduce conflict and strengthen relationships between internal stakeholders and external stakeholders. T 2.

The Grievance Redress Mechanism (GRM) applies to all external and internal stakeholders of the HRP’s

operations during project implementation, including during selection of beneficiaries, reconstruction and

monitoring activities.

Process & Responsibilities: For grievances filed, there will be a normal response time of 5-10 working

days for each case starting from the date the grievance is officially received by HRP, however high-level

cases may require 10-20 working days for a response. The Project Implementation Unit (PIU) shall meet

and discuss, inter alia, grievance and resolutions to determine the level of the complaint (level 1, level 2,

level 3). This process is led by the project’s Social Safeguards Specialist with support from the relevant

team members including: Environment Specialist, Implementation Support Team (IST) Safeguards

Adviser and Project Implementation Unit (PIU) Project Manager. For grievances classified as level 2 and

3 cases, the Social Safeguards Specialist will direct the matter to the Project Manager with the support of

the IST. The internal (PIU and IST) team will meet regularly to work through the outstanding and

difficult grievances and decided jointly on the actions required and communications to the complainant.

If, this group are not able to resolve the matter they can seek guidance from the Climate Resilient

Execution Agency of Dominica (CREAD) and the Permanent Secretary, Ministry of Housing and Lands.

If the grievance continues to be unresolved, a grievance committee meeting will be initiated with the

following participants who make up the HRP Grievance Redress Committee comprising no more than

seven persons who are representatives of:

• Village Councils

• Religious Organisation

• Credit Union, Financial institution or cooperative Association

• NGO's or other civic groups in the region

• Other prominent citizens e.g. Justice of Peace, community activist

• Professionals/academia

If the grievances are extensive, the PIU will explore establishing more than one grievance committee per

region, to ensure that there are sufficient committees established to address grievances in a timely

manner. These committee members will be identified and sensitized on the GRM by the HRP PIU.

The current Grievance Mechanism (GM) is included in the PIU Operations Manual and the

Environmental and Social Management Plan (ESMP) with the objective to formalize the management of

grievances at the PIU level, to minimize the environmental, health, safety and social risks to the Project

and to avoid triggering the Bank’s corporate Grievance Redress System (GRS).

The following is a flowchart illustrating the GRM.

Categories of Complaints: The following general categories of complaints/grievances will be considered

to be within the scope of the project’s GRM:

Complaint Category Grievance Detail

Awareness Complaint On lack of information on various components of the project.

Eligibility Grievance These may require revisiting the beneficiary selection assessment for

verification of the data supporting the original decision to classify the

complainant as ineligible.

Administrative Complaint Such as missing application forms, lack of supporting documentation, etc.

Title| Permit Delay In confirmation of land title (or informal occupancy status), or issuing of

building permit.

Payment Delay Regarding the scheduled release of installments for the project’s housing

reconstruction grant.

Fiduciary Complaint Involving allegations of fraud, collusion, and corruption.

Compliance & Inspection

Complaint

Involving dissatisfaction with results of the building inspection by the

Design & Supervision Firm/TAC, complaints regarding the timing of

inspections, or their conduct (behavior, attitude, absenteeism), environmental, health and safety concerns.

Construction Complaint Regarding either the quality of work by building contractors, the quality of

materials, or their conduct (behavior, attitude, absenteeism).

Community Complaint On lack of implementation of social and environmental safeguards.

The instrument used to detail how complaints will be received, assessed and solved is the HRP Grievance

Redress Mechanism. This tool will be used by the HRP PIU and their direct players and key partners

included contracted entities in managing grievances and resolutions.

Consult the HRP Grievance Redress Mechanism for further details.

9.2 World Bank Grievance Redress System

Communities and individuals who believe that they are adversely affected by a World Bank supported

project may submit complaints to existing project-level grievance redress mechanisms or the World Bank’s

Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed in

order to address project-related concerns. Project affected communities and individuals may submit their

complaint to the World Bank’s independent Inspection Panel which determines whether harm occurred, or

could occur, as a result of World Bank non-compliance with its policies and procedures. Complaints may

be submitted at any time after concerns have been brought directly to the World Bank's attention, and Bank

management has been given an opportunity to respond. For information on how to submit complaints to

the World Bank’s corporate Grievance Redress Service (GRS), visit www.worldbank.org/grs. For

information on how to submit complaints to the World Bank Inspection Panel, please visit

www.inspectionpanel.org.

.

http://www.inspectionpanel.org/

SECTION 10: MONITORING AND REPORTING

Progress in the achievement of the Project Development Objectives (PDO) will be measured through the

following three indicators: (i) direct project beneficiaries, (ii) the number of households with resilient

housing recovered using Project subsidies (the housing grant), and (iii) the number of households that

accessed general advisory service from TACs and benefit from a streamlined permitting process. All three

indicators have been disaggregated by gender. Other secondary level intermediate results indicators also

measure achievement of social outcomes (a summary of the Results Framework is in Annex 9). The

monitoring and supervision of compliance with the World Bank applicable safeguards will be implemented

through supervision of the ESMPs during the construction of the households.

Management Information System (MIS): The overall monitoring and evaluation (M&E) for the project

will be managed by the PIU, with high level oversight by the Housing Task Force (HTF). A project

Management Information System (MIS) will house the data to be used in the generation of periodic reports

and updating of indicator results. The core of this MIS will be a registry database, which will contain the

data from the housing recovery program including the nominee and beneficiary databases (inclusive of

names and unique identifier of all project beneficiaries and contact information; copies of accompanying

documents of proof of identification and ownership / right to occupy site/property; copy of signed

acceptance letter; copy of agreement; banking details; financing details; copies of PPD applications,

inspections, responses, notices; copies of all communications (electronic communication, call logs, meeting

notes, etc.); site assessment report; design/construction documents; associated filed grievances) and the

implementation process, including designated access levels and measures to ensure confidentiality.

Data collection process: The primary data for the MIS will be collected at the level of each of the

communities (Village Councils and Hamlet Development Committees), before the data are aggregated for

the District in question by the TAC / Design & Supervision Firm, and forwarded to the PIU for generation

of consolidated reporting covering the entire project. The Project Results Framework stipulates semi-

annual reporting. However, project management by the PIU, would require more frequent reporting (e.g.

monthly) from the District level in order to assess the status of the project, and identify the bottlenecks that

need to be addressed to advance implementation progress

Registry database: For the MIS to have optimal operational usefulness, it will be important that the registry

database is set up so that it will have data on23 the suggested following modules:

(i) a module on applicant households with their associated application information (home and

demographic), documentation presented, eligibility status etc

(ii) a module for beneficiary households with info on construction type, etc, and to support

payment, compliance monitoring etc.

(iii) A grievance module to record complaints and their outcomes

Specific data entries or a specific subsidiary version of the registry database would have to be created to

accommodate the adaptations of the beneficiary selection process and confirmation of land usage (as

distinct from ownership), that will apply to the Kalinago Territory. Modifications in the registry database

23 The ToR for the consultant, that will be engaged to assist the Information and Communication Technology (ICT)

Unit and the development of the registry database, should address these data requirements.


would also need to be made to capture the particular characteristics of beneficiaries under informal

occupancy arrangements (tenants).

An MIS centered on the registry database, that would include the type of data listed above, would be able

to generate data on achievement of the PDOs and intermediate results indicators. In addition, it would

enable reporting on these and other results at different levels from that of individual villages (Village

Council areas) to the national level, including results regarding coverage of priority beneficiaries including

women headed households, households with disabled head of household, and households with elderly head

of household, as well as data on ineligible households referred to other projects and programs. The MIS

would contain the data for progress reporting by the Design & Supervision Firm on achievement of

construction targets and possible bottlenecks in reaching these. It would also allow comparisons between

results in different Districts, and between the Kalinago territory and elsewhere in Dominica.

To enable upstream data entry for each beneficiary household (as part of the registry database) regarding

(i) eligibility under the beneficiary selection criteria, (ii) Grant Agreement, (iii) disbursements for house

construction, (iv) physical implementation progress, (v) compliance with the ESMP, and (vi) completion

certification, it should be considered to develop an App that can be used by TAC / Design & Supervision

Firm field staff to record the information as soon as it is available. This would also assist the project’s

transparency goals by providing timely information for the envisioned online access to data on beneficiary

selection down to the household level.

Reporting: At critical stages throughout the project, including key milestones, reporting by each contracted

entity is required as guided by the PIU.

SECTION 11: BUDGET REQUIRMENTS FOR ESMF

IMPLEMENTATION

The budget requirements for implementation of the ESMF are covered by the funding allocated for the

project components excluding sub-component 1.3. Costs will include: (i) the planning, technical assistance,

consultation and information dissemination, capacity building, and monitoring of replacement housing -

Sub-Components 1.1, 1.2, 2.2 and Component 3; and (ii) construction of individual house undertaken in

compliance with the house-level ESMP - Sub-Component 2.1. Expenses associated with environmental and

social safeguards fall into three major categories.

• Cost of Environmental and Social Personnel: All environmental and social personnel at the PIU

under MoHL, the IST within MoF, and the Design & Supervision Firm and TAC staff will be part

of the overall human resources for the project. Hence, no separate budget allocation is needed for

the environmental and social staff. The Beneficiary Selection and Grievance Redress Review

Committees will also be facilitated to fulfil their respective duties. Personal protective equipment,

is required for staff of PIU and IST for site inspections, which may fall under the operations budget.

• Cost of Environmental and Social Monitoring. The Technical Services (architects/engineers)

consultants will conduct site visits during the beneficiary selection assessment screening process.

Monitoring by the PIU and collection of primary monitoring data by the Design & Supervision

Firm is covered under the overall program supervision and monitoring. Development of

Management Information Systems to support planning and monitoring processes in project

agencies including development of a registry database is funded under Sub-component 1.2. Some

costs involve transportation, telecommunication, meeting venues, and tablets for field work.

• Cost of Environmental and Social Capacity Building and Communication. These activities

will be combined with other trainings, awareness and information activities. Hence meetings,

handbooks, website development and maintenance, cost of implementing and facilitating

grievances are some expenses covered in respective allocations in the HRP budget. The PIU will

develop national information campaigns, and an environmental and social training for staff in the

TACs. Awareness and communication / information dissemination at the local level will be

planned and implemented by the PIU, with support by the Technical Services consultants in the

beneficiary selection process, and by the TACs/Design & Supervision Firm throughout the project

as part of their engagement with Village Councils / Hamlet Development Committees, Contractors,

and beneficiaries of housing reconstruction assistance.

Further to the cost of the HRP PIU, the household beneficiaries will need to consider in their budget the

following underlying expenses that may arise in implementing the ESMP and this should be conveyed to

them by the Design & Supervision Firm. They include but are not limited to transportation, debris

management, asbestos handling, pest control, tree felling or trimming fee, aggregate from official quarries

and initial application expenses.

ANNEXES

Annex 1: Relevant National Legislation, Policies, and Plans

Legal / Policy Document and Description Relevance to the Project Responsibility Dominica Climate Change Adaptation Policy (2002)

The Policy mandates establishment of legal and institutional

frameworks for environmental management and climate change

adaptation.

The project incorporates climate

change adaptation by:

• Only providing house

reconstruction grants for

locations not exposed to risks

from slope stability, landslides,

and flooding.

• Requiring the design of all

houses funded by

reconstruction grants to be

resilient to Category 5 storm

events.

• Providing technical assistance

and advice on demand to all

homeowners to ‘build back

better’ with hurricane resilient

building techniques.

Climate Change, Environment and Natural Resources

Management Bill (2014)

The Bill is currently being reviewed by a Parliamentary Committee

prior to presentation to the House of Assembly for adoption.

The Bill would establish a Department of Climate Change,

Environment, and Development with a mandate to implement and

coordinate government policies and programs relating to climate

change, and to integrate climate change into the Environmental

Impact Assessment and physical planning process.

Physical Planning Act (2002)

• The Act provides for the orderly and progressive development of

land in both urban and rural areas, for the grant of permissions to

develop land, and for other powers of control over the use of

land. The Act details the application and approval process which

is executed through the Physical Planning Division of the

Physical Planning and Development Authority.

• The Act states that: ‘No person shall carry out any development

of land except under and in accordance with the terms of a

development permission granted in that behalf prior to the

commencement of such development,’ and makes provision for

the Authority to consult with local authorities where such

consultation is desirable in the interests of good planning.

• ‘Every application for permission to develop land, made by the

owner of the land, shall be accompanied by a certified copy of

the applicant’s certificate of title or other relevant title document

in respect of the land to which the application relates.’

• ‘Unless the Authority otherwise determines, environmental

impact assessment shall be required in respect of any application

for development permission where the Authority finds that

‘significant environmental harm could result’.

• The Authority may impose conditions on a grant of development

permission to arrange for ‘the preservation of any buildings or

sites of importance to the cultural heritage of Dominica.’

Any housing development to be

carried out in Dominica requires (i)

an application including relevant

title documentation, and (ii) a

development permission (building

permit) granted prior to the

commencement of the development.

Construction that may cause

‘significant environmental harm’

would require an environmental

impact assessment. The housing

reconstruction under the project will

be mostly done in situ, and the

project’s ESMP identifies the likely

environmental risks to be managed.

The project’s archaeological chance

find procedure accommodates the

requirement to safeguard the

cultural heritage of Dominica.

Physical Planning

Division

Title by Registration Act (1980)

The act defines title to land as a Certificate of Title issued in two

copies by the Registrar of Titles. One copy is to be archived in the

Government’s Register of Titles, and the other kept by the land

owner.

The Act lays out the requirements for obtaining a Certificate of Title

for land not yet registered under the Act, which can be based on

different forms of documentation such as (i) a good documentary title

As described above, a condition for

the development permission

(building permit) is relevant title

documentation, and assistance from

the project to obtain this for selected

beneficiary households without a

Certificate of Title will be critical to

remove a potential bottleneck for

Registrar of Titles


Legal / Policy Document and Description Relevance to the Project Responsibility of ownership for a least thirty years, (ii) deeds or other documentation

of an undisturbed possession or ownership for twelve years, (iii)

acquisition by descent or will or deed from somebody who would

have been entitled to have the land registered, or (iv) if the land has

been in the sole and undisturbed possession of the applicant alone, or

as executor, administrator or trustee for 30 years.

physical implementation of housing

reconstruction.

Solid Waste Management Act (2002)

The core functions of the Solid Waste Management Corporation, whose

functions are inter alia:

• Provide storage facilities for solid waste.

• Procure equipment for the collection, transportation and disposal

of solid waste.

• Convert existing dumps into sanitary landfill sites.

• Develop and manage new sanitary landfill sites and other disposal

methods.

• Provide facilities for the treatment and disposal of biomedical and

hazardous wastes.

• Encourage recovery of recyclable items from solid waste.

• Prepare plans and programs to address the problems of solid waste

management in Dominica.

• Oversee the management of all solid waste collection and disposal

systems in Dominica.

The Act informs the procedures to

be followed or guide to the

management of building debris from

damaged and destroyed houses as

well as construction debris:

• Both types of debris will be

moved to and deposited at the

Fond Cole sanitary landfill (or

other approved by the GoCD

and the PIU). This requirement

will be included in contracts

with building contractors.

• Effort should be made by the

project to support DSWMC to

place recycle bins for different

types of debris in villages

where reconstruction takes

place.

Dominica Solid

Waste

Management

Corporation

(DSWMC)

Forestry and Wildlife Act

The Forestry Act provides the Forestry, Wildlife and National Parks

Division with the tools for examination and control of forest use.

National Parks and Protected Areas Act

The National Parks and Protected Areas Act gives the National Parks

Unit In the Forestry, Wildlife and National Parks Division the

authority to govern and manage the use of PAs in Dominica,

particularly the UNESCO World Heritage Site, the Morne Trois

Pitons National Parks where homes are adjacent to the park where at

times illegal activities occur that relate to local livelihood.

Any forest or river resources used

must be approved, and restricted use

in protected areas (PA) as well as

near the borders of PAs must follow

the management arrangements of

the Forestry, Wildlife and National

Parks Division

Forestry, Wildlife

and National

Parks Division

Pesticides Control Act

Dominica has signed the UN Convention on Persistent Organic

Pollutants. At the local level, the Pesticides Control Act governs the

types, use and management of pesticides to control pests on island.

Any use of pesticides must be in

line with approved pesticides to

control pest as governed by the

Pesticide Control Board.

Pesticide Control

Board

Approved pest

control companies

Dominica Building Code (1996)

The Building Code provides the physical planning authorities with the

tools for examination of development proposals to ensure that all

developments are in concert with the physical, social and economic

requirements of the Organization of East Caribbean States.


carried out in the country must

comply with the Building Code.

Physical Planning

Division

Guide to Dominica’s Housing Standards (2018)

The Guide is a derivative from the Dominica Building Code and the

Dominica Building Guidelines, and is intended to serve as an easy

reference tool for all stakeholders involved in roofing

repairs/reconstruction, and partial or complete reconstruction of

residential buildings post Hurricane Maria. The guidelines aim to

meet the minimum standards in accordance with ‘Build Back Better’

principles catering to housing structures which are resilient to weather

and seismic events.


carried out in the country must be

done in accordance with the

Building Code and meet the

Housing Standards. This is the

basis for informing the housing

reconstruction activities under the

project.

Ministry of

Housing and

Lands


Legal / Policy Document and Description Relevance to the Project Responsibility Dominica National Land Use Policy (2014)

Dominica has a strong tradition of protecting its natural resources

including through a system of National Parks and protected areas

which cover a significant portion of the island. The long-term vitality

of these systems contributes to resilience against natural hazards and

the impacts of climate change, and contributes to high quality soil for

agricultural production.

The project’s criteria for eligibility

for the housing reconstruction grant

excludes any house in a National

Park or Forest Reserve.

Hurricane Maria caused extensive

destruction of forest trees, and

salvage and use of fallen trees as

lumber for house reconstruction

could be considered.

Division of

Forestry

National Policy and Action Plan for Gender Equity and Equality

(2006)

The policy is guided by Government’s recognition that the

development of Dominica hinges on the creation of an environment

free from institutional and ideological barriers of gender which

impinge on human development, and by extension national

development. The national gender policy of Dominica seeks to apply

a gender perspective to the key sectors of health, education, training,

housing, and the provision of basic amenities, poverty reduction and

the generation of sustainable ESMPloyment opportunities toward the

creation of an equitable and just society to assist all Dominicans, of

both sexes, in reaching their full potential.

The project’s prioritization criteria

for eligibility for the housing

reconstruction grant includes

female-headed households with

children below 15 years of age, and

the target is that 35 percent of the

1,700 households with totally

destroyed homes, who receive the

housing grant, should be female

headed.

Bureau of Gender

Affairs in the

Ministry of Social

Services, Family,

and Gender

Affairs

Kalinago Territory Act (2015)

The Carib Reserve Act was enacted in 1978, the year of Dominican

independence. It reaffirmed the territorial boundaries first established

by colonial authorities in 1903, legally established common

ownership of land within the reserve, and the office and powers of an

elected chief and council. A department of Carib affairs was

established in 2000 and upgraded to a Ministry of Kalinago Affairs in

2014. In March 2015, an amendment was made that changed the

name of the Carib Reserve Act to the Kalinago Territory Act, and

replaced the word ‘Carib” with ‘Kalinago’, and ‘Reserve’ with

‘Territory’. Other than that, the content of the 1978 Act remains

unchanged.

The Act provides the institutional

framework to ensure free, prior, and

informed consultation resulting in

broad community support to the

project by the Kalinago people as

required by OP 4.10 on Indigenous

Peoples, and such support has been

expressed during the initial

consultations held in the area. The

project’s overall approach to

community engagement would also,

with a few adaptations, suit

conditions in the Kalinago

Territory.

Kalinago Council

and Ministry of

Kalinago Affairs

Dominica Land Acquisition Act (1946, amended in 1986) The Land Acquisition Act, Chapter 53:02 deals with the acquisition

of land by the state, and outlines procedures in acquiring private land

for a public purpose.

The Land Acquisition Act is largely consistent with the requirements

of OP 4.12 on Involuntary resettlement, except with regard to the

timing of compensation payments. OP 4.12 requires that

compensation must be made prior to use of acquired land, whereas the

Land Acquisition Act allows for compensation after land has been

acquired.

OP 4.12 and the Land Acquisition

Act will not be triggered by the civil

works under the Housing Recovery

Project.

The Lands and

Survey Division

in MoHL and the

Property

Valuation Unit

within the

Ministry of

Environment,

Natural

Resources,

Physical Planning

and Fisheries.

Dominica Resettlement Strategy (no date)

A comprehensive approach to the resettlement process undertaken by

the Government of Dominica after Tropical Storm Erika in 2015. The

strategy intends to guide the process to resettle communities and

families that cannot continue living where they used to live –

Guided by the Dominica

Resettlement Strategy, the

Government aspires to carry out

major housing reconstruction

projects, including the construction

Responsibility for

planning and

implementation is

not described, but

would likely


Legal / Policy Document and Description Relevance to the Project Responsibility regardless of whether or not their houses were destroyed or damaged

by Tropical Storm Erika - because the land on which they were settled

is highly vulnerable to natural hazards. It establishes the principles

and main guidelines for the resettlement process, assesses the main

issues to be addressed, and drafts a broad timeline for its

implementation.

of 1,000 housing units in new sites

for households living in areas highly

vulnerable to natural hazards. This

is one of the programs that

households found ineligible under

the Housing Recovery Project may

be referred to.

include the

entities involved

in implementation

of the Land

Acquisition Act.

Annex 2: Map of Dominica’s Health Districts

Annex 3: Map of Dominica’s Village Districts

Annex 4: Guidelines for World Bank Code of Conduct for Contracted Entities

The objective of the Worker’s Code of Conduct is to avoid or minimize as much as possible, any negative

impact that could be produced as a consequence of interrelations between the workers inside the local areas

of influence and the outskirts of the Project Area. The Contractor shall implement a Code of Conduct

consistent with the guidelines included herein to assist all employees to:

o Understand expected standards of conduct and behavior;

o Comply with relevant laws and policies;

o Demonstrate and promote good ethical work practice;

o Respect colleagues, supervisors and community members.

Contractors shall ensure that each worker receives a written copy of this Code as part of the induction

process and as part of the Contract. As a requirement to be hired, all workers must sign a copy of this Code,

where they acknowledge it and certify they have read it and accepted its terms, promising to comply with

its terms thoroughly and at all times. Additionally, copies of this Code shall be made available at a visible

location at the project site.

Under the Code of Conduct all workers shall:

o Consider people equally without prejudice or favor;

o Act professionally with honesty, consistency and impartiality;

o Take responsibility for situations, showing leadership and courage; and

o Place the public interest over personal interest.

o Observe standards for safety.

o Be fiscally responsible and focus on efficient, effective and prudent use of resources.

The workers are obliged to comply with the rules and procedures indicated in the Code, so as to maintain

good relations with the local community in the direct area of influence of the Project. Any worker may be

subject to disciplinary actions and/or may be fired if their behavior while he/she is employed on the project

goes against the rules stated in the Code. However, workers shall have access to the Grievance Mechanism

for the Project (see section 19).

Under the Code of Conduct, as a minimum, workers shall comply with the following rules:

Rules Regarding the Local Population

The local population is defined as all people that live within the direct area of influence of the Project,

or in the areas used for the transportation of equipment and materials required for the activities of the

Project.

All workers are expected to behave adequately at all times and must avoid improper relations with the

local population. The Contractor will not tolerate any form of harassment or discrimination, including

behavior, comment, jokes, slurs, email messages or any other social media, pictures, photographs, or other

conduct that contributes to an intimidating, disrespectful or offensive environment.

All workers shall avoid any discriminatory conduct based on gender, age, disability, race, language,

culture, political affiliations, philosophy, religion, or any other basis.

All workers must comply, at all times, with all applicable environmental and health and safety rules

and regulations.


Should the worker fail to comply with the Code or behave in such a way that he/she creates a problem

with the local population, the corresponding action must be communicated to the Contractor, detailing what

happened, so that the Company can carry out an investigation.

Rules regarding the Construction

All Workers are required to show at all times a transparent and honest behavior, and a high level of

personal responsibility and professionalism, either in or out of the Project Area.

All Workers shall comply with all applicable laws, rules and regulations.

Workers shall immediately inform management about any kind of sickness or symptom that may affect

their ability to carry out their work-related obligations properly.

Workers shall use adequate personal protection equipment during their activities within the Project Area,

including Project Vehicles.

Workers are not allowed to smoke or make an open fire within or in the surroundings of the Project Area

or near any Project Property, including Project Vehicles.

Workers are not allowed to engage in gambling while at work and using company assets for gambling

are prohibited, including during breaks. For purposes of this standard, “gambling” is defined as playing a

game for money or property or betting on an uncertain outcome. Prohibited gambling activities include, but

are not limited to: Games (e.g., cards, dice, and dominoes) played for money or property, including

electronic games (online poker, roullete, etc,); betting on sporting events, bingo, etc.

Workers are forbidden to possess, use or carry any kind or illegal drugs, medical paraphernalia,

narcotics or alcoholic beverages within the Project Area or any Project property, including Project

Vehicles.

Workers are not allowed to possess or carry weapons, such as firearms, explosives, ammunitions, knives,

clubs, etc., within the Project Area or any Project Property, including Project Vehicles.

All Workers shall not receive or hand over money, goods or other objects of value in order to obtain

benefits, receive favors or influence decisions, third parties, or themselves.

Workers shall not use Project funds or equipment, or other articles provided for the Project for their

personal benefit or any other unauthorized use.

Pets are not allowed in the Project Area.

Fishing, hunting and deforestation is also forbidden within the Project Area and its immediate

surroundings.

For security reasons, Workers may not abandon the Project Area without permission.

Annex 5: Role of Direct Players and Key Partners in the Implementation of Safeguards

Operating arrangements throughout the safeguards management journey requires transparent processes and

roles among the players and partners at various stages in the implementation of the HRP. Direct players

under the project focused on supporting the three construction stages lie within the management of the PIU.

Table 1 lists the direct players and their work focus that supports the safeguards. Table 2 lists the key

partners, areas of cooperation and supporting procedures to follow aligned with WB operational polices.

Table 1. Direct Players and Work Focus to Support Environmental & Social Safeguards

Direct Player Work Focus

World Bank (WB) Team For no objection of the ESMF, EA-ESMP and other actions, where

required.

WB & IST Environmental

& Social Counterparts

To support work development processes and implementation, where

appropriate.

WB Consultants/Firms To make recommendations, to provide technical support and to implement

consultancy work that adheres to environmental and social safeguards

processes in alignment with PIU overarching management processes.

Technical Assistance

Center (TAC) Consultants

/ Team

To provide technical support that adheres to environmental and social

safeguards processes in alignment with PIU management processes.

HRP PIU To integrate cross border implementation and management of work plans

aligned with grant disbursements.

Ministry of Housing To support the PIU processes as the Focal point of the HRP.

Physical Planning

Division

To approve the housing site based on national legislation including

environmental law and WB safeguards triggered under the HRP.

Homeowners To champion adherence to the work required under environmental and

social safeguards.

Added to the direct players are the key partners for specific areas of cooperation and support processes to

support environmental and social safeguards predominantly throughout the project noted in Table 2.

Table 2. Key Partners & Procedures to Support Environmental & Social Safeguards

Partners Area of Cooperation Support Process WB-OP

Roseau Market Trust Chance Find – archeological ‘Chance Find’

Procedure

OP4.11

Dominica Police Force – Central

Intelligence Department (CID)

Chance Find – skeletal remain N/A

Environmental Health

Department (EHD);

Pesticide Control Board;

Official pest control companies

Pest management Pest Management

Procedure

OP4.09

Dominica Solid Waste

Management Corporation

(DSWMC);

Other support identified by

DSWMC

Waste management Waste Management

Procedure

OP4.01

Forestry, Wildlife & National

Parks Division – Timber

Utilization Unit

Downed trees management

(promoted) / last resort -

Lumber Salvaging

Activity (use of

OP4.01


private land felling of trees

management

Alaskan saw mill at

site)

Environmental Health

Department

Environment, Health & Safety Health & Safety

Plan

OP4.01

Contractor;

Design & Supervision Firm

TAC support (if required)

Labour & working conditions Code of Conduct

OP4.01

Contractor;



Environment, Health & Safety Personnel Protective

Equipment

OP4.01

Contractor;

Design & Supervision Firm;


Job hazard management Job Hazard Analysis

& Procedures to

Follow

OP4.01

Contractor;

Design & Supervision Firm;


Emergency management Contingency &

Emergency

Management Plan

OP4.01

Dominica Police Force Traffic

Department

Traffic management Traffic Management

Procedure

OP4.01

Ministry of Kalinago Affairs;

Kalinago Council

Indigenous management Indigenous Peoples

Plan (IPP)

OP4.10

Beneficiary Selection

Committee

Beneficiary selection Beneficiary

verification &

prioritization

OP4.01

Grievance Redress Committee;

HRP PIU

Grievance Redress

Mechanism

Grievance Logging

& Complaints

System

Cross

border

The safeguards implementation journey and work plan outline the steps per work area with respective

procedures, human resources and schedule for implementation of the environmental and social safeguards.

Annex 7: HRP Application Form

GOVERNMENT OF THE COMMONWEALTH OF DOMINICA

“AIDE WAGER KAI”

APPLICATION

This section is for official use only

Individual Application No.

HRP Application Approval No.

Date of Approval

Beneficiary Score

Beneficiary Application (Please mark X where applicable and N/A where not applicable)

Section A. Personal Details

First Name:

Middle Name(s):

Surname:

Maiden or Former Name:

Identification Type: Identification Number:

Address at the time of the Hurricane:

Current Address:

If your current address is different than that of the damaged home please indicate whether you are

living:

In a shelter

With relatives or friends

Renting

Marital Status:

Single: Married:


Widow/Widower: Divorced:

Age:

Sex: Male: Female:

Do you have any form of disability? Yes: No:

Please state the form of disability:

Do you have any dependents? (Include details in Section B Yes: No:

Number of dependents:

How many of them are elderly?

How many of them are disabled?

This section to be completed by residents of Kalinago Ethnicity ONLY

Are all of your dependents Kalinago? Yes: No:

If no, state the number of dependents who are Kalinago: Non-Kalinago:

If married, is your spouse Kalinago? Yes: No:

Section B: Household Members (Please list all who live with applicant)

Full Name Relationship

to Applicant

Ag

e

Form of

disability (if

applicable)

Total Number:

Section C: Employment Status (Please mark X where applicable)

Unemployed

Self-employed

Employed

Retired


Basic Monthly Income:

<$500

$501 to $1000

>$1000

If above EC$1000 state amount

Section D: Receipt of Assistance (Government/Donor Agency)

(Please mark X where applicable)

Has your household received any

direct reconstruction/structural restoration of your home

through Government or Donor Housing Program?

Yes: No:

If yes, please select the appropriate option:

Provided a new home in a different location

Rebuilding home in the same location

Construction of a temporary structure

Partial repairs to existing structure

Grant for rebuilding and/or repair

State grant amount:

Who provided the support?

Social Safety Net Support:

Are you or any household member the recipient of any of the following programs?

Public Assistance

Over 70 Allowance

Education Trust Fund

Section E: Details of Citizenship

Are you a Dominican Citizen? Yes: No:

If not, have you obtained permanent residency? Yes: No:

Date Permanent Resident Certificate was issued:

Section E: Details of Property

Name of Home-owner

Applicant Relationship to Owner of the Home

District/Parish

Address of Property

Registered/Permission to Occupy


Damage to Home (Please mark X where applicable)

Minor damage

Partially destroyed

Completely destroyed (entire structure uninhabitable)

Was the home insured? Yes: No:

Was part of your house being used for your livelihood? Yes: No:

Size of House in square feet (sq. ft.)

The application form must be submitted with the following documents:

1. One official picture ID (passport, driver's license)

2. Permanent Resident Certificate (if applicable)

3. Property Deed

4. Certificate of disability from a medical professional (if applicable)

5. Certificate/proof confirming the right to occupy land

6. Birth certificate(s) of applicant’s dependent(s)

7. Proof of Address (eg. Copy of Utility Bill prior to September 2017)

Kindly submit the application form with the required documents listed above to the following

address:

Project Manager

Housing Recovery Project - Project Implementing Unit

Old Street, Roseau

Commonwealth of Dominica

Signature: Date:

For Official Use Only

The following Documents were received and attached


Received in

good

condition

If any of the

documents listed

above has been

lost or damaged

(Please indicate)

1. Certified copy of birth certificate of applicant

2. One official picture ID (passport, driver's license)

3. Permanent Resident Certificate (if applicable)

4. Property Deed

5. Certificate of disability from a medical professional

(if applicable)

6. Certificate/proof confirming the right to occupy land

7. Certified copy of birth certificate(s) of applicant’s

dependent(s)

8. Proof of Address (eg. Copy of Utility Bill prior to September

2017)

Process Record

Name Signature Date

Application received

Procedural Check

Application returned for correction

MIS captured data

Data verified

Review completed/Data validated

Filed

72


Annex 8: HRP Environmental and Social Management Plan (ESMP) for Small

Construction and Rehabilitation Activities

General Guidelines for Use of ESMP

For low-risk topologies, such as a small house rehabilitation activity or small-scale works in building construction

(around 500 sq. ft.), the HRP safeguards team developed a brief Environmental and Social Management Plan (ESMP)

checklist-for a more streamlined approach to prepare ESMPs. The checklist has been developed to be user friendly

and compatible with World Bank’s safeguard requirements.

The ESMP covers typical core mitigation approaches to civil works contracts with small, localized impacts. It may

not contain socio-economic parameters regarding vulnerability identified in ESMF and Mitigation Table such as single

or disabled head of households. This checklist provides the key elements of an ESMP to meet World Bank’s

Operational Policies:

OP 4.01 Environmental Assessment

OP 4.09 Pest Management

OP 4.10 Indigenous Peoples Plan

OP 4.11 Physical Cultural Resources

The intention of this checklist is that it would be applicable as guidelines for the small works contractors, the

TAC/Technical Services (architects, engineers) consultants and the Design and Supervision Firm carrying out small

civil works under Bank-financed projects. Monitoring on same would be stored and managed in the management

information system (MIS).

The ESMP checklist has four sections:

Part 1: Includes a descriptive part that characterizes the project, specifies institutional and regulatory aspects,

describes technical project content, and outlines any potential need for capacity building. This section should

indicatively be up to two pages long. Attachments for additional information may be supplemented as needed.

Part 2: Includes a screening checklist of potential environmental and social impacts, where activities and potential

environmental issues can be checked in a simple Yes/No format. If any given activity/issue is triggered by

checking “yes”, a reference to the appropriate section in the table in the subsequent Part 3 can be followed,

which contains clearly formulated environmental and social management and mitigation measures.

Part 3: Represents the environmental and social mitigation plan to follow up proper implementation of the measures

triggered under Part 2. It has the same format as required for management plans produced under standard

safeguards requirements for Category B projects.

Part 4: Contains a simple monitoring plan to enable both the Contractor as well as authorities and the World Bank

specialists to monitor implementation of environmental management and protection measures and detect

deviations and shortcomings in a timely manner.

Parts 2 and 3 have been structured in a way to provide prescriptive and enforceable environmental and social measures,

which are understandable to non-specialists (such as Contractor’s site managers) and are easy to check and enforce.

Part 4 has also been designed intentionally simple to enable monitoring and reporting protocol of key parameters with

simple means and non-specialist staff.

73


ESMP Implementation Timeline

ESMP

Activities

Responsibilities Time Periods

Part 1 ▪ Content reviewed by the MIS firm to incorporate the ESMP in the Management Information System

(MIS) where appropriate

▪ Executed by the Technical Services (architects, engineers) Consultants | TAC

▪ Reviewed by the Design & Supervision Firm and reported to the PIU

▪ Approved by the PIU

▪ After beneficiary

selection

Part 2 ▪ Content reviewed by the MIS firm to incorporate the ESMP in the MIS where appropriate

▪ Executed by the Technical Services (architects, engineers) Consultants | TAC

▪ Monitored by the Design & Supervision Firm and reported to the PIU

▪ Monitored and approved by the PIU with support from the IST Safeguards Specialists

▪ Screening stage of

beneficiary selection

▪ Design & site preparation

stage


▪ Executed by the Contractor

▪ Supervised by the Design & Supervision Firm and reported to the PIU

▪ Supported by the Technical Services (architects, engineers) Consultants | TAC

▪ Monitored and approved by PIU with support from the IST Safeguards Specialists

▪ Design and site

preparation stage

▪ Construction stage


▪ Executed by the Contractor

▪ Supervised by the Design & Supervision Firm and reported to the PIU

▪ Supported by the Technical Services (architects, engineers) Consultants

▪ Monitored and approved by PIU with support from the IST Safeguards Specialists

▪ Construction stage

▪ Completion of

construction &

demobilization stage

74


ESMP for Small Construction and Rehabilitation Activities

PART 1: General Project and Site Information

INSTITUTIONAL & ADMINISTRATIVE

Country Commonwealth of Dominica

Project Title Housing Recovery Project (P166537)

SITE DESCRIPTION FOR EACH BENEFICIARY

Name of the Beneficiary

Address of Beneficiary Location (Street

Name and Number of lot/houses,

settlement name/ neighborhood name,

and other details as applicable

Site Map Yes No

Who owns the land?

Description of geographic, physical,

biological, geological, hydrographic,

nearby protected area or indigenous

peoples (if applicable), and socio-

economic context, including:

Altitude (in meters)

Nearest access road /highway/

Proposed Date of Commencement of

works:

Other information, as applicable

75


Locations and distance for potential

material sourcing

Sand

Stone

Gravel

Distance to Fond Cole or other waste

and debris authorized disposal site

LEGISLATION

Identify national & local legislation &

permits that apply to project activity

[see Annex 1 in ESMF for guide listing relevant legislation and include the permits that apply]

Have all legally required permits been

acquired for the works?

Yes No

If No, works should not proceed

ENVIRONMENTAL & SOCIAL AWARENESS

Will there be any awareness? Yes No

If Yes, Attachment 1 includes the capacity building program

COMMUNICATION AND DISCLOSURE

76


Have the local construction and

environment inspectorates and

communities been notified of upcoming

activities?

Yes No

If No, works should not proceed until notification is done.

Has the public/neighbor communities

been appropriately notified of the

works?

Yes No

If No, works should not proceed until notification is done.

Part 2: Environmental, Social, Health & Safety Safeguards Screening

Will the site activity

include/involve any

of the following?

1. Risks related to property rights including in the

Kalinago Territory.

[ ] Yes [ ] No See Part 3/ Section A below

2. Potential for conflict with neighbors [ ] Yes [ ] No See Part 3/ Section B below

3. Removal of existing debris, trees and vegetation,

earth works [ ] Yes [ ] No See Part 3/ Section C below

4. Traffic and pedestrian safety [ ] Yes [ ] No See Part 3/ Section D below

5. Chance Finds (PCR, skeletal remains) [ ] Yes [ ] No See Part 3/ Section E below

6. Typical impacts from

construction/reconstruction

of small houses (dust, noise, erosion, sedimentation,

etc.)

[ ] Yes [ ] No See Part 3/ Section F below

7. Impacts on forests and/or protected areas [ ] Yes [ ] No See Part 3/ Section F below

8. Re-location in situ [ ] Yes [ ] No See Part 3/ Section F below

9. Re-location ex-situ within the Kalinago Territory [ ] Yes [ ] No See Part 3/ Section F below

77


10. Individual wastewater treatment system [ ] Yes [ ] No See Part 3/ Section F below

11. Pest control [ ] Yes [ ] No See Part 3/ Section G below

12. Hazardous or toxic materials [ ] Yes [ ] No See Part 3/ Section H below

13. Demobilization of work site [ ] Yes [ ] No See Part 3/ Section I below

OP. 4.01 – Environmental Assessment (EA)

A. Is the proposed construction/reconstruction project

likely to have only small scale adverse environmental

impacts that would be classified as Category B under

WB OP 4.01 Policy?

[ ] Yes [ ] No

If Yes, check Mitigation Measures on Part 3.

B. Are the above-mentioned adverse environmental

impacts only small-scale, site-specific, temporary,

reversible, and limited to the

construction/reconstruction or replacement time

frame and for which mitigation measures are readily

known and easily implemented (as Category B under

WB OP 4.01 Policy)?

[ ] Yes [ ] No


C. Will an Environmental and Social Management Plan

(ESMP) be available for the nature and scale of the

proposed works, including all measures needed to

prevent, minimize, mitigate, or compensate for

adverse impacts and improve environmental and

social performance?

[ ] Yes [ ] No


OP. 4.11 – Physical Cultural Resources

D. Is the proposed activity located in, or in the vicinity

of, cultural sites?

[ ] Yes [ ] No

If Yes, check Part 3/ Section E.

E. Is the proposed activity located in an area where

known Physical Cultural Resource (PCR) or burial

site exist?

[ ] Yes [ ] No

78



F. Will the proposed activity use any public PCR? [ ] Yes [ ] No


G. Will the proposed activity apply and develop a

Chance Finds Procedure for the construction phase?

[ ] Yes [ ] No


OP 4.09 – Pest Management

H. Will there be a need to control existing pests in the

site proposed for the construction/reconstruction of

the new house?

[ ] Yes [ ] No

If Yes, check Part 3/ Section G.

I. Will the use of pesticides be used only in small

limited quantities within one single housing unit to

control mainly rodents and termites?

[ ] Yes [ ] No


J. Will the pesticides be purchased from authorized

dealers and be approved by the Dominica Pesticides

Control Board, within the Ministry of Agriculture

and Fisheries?

[ ] Yes [ ] No


OP 4.10 – Indigenous Peoples

K. Will the activity (house construction/reconstruction)

take place within the Kalinago Indigenous People

Territory?

[ ] Yes [ ] No

If yes, check Mitigation Measures on Part 3

L. Will the design and planning be conducted in

consultation with and consented by the elected

Kalinago Council and Kaliago beneficiary?

[ ] Yes [ ] No


M. Will an Indigenous Peoples Plan (IPP) to support the

unique needs of the Kalinago be implemented in the

HRP?

[ ] Yes [ ] No


79


PART 3: Mitigation Measures

ACTIVITY POTENTIAL

IMPACTS

PARAMETER MITIGATION MEASURES CHECKLIST24

DESIGN STAGE AND SITE PREPARATION

A. Site

Investigation

Potential risks related

to property rights

Property rights (a) Researching and clarifying site ownership

(b) Ensuring owner’s written consent before accessing site

(c) Ensuring Kalinago Council’s written consent of owner’s right to

land in the Kalinago Territory inclusive of relocation ex-situ within

the Kalinago Territory, noted in the HRP Indigenous People’s Plan

(IPP).

(d) Notification of owners and in the Kalinago Territory, the head of

household and the Kalinago Council of commencement of works, if

required, prepare and sign a works completion handover protocol

(e) Notification of owners and in the Kalinago Territory, the head of

household and the Kalinago Council of all activities and any site

damages

Potential risks related

to natural hazards

Location and risk (f) All legally required permits for relocation in-situ have been acquired

for reconstruction at the new site approved by the owner, and in the

Kalinago Territory, by the head of household and the Kalinago

Council

B. General

Works

Preparation

Conflicts with

communities due to

upcoming expected

nuisances

Formal community relations,

including the Kalinago

Council and the Hamlet

Development Committees

stipulated in the IPP:

notifications/communications;

workers’ Code of Conduct

(a) The local construction and environment inspectorates and

communities have been notified of upcoming activities

(b) The public has been notified of the works through appropriate

notification in the media and/or at publicly accessible sites

(including the site of the works)

(c) All local stakeholders shall be informed of the works to be executed,

inclusive of its description, the accurate commencement time,

estimated completion time and any potential impact that may occur

(updates shall be given as work progresses).

(d) Local stakeholders will be informed of the Code of Conduct that

shall be applied to the workers.

2424 These are Best Management Practices (BMPs) that should be applied at all sites, as possible.

80


(e) All workers will be oriented on the workers’ Code of Conduct by the

Design & Supervision Firm and the Contractor.

(f) All legally required permits have been acquired for construction

and/or rehabilitation

(g) The Contractor formally agrees that all work will be carried out in a

safe and disciplined manner designed to minimize impacts on

neighboring residents and environment.

Unlawful

construction/penalties

Permits and authorizations

(e) The contractor/beneficiary shall be responsible for ensuring that he or

she has all relevant legal approvals and permits required to commence

works, including those specific to the Kalinago Territory.

SITE CLEARING/CLEANING AND EARTH WORKS

C. Removal of

debris, trees

and vegetation,

earth works

Increased dust

Air quality (a) During dry periods when dust is a nuisance it shall be mitigated by

spraying of water onto work surfaces along the work area.

(b) At all sites, the surrounding environment (including sidewalks,

roads if located adjacent) shall be kept free of debris to minimize

dust.

Risk of accidents

with community

members or other

unauthorized persons

Site Security (c) The Contractor/Beneficiary shall be responsible for maintaining

security over the construction site including the protection of stored

materials and equipment and maintain access control to avoid

liabilities associated with accidents involving unauthorized people

in the site.

(d) Access to the construction/works site by unauthorized persons shall

be restricted. Persons wishing to enter the construction site must first

report to the Design & Supervision firm/person in charge at the

entrance of the site.

(e) If trees are to be removed, Contractor shall specify how many and

the detailed mitigation measures to be adopted

(f) The necessary permits must be secured prior to starting to clear the

site.

(g) The removal of vegetation in sensitive areas will be discouraged and

when absolutely required must be limited to the authorization issued

by applicable authorities in Dominica (Physical Planning

Division/Forestry, Wildlife and National Parks Division, DOMLEC,

81


DOWASCO) and according to a suppression plan where all

elements will be identified and cataloged (specie, girth and DBH25);

(h) The areas or the elements to be suppressed shall be previously

identified and marked with colored tape in order to allow quick

visualization and avoid cutting unauthorized trees.

(i) Tree cutting shall be performed by specially trained staff. The team

shall count with the PPEs and the appropriate equipment and tools.

(j) The use of fire or hazardous material is strictly prohibited.

(k) If required, a certified copy of the authorization to suppress

vegetation, including, when applicable, the map of the boundaries of

the area of intervention must be maintained onsite.

Risk of health hazard

from debris/waste

accumulation

Debris/waste management (l) Debris at the site should be separated such as white goods (washing

machines and refrigerators), metal, general trash and disposed at the

official locations based on the waste management plan.

(m) There will be no burning of debris/waste.

CONSTRUCTION PHASE

D. Transportation

and storage of

construction

materials

Increased dust Air quality (a) Unpaved, dusty access roads should be compacted and/or wet

periodically.

(b) There will be no excessive idling of construction vehicles at sites;

(c) The bins of all haulage vehicles transporting aggregate or building

materials must be covered on all public roads.

(d) Materials such as sand, cement, or other fines should be kept

properly covered and bunded and be moistened with sprays of

water.

(e) Cement should be kept stored within a shed or container.

(f) There will be no open burning of debris / waste material at the site.

Direct or indirect

hazards to public

traffic and

pedestrians by

construction

activities

Traffic and Community

Safety

(a) The Contractor or Design & Supervision Firm will enforce a generic

Traffic Management Plan approved by the Dominica Police Force

Traffic Department for activity on public road.

(b) The Contractor or the Design & Supervision Firm will timely disclose

service disruptions to community where applicable;

(c) Traffic control strategy will be implemented as to minimize the

impact to the surrounding community.

25 Diameter at Breast Height (DBH)

82


(d) The traffic management plan to be developed by the Design &

Supervision Firm and implemented by the contractor shall include:

alternative routes to be identified in the instance of extended road

blockages; the public to be notified of all disturbance to their normal

routes; signposting, warning signs, barriers and traffic diversions

must be clearly visible and the public warned of all potential hazards;

provision must be made for the safe passages and crossings for all

pedestrians where construction traffic interferes with their normal

route; there must be active traffic management by trained and visible

staff at the site or along roadways as required to ensure safe and

convenient passage for the vehicular and pedestrian public;

(e) Adjustment of working hours to local traffic patterns, e.g. avoiding

major transport activities during rush hours.

(g) Contractor/Beneficiary will ensure that the construction site is

properly secured, and construction related traffic regulated as per

Traffic Management Plan.

E. Small-scale

excavations of

foundations

and other

earth

movements

Potential Chance

Finds of Skeletal

remains

Chance Finds (a) It shall be ensured that provisions are put in place so that skeletal

“chance finds” encountered in excavation or construction are noted

and registered, responsible officials contacted notably the Dominica

Police Force Central Investigation Department, and works activities

delayed or modified to account for such finds.

Potential Chance

Finds of PCR

(Physical Cultural

Resources)

Chance Finds (a) Contractor/Beneficiary will be required to follow a Chance Finds

Procedure, communicating any cultural archaeological findings to

the Roseau Market Trust for the National Museum in Roseau or any

natural cultural findings to the Forestry, Wildlife and National Parks

Division (FWNPD). Similar in the Kalinago Territory,

communicating Chance Finds to the Kalinago Council and the

Ministry of Kalinago Affairs.

(b) Ensure that any cultural artifacts or other possible “chance finds”

encountered during field works are noted and registered, and

secured, and the Roseau Market Trust and the FWNPD, and in the

Kalinago Territory, the Kalinago Council are contacted.

(c) Ensure that activities are stopped or modified until proper guidance

from the relevant authorities.

F. General small-

scale

construction

activities

Risk of health and

safety accidents with

workers

Workers Health and Safety (a) Contractors and workers will be trained on basic standard operating

procedures for small civil works.

(b) Measures to control dengue and other water-borne diseases by

eliminating the breeding grounds of Aedes aegypti will include the

following: covering or boring tires; using coarse sand in dishes of

flower pots; bagging and throwing in the trash cans that can

83


accumulate water; emptying bottles and turning upside down before

discarding; covering the water tanks, etc.

(c) The Contractor/Beneficiary must designate a person responsible for

Occupational Health and Safety (OHS) who will ensure that the

requirements and procedures are followed by all and at all levels of

execution.

(d) All working sites must be equipped with First Aid kits and a

responsible person trained in administering first aid measures.

(e) The Contractor/Beneficiary shall ensure that all workers operate

within a safe environment. Sanitation facilities shall be provided for

all site workers.

(f) The Contractor/Beneficiary must provide all workers with the

necessary protective gear as per their specific tasks such as hard hats,

overalls, gloves, goggles, boots, etc.

(g) The Design & Supervision firm shall develop and implement a basic

Occupational Health and Safety plan that must be approved by the

PIU.

(h) The Occupational Health and Safety Plan will include the following

minimum content:

• Job Hazard Analysis

• Manual of safe work procedure26 (SWP) for key activities (site

clearing, tree removal, trench and excavation, access /egress,

installing scaffolds, working on ladder, working on heights,

lockout-tagout (LOTO), housekeeping and materials storage,

manual and mechanical lifting, lifting and hoisting, confined

space entry, fall-arrest rescue, and others, as applicable)

• Training

• Reporting and investigating Accidents, identifying Root Cause,

and acting upon prevention and corrective measures.

• Emergency Preparedness and Response Plan addressing as a

minimum, fire, medical emergencies and natural hazards

emergencies such as floods and landslides

(a) The appropriate posting of information within the site must be done

to inform workers of key rules and regulations to follow.

Risk of

contamination when

working (sawing,

Workers’ Health and Safety (a) Care must be taken when working (sawing, sanding, machining,

etc.) with CCA-treated timber in a way that produces saw-dust.

Appropriate personal protective equipment should be worn, and

these activities should take place outdoors.

26 Also known as Standard Operating Procedures.

84


sanding, machining)

timber treated with

Copper Chrome

Arsenate (CCA)

(b) Disposal of CCA-treated timber debris from destroyed houses and

from construction should be done under the arrangements described

above in the section on ‘debris/waste management’ involving

disposal at the DSWMC operated sanitary landfill at Fond Cole (or

other approved by the GoCD and the PIU).

Increased level of

noise

Noise (c) Construction schedule will be limited to the restricted times

established in legislation and in the permit.

(d) When neither exist, and where noise management is a concern, the

contractor(s) shall schedule activities during normal working hours

(between 8am and 5pm).

(e) During the operation of engines, covers of generators, air

compressors and other powered mechanical equipment shall be

closed, and equipment placed as far away from residential areas as

possible

(f) Where noise is likely to pose a risk to the surrounding community,

the contractor(s) shall inform the Design & Supervision firm and shall

develop a public notification and noise management plan for approval

by the Dominica Police Force and PIU

(g) No night works or delivery of materials at night shall be permitted.

(h) Excessive noise level posed by workers on site such as loud music

will be managed.

Potential pollution of

surface or

underground water

bodies, water

courses, etc.

Water Quality (a) Protect surface waters, groundwater resources, springs and

watercourses from siltation and pollution with temporary devices.

(b) Wastewater systems will be designed and installed according with

technical requirements by the Design & Supervision Firm

(c) Liquid wastes will not be allowed to accumulate on or off the site,

or to flow over or from the site in an uncontrolled manner or to

cause a nuisance or health risk due to its content.

(d) Liquid and hazardous wastes will be stored in appropriate containers

separated from the general refuse;

(e) Site work vehicles and machinery will only be permitted to be

washed on site in case of spill of construction works material e.g.

mixed cement; in these cases, it will be washed only in designated

areas where runoff will not pollute natural surface water bodies.

(f) Portable toilets, or other appropriate option, will be installed during

construction, as directed by the Design and Supervision Firm

Waste Management (a) Contractor/beneficiary must ensure regular removal and disposal of

all site wastes

85


(b) All waste will be collected by licensed collectors and disposed of

properly at Fond Cole or other approved locations by GoCD and the

PIU, and the records of waste disposal shall be maintained as proof

for proper management as designed.

(c) Whenever feasible the contractor will reuse and recycle appropriate

and viable materials.

(d) Temporary storage of wastes should be away from watercourses and

springs.

(e) Under no circumstances shall the contractor(s) allow construction

wastes to accumulate as to cause a nuisance or health risk due to the

propagation of pests and disease vectors.

Potential impacts to

forests, rivers,

wetlands and/or

protected areas or

other sensitive areas

Biodiversity (a) Establish barrier area to protect sensitive area

(b) Verify that drainage and siltation do not affect the sensitive area.

(c) All recognized natural habitats, wetlands and protected areas in the

immediate vicinity of the activity will not be damaged or exploited;

(d) All workers will follow a Code of Conduct that strictly prohibits

from hunting, foraging, logging or other damaging activities in

surrounding areas.

(e) Project will develop communication and awareness among workers

(f) Adjacent wetlands and streams shall be protected from construction

site run-off with appropriate erosion and sediment control features,

including but not limited to silt fences

(g) There will be no unlicensed borrow pits, quarries or waste dumps in

adjacent areas, especially not in or adjacent to protected areas.

(h) Extraction of construction materials will follow authorization from

applicable authorities.

(i) Construction materials will only be purchased from authorized

dealers.

G. Pest control Potential impacts to

environment and to

workers’ health and

safety

Pest management (a) Construction sites must ensure that control of rodents and other

pests is performed safely by registered pest control companies.

(b) Small quantities of pesticides must be stored in a locked, well

ventilated cupboard in a storeroom, away from food and water

supplies, out of the reach of children, and in covered properly

labelled, intact bottles or packages.

(c) Pesticides will not be purchased in, or transferred to, unlabeled plastic

containers or plastic bags.

86


(d) Pesticides will not be transported together with food, animal feed or

drinks

(e) Workers should always wear protective clothing as necessary while

using pesticides (gloves, eye, shields, respirators, overalls, boots)

(f) Use the proper application equipment for applying pesticides

(g) Always ensure that pesticides spray equipment is properly

maintained and calibrated

(h) Empty pesticides containers shall not be used to store water or

drinks, but instead shall be disposed of together with the hazardous

wastes.

(i) Pesticides equipment and containers shall not be washed in water

bodies (rivers, lakes, sea, streams).

H. Use of Toxic

Materials

Potential

contamination with

asbestos

Asbestos management

(a) If asbestos is located on the project site, it shall be marked clearly,

and treated and disposed of as hazardous material in collaboration

with the DSWMC using international best practices

(b) When possible, the asbestos will be appropriately contained and

sealed to minimize exposure

(c) The asbestos prior to removal (if removal is necessary) will be

treated with a wetting agent to minimize asbestos dust

(d) Asbestos will be handled and disposed by skilled & experienced

professionals

(e) If asbestos material is to be stored temporarily, the wastes should be

securely enclosed inside closed containments and marked

appropriately. Security measures will be taken against unauthorized

removal from the site.

(f) The removed asbestos will not be reused.

Toxic / hazardous

waste management

(a) Temporarily storage on site of all hazardous or toxic substances will

be in safe containers labeled with details of composition, properties

and handling information

(b) The containers of hazardous substances shall be placed in a leak-

proof container to prevent spillage and leaching

(c) The wastes shall be transported by specially licensed carriers and

disposed in a licensed facility.

(d) Paints with toxic ingredients or solvents or lead-based paints will not

be used.

(e) All paints and preservatives shall be used only with the approval of

the Design and Supervision Firm and the PIU.

(f) Storage, use, and disposal of excess paints and preservatives shall be

managed in conformance with the manufacturers’ recommendations

and as approved by the Design and Supervision Firm and the PIU.

87


(g) The contractor shall provide the Design and Supervision Firm and

the PIU. with a list of hazardous materials and estimated quantities

to be used, storage, spill control and waste disposal plans to be

observed during the execution of the contract.

COMPLETION OF CONSTRUCTION AND DEMOBILIZATION

I. Demobilization

of activities and

equipment

Potential impacts to

natural environment

Protection of natural

environment

(a) Notification of owners of termination of works, and prepare and

sign a works completion handover protocol

(b) Restoring surface and vegetation where it has been significantly

disturbed

(c) Taking out all waste after completion of the construction and

disposing of it according to approved procedures by the PIU/GoCD.

(d) Removal of all signage from site?

88


PART 4: Monitoring Plan

Parameter

Verification of Mitigation Measure Monitoring

location

Monitoring

method Frequency

Agents

Responsible for

ensuring

compliance

Phase

Drainage

Verify good drainage to avoid water release into

stream and neighboring properties.

At site

Visually and

where

applicable,

proof of

receipts

Each site

visit:

minimum 3

visits per

household

Design &

supervision firm

Verify good drainage around completed house by

channels and ditches.

Sedimentation

When necessary, verify that temporary devices are

used to reduce/prevent off-site sediment transport

during heavy rainfall.

Pest prevention

and control

Verify good drainage and waste management

implementation to avoid disease vector breeding

sites.

Erosion and

other

environmental

degradation

Verification that aggregate (sand and gravel) was

obtained at the two approved active quarries in

Colihaut, and the one in Layou and other approved

by the GoCD/PIU.

Re-use salvaged materials (particularly timber)

Air quality

Verify dust suppression techniques during site

clearing, demolition, excavation and construction

activities.

Waste

management

Verify that all building and construction debris is

waste segregated, and dispose it at the Ford Cole

sanitary landfill (no local disposal or burning of

89


Parameter


location

Monitoring

method Frequency

Agents

Responsible for

ensuring

compliance

waste material) or other approved location by the

DWSMC.

Potentially hazardous wastes (e.g. used machinery

oils, lubricants, solvents, pesticides, paints or

cleaners) are appropriately stored, handled,

transported, and disposed of in a manner that

prevents environmental contamination.

Verify good house-keeping practices on site, such

as sorting and placing loose construction materials

or demolition debris in established areas.

Wastewater

Verify that sanitation facilities for the house have

adequate sewage disposal that will not contaminate

drinking water sources, streams, or neighboring

properties.

Workers’ health

and safety

practices

Use appropriate Personal Protection Equipment

such as safety glasses with side shields, face

shields, hard hats, and safety shoes.

Conduct sawing, cutting, grinding, sanding,

chipping or chiseling with proper guards and

anchoring as applicable.

Use temporary fall protection measures in

scaffolds and out edges of elevated work surfaces

Ensure access to adequate toilet/latrine facilities.

90


Parameter


location

Monitoring

method Frequency

Agents

Responsible for

ensuring

compliance

Controlled

access to site

Verify that restrict access to the construction site is

enforced (particularly children)

Traffic

management

Verify that traffic procedure has been approved by

the Dominica Police Force Traffic Department Access roads

Social

Management

Provide opportunities for employment and training

of labor from the host community

At site

No employment of labor under the age of 16 or

labor that will prevent attendance at school.

Provide Consultation on Code of Conduct and

verify that contactors are aware of and willing to

adhere to it.

No forced labor. All immigrants must present valid

work permits)

Site

decommissioning

Waste

management

Verify that site is cleared and cleaned of all

construction wastes and debris by project

completion.

At site

The Design and Supervision Firm will use the Monitoring Plan in Part 4 of the ESMP to develop and prepare a

monitoring report for monitoring each beneficiary home during each site visit. The checklist will have a section to

include comments for each mitigation measure of the parameters during each visit (see sample template). These can

be compared to determine environmental and social patterns for each site visit based on the following reports:

▪ Individual site progress per visit – to identify challenges in light of solving them early and to identify good

practices that can be applied in other households.

▪ Individual site progress overtime – to identify recurring or new challenges in light of solving them early

and to identify good practices that can be applied in other households.

▪ Development planning districts – to inform current and future physical planning in the various districts,

including the Kalinago Territory.

All reports will be submitted to the PIU as agreed.

Sample Monitoring Report Template:

HRP ESMP Compliance Monitoring for Beneficiary ID #_____in the ____ District, site visit #

Phase: e.g. Site preparation or Construction or Decommissioning

Site visit: e.g. #1 or #2 etc

Date of visit: day-month-year

Parameter Compliance Comments

Yes No

Site assessment conducted by:_________________

Date of submission to PIU: ____________________

Report received at PIU by: _____________________

Date received by Safeguard Specialist: ___________

Follow up action required: _______________________

The final ESMP monitoring report will be completed by the Design and Supervision Firm on site

closure/decommissioning, which will include a comparison of all site visits per household beneficiary.

HRP ESMP Comparative Compliance Monitoring for Beneficiary ID #_____in the ____ District

92


Phase: e.g. Site preparation or Construction or Decommissioning

Site visit: e.g. #1 or #2 etc

Date of visit: day-month-year

Parameter Compliance Comments

Visit #1 Visit #2 Visit #3

Yes No Yes No Yes No

Site assessment conducted by:_________________

Date of submission to PIU: ____________________

Report received at PIU by: _____________________

Date received by Safeguard Specialist: ___________

Follow up action required: _______________________

93


Annex 9: Project Results Framework – Dominica Housing Recovery Project

Indicator Name Frequency Data Source/Methodology Responsibility for

Data Collection Direct project beneficiaries Semi annual Project's progress report (based

on TAC progress reports) PIU/MoP/MoHL

Percentage of which are Female Semi annual Direct beneficiaries are people or groups who directly derive benefits from the Project including a subsidy or utilizing

services from the TACs. Assumes 2.7 people per household per 2011 census data. Number of households with resilient

housing recovered using project

subsidies27

Semi annual Project's progress report (based

on TAC progress reports and

PPD database)

PIU/MoP/MoHL

Percentage of female‐headed households

(primary beneficiaries) Semi annual

This indicator is defined as the number of households that received project subsidies and have a completion certificate for

resilient housing reconstruction. It is meant to track progress made to increase stock of houses built to resilient standards. Number of households that accessed

general advice service from TACs and

benefit from streamlined permitting

process



PPD database)

PIU/MoP/MoHL

Number of female‐headed households

(primary beneficiaries) Semi annual

This indicator measures the number of households that accessed general advice service from TAC and benefit from

streamlined permitting process. It also denotes level of public awareness of project activities. Number of on-demand building

assessments performed by TACs Semi annual Project's progress report (based

on TAC progress reports)

PIU/MoP/MoHL

This indicator measures the uptake of TAC’s building assessment services. Number of building permits issued Semi annual Project's progress report (based


PPD database)

PIU/MoP/MoHL

This indicator measures uptake of TAC’s building permitting streamlining services Number of subsidies disbursed Semi annual Project's progress report (based


PPD database)

PIU/MoP/MoHL

This indicator measures progress made on tranche disbursement to beneficiaries (3 tranches per household) Share of grievance cases resolved within

6 weeks of submission Semi annual Project's progress report (based


This indicator measures the efficiency of the Government in addressing the registered complaints. Number of communication campaigns

delivered to affected communities and

general public



This indicator measures the roll‐out of communication campaigns related to resilient building practices and project

activities which will be identified in the Communication Strategy. There will a minimum of three campaigns in the first

year to ensure effective communication, and at least one campaign a year in the subsequent years

27 The beneficiary selection criteria for allocation of the house reconstruction grant assign priority to beneficiaries,

who meet a range of vulnerability characteristics (see Section 6.1). These primary beneficiaries are not confined to

female-headed households. Therefore, to capture the achievement of this prioritization, project monitoring needs to

report the percentage of three sub-sets of vulnerable beneficiaries, namely (i) female-headed households with

children below 15 years of age, (ii) households with disabled head of household, and (iii) households with elderly

head of household.

Annex 10: ESMF Mitigation Table

HRP ENVIRONMENTAL, SOCIAL, HEALTH & SAFETY MITIGATION TABLE, RESPONSIBILITIES AND COSTS

ACTIVITY POTENTIAL

IMPACTS

MITIGATION ACTION/S

AGENCY or

OTHER AGENT

RESPONSIBLE

FOR

MITIGATION

AGENCY

RESPONSIBLE

FOR

MONITORING/

SUPERVISION

FREQUENC

Y

MEANS OF

VERIFICATIO

N

COST OF

MITIGATION/

SOURCE OF

FUNDS

Component 1 – Support for Housing Recovery Systems and Capacity Building (US$3.5 million)

Project Design phase

1. Preliminary

selection of

beneficiaries of

the subsidy

among a

demand-driven

base of

applications

1. Potential

politicizing of

the selection

process, with

risk of not

addressing

poverty and

vulnerability,

and/or not

reaching the

most needed.

1.a - Establishment of clear

selection criteria – included in

this ESMF and in the Project

Operational Manual (POM)

with prioritization given to (i)

households that are still in

hurricane shelters, and (ii)

single parent households with

children under 16 years; (iii)

households with a disabled

household head, and (iv)

households with an elderly

household head.

Four preparatory activities

will be undertaken: (i) a

national information campaign

to inform the population about

the project approach, the

criteria for beneficiary

selection, the deployment of

technical services/TACs,


and building contractors, and

the Grievance Redress

Mechanism, (ii) set up of a

Beneficiary Selection Review

Social Specialist in

the PIU (Ministry of

Housing and Lands -

MoHL) and HRP

Beneficiary

Selection Review

Committee.

Social Specialist

in the PIU

(MoHL) with

support from the

Implementation

Support Team

(IST) within

Ministry of

Finance (MoF)

Once during

Project design

Project Progress

Report,

Public online

listing

Included in

Project

Cost/Componen

t 3 (US$ 3

million) –

Project

Implementation

and

Administration

95


Committee, (iii) set up of a

Grievance Committee to

address complaints on the

Project, and (iv) a site visit to

assess the environmental risks.

The eligibility criteria that will

be applied in the beneficiary

selection process (Section 6.1

of this ESMF) involve both

environmental and socio-

economic considerations. The

HRP Beneficiary Selection

Review Committee will

review and validate the list of

beneficiaries and produce a

list of confirmed

beneficiaries. This list will be

made public locally and on-

line (project website at

MoHL) as a final step in the

validation and confirmation.

1. b - The HRP Communication

Strategy will seek to disseminate

information on the Project,

including social services, local

government and shelter

managers to create awareness

and engage the most needed in

the self-driven application (e.g.,

female headed households with

dependent children, including

grandmothers as caregivers for

grandchildren, which make up a

large proportion of those still in

temporary shelters; these will

benefit from the communication

and outreach strategy, since

these categories of prioritized

beneficiaries are likely to have

Social Specialist in

the PIU (Ministry of

Housing and Lands -

MoHL) and HRP

Beneficiary

Selection Review

Committee.

Social Specialist

in the PIU

(MoHL) with

support from the

Implementation

Support Team

(IST) within

Ministry of

Finance (MoF)

Once during

Project design

Project Progress

Report,

HRP

Communication

Strategy on HRP

website

Included in

Project

Cost/Componen

t 3 (US$ 3

million) –

Project

Implementation

and

Administration

96


limited access to information

about the project, and also

limited ability to act on such

information.

2. Screening of

potential

beneficiaries’

site for

suitability for

resilient home

reconstruction

(focusing on

beneficiaries

who lost

homes less

than 500 sqft)

- assess

adequacy of

land based on

site hazards

and natural

disasters risks.

2. Lots

potentially

located in

unsuitable

areas (risks of

flooding,

landslides,

degraded

environment,

etc..) or to be

relocated in

same lot but

affecting

owner’s own

crops or other

assets.

2. Screening criteria established in

the ESMF and the POM and

coordination with other

Government programs to deal

with ineligible applicants under

this Project

The demand driven approach

allows owners to decide if they

want to lose some crops or

assets to build/rebuild their

homes (not involuntary) and to

avoid removal of trees

particularly on the border of

forest and protected areas.

Technical Services

(architects/engineers)

and National

Parks/forest reserve

officials.

Environmental

and Social (E&S)

Specialists in the

PIU (MoHL)

with support

from the IST

within MoF, and

if needed,

Forestry, Wildlife

& National Parks

Division.

Individually to

each potential

beneficiary, on

a first-

come/first

serve basis

Project Site Risk

Assessment

Report on

Potential

Beneficiaries

Included in

Project

Cost/Sub-

component 1.1 -

Planning and

Support to

Technical

Assistance

Centers (TACs)

(US$ 2.7

million) and

Component 3

(US$ 3 million)

– Project

Implementation

and

Administration

3. Implementation

of housing

reconstruction

in the Kalinago

Territory

3. Potential lack

of

compliance

with Bank

Policy 4.10

(Indigenous

People)

3.a - Preparation and

implementation of the Project

in the Kalinago Territory will

be conducted through the

elected Kalinago Council and

the Ministry of Kalinago

Affairs, including ensuring

free, prior and informed

consultation, and a broad

Kalinago people’s support for

the project.

Social Specialist E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

4 consultations

held during

project design

Consultation brief

inclusion in the

IPP

Included in

Project

Cost/Componen

t 3 (US$ 3

million) –

Project

Implementation

and

Administration

97


3.b – Preparation of an Indigenous

Peoples Plan (IPP) to support

the unique needs of the

Kalinago in Dominica under

the HRP.

Social Specialist E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

Once during

project design

Project Progress

Report,

IPP disclosed

online

Included in

Project

Cost/Componen

t 3 (US$ 3

million) –

Project

Implementation

and

Administration

4. Proof of

ownership of

land through a

registered title,

a registered

deed or an

unregistered

deed.

4. Potential

difficulties for

beneficiaries

to obtain proof

of ownership.

4. The Project will facilitate,

when required, through the

Ministry of Housing and Lands

acquiring legal evidence of

land ownership, but will not

finance tenants or leaseholders,

since there are other programs

suited to this need. The Project

does not support commercial

properties either.

Home owner

Registry

E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

Individually to

each

beneficiary, on

a first-

come/first

serve basis

Project Progress

Report

Copy of title/deed

on file

Included in

Project

Cost/Componen

t 3 (US$ 3

million) –

Project

Implementation

and

Administration

5. Project design

of individual

houses for the

beneficiaries

selected

through 1 and 2

above.

5.a –Design of

houses that

are

potentially

above the

individual’

s financial

resources

(Project

grant plus

individual

resources).

5.a - The Design and Supervision

Firm hired by the Project will

ensure that design is appropriate to

beneficiaries’ financial means

The Design and

Supervision Firm

E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

Individually to

each

beneficiary, on

a first-

come/first

serve basis

Project Progress

Report on Design

& Supervision

Included in

Project

Cost/Componen

t 3 (US$ 3

million) –

Project

Implementation

and

Administration

5.b – Design of

houses that

are

potentially

unsuited for

the

topography

or other

physical

5.b - The Design and Supervision

Firm hired by the Project will

ensure that design is appropriate to

the physical characteristics of the

beneficiaries’ lot and specific site

characteristics will be flagged in

the initial site assessment by the

technical support team.

The Design and

Supervision Firm &

Technical Support

Teams

E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

Individually to

each

beneficiary, on

a first-

come/first

serve basis

Project Progress

Report on Design

& Supervision

Included in

Project

Cost/Componen

t 3 (US$ 3

million) –

Project

Implementation

and

Administration

98


features of

the lot.

6. Technical

Design of a

New Physical

Development

Planning

Office in the

same site of the

previous

building that

was destroyed

by the

hurricane.

6. – Although the

Project will only

finance the

detailed design of

the new building,

the future

construction (even

if not financed by

the Bank) could

incur potential

EHS impacts if

these aspects are

not incorporated

in the design

phase.

The design of the building will

also include an ESMP to address

the EHS impacts and risks of the

future construction of the building

and such ESMP should be

incorporated into the bidding

documents for the design.

Design Firm to be

contracted through a

competitive process

E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

Upon

implementation

of Sub-

component 1.3

Project Progress

Report

RFP,

Completed design

demonstrating

inclusion of EHS

elements

Included in

Project

Cost/Sub-

component 1.3 –

(US$0.2

million) and

Component 3

(US$ 3 million)

– Project

Implementation

and

Administration

Component 2 - Subsidies to homeowners on a demand-driven basis (US$ 33.5 million)

Construction phase

7. Small

construction

activities for

individual

houses (up to

500 sqft)

7.a – Civil works

may require

the removal

of existing

debris with

potential for

inadequate

disposal

leading to

pollution of

water and

soil, or health

hazard in the

nearby

community.

7.a – Each Contractor or owner

(when self-construction) will be

required to follow an

Environmental and Social

Management Plan (ESMP) for

individual small construction,

including Debris Management

requirements to dispose of debris

in the Fond Cole sanitary landfill

or other location approved by

GoCD and the PIU.

The Contractor or

the Beneficiary

through his own

building personnel

(self, relatives and/or

community

members).

The Design and

Supervision

Firm, Dominica

Solid Waste

Management

Corporation, the

E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

As a minimum,

every other

week

supervisions by

the Design &

Supervision

Firm

Project Progress

Report on ESMP

implementation

Individual ESMP

Inspections and

supervisions

included in

Project

Cost/sub-

component 2.2 –

Design and

Supervision of

House

Reconstruction

(US$ 2.05

million) and

Component 3

(US$ 3 million)

– Project

Implementation

and

Administration

7.b – Civil works

may require

removal of trees

7.b - Each Contractor or owner


required to follow an ESMP for

The Contractor or

the Beneficiary

through his own

The Design and

Supervision

Firm, the E&S

As a minimum,

every other

week

Project Progress

Report on ESMP

implementation

Included in

Project Cost/

sub-component

99


in very small

quantities, which,

however, if

unregulated may

lead to

environmental

degradation.

individual small construction, that

may include the need to consult

with Forest, Wildlife and National

Parks Division and follow specific

measures for trimming or removal

of individual trees only if

necessary on site.

building personnel


community

members).

Specialists in the

PIU (MoHL)

with support

from the IST

within MoF, and

if required,

Forestry

Division.

supervisions by

the Design &

Supervision

Firm

Individual ESMP 2.2 – Design

and Supervision

of House

Reconstruction

(US$ 2.05

million) and

Component 3

(US$ 3 million)

– Project

Implementation

and

Administration

7.c – Civil works

may require use

of aggregate

(sand, stone and

gravel) in small

quantities, given

the size of the

houses, which

however, if

unregulated may

lead to

environmental

degradation,

erosion,

sedimentation of

water bodies.

7.c - Each Contractor or owner

will be required to follow an

ESMP for individual small

construction, including

requirements to use only aggregate

from existing quarries approved by

GoCD (Physical Planning

Division) and the PIU.

The Contractor or

the Beneficiary

through his own

building personnel


community

members).

The Design and

Supervision

Firm, the E&S

Specialists in the

PIU (MoHL)

with support

from the IST

within MoF.

As a minimum,

every other

week

supervisions by

the Design &

Supervision

Firm

Project Progress

Report on ESMP

implementation

Individual ESMP

Included in

Project Cost/

sub-component

2.2 – Design

and Supervision

of House

Reconstruction

(US$ 2.05

million) and

Component 3

(US$ 3 million)

– Project

Implementation

and

Administration

7.d – Civil works

may require the

use of very small

to minimal

quantities of pest

control products

(given the small

size of the homes)

to control termite

in building

foundations and

7.d - Each Contractor or owner




including requirements for use of

small quantities of pest control

products authorized by the

Dominica Pest Control Board, and

in consultation with Forest,

Wildlife and National Parks,

Environmental Health Department

The Contractor or

the Beneficiary

through his own

building personnel


community

members).

The Design and

Supervision

Firm, the E&S

Specialists in the

PIU (MoHL)

with support

from the IST

within MoF, and

when required

the Forestry

Division and

As a minimum,

every other

week

supervisions by

the Design &

Supervision

Firm

Project Progress

Report on ESMP

implementation

Individual ESMP

Included in

Project Cost/

sub-component

2.2 – Design

and Supervision

of House

Reconstruction

(US$ 2.05

million) and

Component 3

(US$ 3 million)

100


control of rodents,

ants, and other fly

animals and

common

household pests

that if unregulated

may lead to fauna,

flora and water

contamination, as

well as health and

safety risks to

workers and

surrounding

communities.

and the PIU and to be done

through licensed registered

professional contractors.

Environmental

Health

Department.

– Project

Implementation

and

Administration

7.e – Although

remote, the

possibility exists

for civil works to

uncover

archaeological

finds of pre-

Colombian and

later colonial and

Creole

settlements, or

skeletal remains.

7.e - Each Contractor or owner




including requirements to follow a

Chance Finds Procedure

(communicating any

archaeological physical cultural

findings to Roseau Market Trust

for the National Museum in

Roseau, any natural cultural

findings to the Forestry, Wildlife

and National Parks Division and

skeletal remains to the Dominica

Police Force Central Investigation

Department (CID).

The Contractor or

the Beneficiary

through his own

building personnel


community

members).

E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF

in collaboration

with the Roseau

Market Trust or

the Forestry

Division or the

CID.

As a minimum,

every other

week

supervisions by

the Design &

Supervision

Firm

Project Progress

Report on ESMP

implementation,

Individual ESMP

Included in

Project Cost/

sub-component

2.2 – Design

and Supervision

of House

Reconstruction

(US$ 2.05

million) and

Component 3

(US$ 3 million)

– Project

Implementation

and

Administration

7.f – Although

most of the

construction will

likely be made by

beneficiaries

themselves,

relatives, friend

and community

members, it may

7.f - Each Contractor or owner




including requirements to follow a

Workers’ Code of Conduct. In

addition, the project will follow an

approach which has been

successfully applied in other civil

The Contractor or

the Beneficiary

through his own

building personnel


community

members).

The Design and

Supervision

Firm, and the

E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

As a minimum,

every other

week

supervisions by

the Design &

Supervision

Firm

Project Progress

Report on ESMP

implementation,

Construction

Labor Agreement,

Workers’ Code of

Conduct

Included in

Project Cost/

sub-component

2.2 – Design

and Supervision

of House

Reconstruction

(US$ 2.05

million) and

101


also involve pre-

qualified building

contractors in a

small scale, thus

potentially

involving

minimal labor

influx, potentially

resulting in

conflicts with

existing

communities.

works projects in Dominica using

local contractors. It involves a

meeting held before the start of

physical works between the

concerned local governance entity

and the contractor, where the PIU

will be represented, and where

issues related to the work and the

contractor’s presence are discussed

and agreed upon in writing

(Construction Labor Agreement).

Component 3

(US$ 3 million)

– Project

Implementation

and

Administration

7.g – Inadequate

consideration of

environmental,

social, health and

safety (ESHS)

aspects during

construction, such

as air pollution,

increased noise,

potential traffic

increase and

increase of risk of

traffic accidents

involving

community

members, etc.

7.g.1 – Prior to finalization of each

individual Grant Agreement, the

Design & Supervision Firm will

inform each beneficiary of the

ESMP requirements during

construction and will assist with

obtaining a building permit, if

needed.

The Design and

Supervision Firm

E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

Prior to each

Grant

Agreement

Project Progress

Report on ESMP

implementation

Included in

Project Cost/

sub-component

2.2 – Design

and Supervision

of House

Reconstruction

(US$ 2.05

million) and

Component 3

(US$ 3 million)

– Project

Implementation

and

Administration

7.g.2 – The ESMF includes a

generic ESMP (in Annex 8) to

address the potential ESHS of

small construction activities,

including, but not limited to,

Construction Waste Management,

Waste and Hazardous Waste

Management, Effluents

Management, limit construction

hours to 7am-7pm week days,

comply with noise standards, and

promote this publicly; use dust

suppression techniques, use dust

The Contractor or

the Beneficiary

through his own

building personnel


community

members).

The Design and

Supervision

Firm, and the

E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

As a minimum,

every other

week

supervisions by

the Design &

Supervision

Firm

Project Progress

Report on ESMP

implementation

Included in

Project Cost/

sub-component

2.2 – Design

and Supervision

of House

Reconstruction

(US$ 2.05

million) and

Component 3

(US$ 3 million)

– Project

Implementation

102


control measures such as, for

example, enclosures and covers,

increase of moisture contents of

materials, install sewage systems

for workers, etc.

and

Administration

7.h – Potential

health and safety

risks for workers

during building

activities, such as

cave-ins during

excavations, falls

from heights, slip

and trips,

dismembering

when working

with electrical or

mechanic

equipment, etc.

7.h – The ESMF includes a

generic ESMP (in Annex 8) to

address the potential HS of small

construction activities, and the


review and supervise the use of

adequate PPEs and

implementation of standard

operating procedures for key

activities on small construction,

such as excavation, working on

heights, scaffolding, etc

The Contractor or

the Beneficiary

through his own

building personnel


community

members).

The Design and

Supervision

Firm, and the

E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

Prior to

launching of

the Project and

every other

week

supervisions by

the Design &

Supervision

Firm

Project Progress

Report on ESMP

implementation,

Site visit during

construction,

SOPs for key

activities on small

construction

Included in

Project Cost/

sub-component

2.2 – Design

and Supervision

of House

Reconstruction

(US$ 2.05

million) and

Component 3

(US$ 3 million)

– Project

Implementation

and

Administration;

cost of

implementing

the ESMP must

be included in

the cost of the

construction, as

estimated for the

Grant

7.i- Potential

impacts and risks

to communities

from

transportation of

heavy equipment

and building

materials.

7.i- The ESMF includes a generic

ESMP (in Annex 8) to address the

potential ESHS of small



review and supervise the

implementation of a Community

Safety Management Plan,

including traffic plan, adequate

signage to call attention to traffic

risks, limiting vehicle speed in

The Contractor or

the Beneficiary

through his own

building personnel


community

members).

The Design and

Supervision

Firm, and the

E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

As a minimum,

every other

week

supervisions by

the Design &

Supervision

Firm

Project Progress

Report on ESMP

implementation,

Traffic Plan

Site visit

Included in

Project Cost/

sub-component

2.2 – Design

and Supervision

of House

Reconstruction

(US$ 2.05

million) and

Component 3

(US$ 3 million)

– Project

103


access roads, limiting hours for the

delivery of building materials, etc.

Implementation

and

Administration;

cost of

implementing

the ESMP must

be included in

the cost of the

construction, as

estimated for the

Grant

7j. Inadequate and

poorly managed

community

relations leading

to psycho-social

tensions towards

the project,

contractors and

staff and design

and supervision

firm.

7j Social Management

Components of ESMP:

Inform the local authorities and

community about construction

and work schedules, interruption

of services, traffic detour routes

and provisional bus routes, as

appropriate.

Social sensitivity should be

applied in communities within the

Kalinago Territory and other

minority demographic groups.

The Code of Conduct is

established and should be

followed.

The Design and

Supervision Firm,

The Contractor

The Design and

Supervision firm,

The PIU

Safeguards

specialists

Throughout the

construction

phase as

required by

monitoring

schedule

Project Progress

Report on ESMP

implementation,

Community

meeting

Cost of

implementing

the ESMP must

be included in

the cost of the

construction, as

estimated for the

Grant

104


7k. Poorly

Managed Solid

Waste/Debris

Disposal around

construction sites

leading to

potential

community health

and

environmental

health risks.

There is also the

potential impact

of material spills

that poses safety

risks to the wider

community where

construction

works are being

conducted. This

may include

vector borne

diseases and

generally affect

the aesthetics of

the community’s

natural and built

environment

7k Proper disposal of construction

waste through a waste

management plan which will

include and in accordance with the

national regulations:

Ensuring that there are

daily site clean-up procedures,

including maintenance of adequate

disposal facilities for construction

debris.

Utilizing reduce reuse recycle

principle for all demolition debris

generated; and where not feasible,

the carrying of this debris to

designated and approved sites.

This will ensure that there is

restoration of the affected area to

its original state to the satisfaction

of the HRP PIU and/or delegated

agencies and local communities.

The Design and

Supervision Firm,

The Contractor

The Design and

Supervision

Firm,

The PIU

Safeguards

specialists

Throughout the

construction

phase as

required by

monitoring

schedule

Project Progress

Report on ESMP

implementation,

Waste

Management

Procedure,

Site visit

Cost of

implementing

the ESMP must

be included in

the cost of the

construction, as

estimated for the

Grant

7. l. Reduced

Water quality,

liquid and solid

waste discharge

7.l Whenever possible, the

amounts of wastewater that need

to be discharged must be

minimized and alternative means

of disposal must be identified.

Liquid spills of lubricant, fuel and

oil within the site should be

attended at the earliest in order to

minimize land & groundwater

contamination.

The Design and

Supervision Firm,

The Contractor

The Design and

Supervision

Firm,

The PIU

Safeguards

specialists

Throughout the

construction

phase as

required by

monitoring

schedule

Project Progress

Report on ESMP

implementation,

Site visit

Cost of

implementing

the ESMP must

be included in

the cost of the

construction, as

estimated for the

Grant

105


(Procedures are included in the

ESMP)

7m. Poor

sanitation within

and around

construction sites

7.m The necessary training shall

be conducted for contractors and

their employees and this will be

ensured by the D&S Firm with

further validation by the PIU

safeguards specialists.

Elements of any Health and Safety

Management plan developed will

include a checklist which should

be monitored and evaluated

periodically.

The Design and

Supervision Firm,

The Contractor

The Design and

Supervision

Firm,

The PIU

Safeguards

specialists

Throughout the

construction

phase as

required by

monitoring

schedule

Project Progress

Report on ESMP

implementation,

Site visit

Cost of

implementing

the ESMP must

be included in

the cost of the

construction, as

estimated for the

Grant

8. Closure and

decommissioning

of construction

sites

8.– Potential for

contamination

and pollution

from construction

materials left

behind; risks of

accidents with:

holes left

unprotected,

rebars

unprotected from

impalement risks,

wood uncleared

from steel nails,

etc.; risks of

contamination

with hydrocarbon

and/or chemical

spills.

8. The ESMF includes a generic

ESMP (in Annex 8) to address the

potential ESHS of small



review and supervise the

implementation of the procedures

for Site Decommissioning,

including decontamination of the

site, when required.

The Contractor or

the Beneficiary

through his own

building personnel


community

members).

The Design and

Supervision

Firm, and the

E&S Specialists

in the PIU

(MoHL) with

support from the

IST within MoF.

Inspection

prior to

authorizing the

last installment

to the

Contractor or

to the

Beneficiary.

Project Progress

Report on ESMP

implementation,

The cost of

implementing

the ESMP must

be included in

the cost of the

construction, as

estimated for the

Grant.

Annex 11: Housing Recovery Project ESMF: Consultations

Kalinago Council - October 11, 2018 in Saint Cyr Village

Persons met: Charles Williams, Chief

Jacqueline Corbette, Clerk

Jumadine Frederick, Councilor (Housing)

Issues raised and information provided by the Kalinago Council:

• Reconstruction of houses destroyed/damaged by Hurricane Maria will require approval by the

Council (whether the reconstruction/repair is done in situ or in a different location due to hazard

considerations).

• The Council has a list of houses that were totally damaged or compromised by Hurricane Maria,

and requests information on the number of new houses that will be constructed/financed under the HRP in

the Kalinago Territory. This information will enable the Council to determine the allocation of the housing

reconstruction assistance to those most in need.

• The Council has authority to allocate land for housing within the Kalinago Territory. For eligible

beneficiaries with a damaged house located on a hazard plot, the Council can identify and allocate a

different non-hazardous house plot.

• The Council know of renters/tenants (= non-owners) who resided in houses destroyed by Hurricane

Maria, but does not have a complete inventory of all such cases. Renters/tenants can apply to the Council

for an alternative plot for construction of a replacement house in the same way as an eligible beneficiary

with a damaged house located on a hazard plot.

• The Council requested that (a) as much as possible the housing reconstruction work should be done

with local labor, and (b) that the large number of hurricane-destroyed trees should be made use of for the

replacement houses (it was asserted that most of the hurricane destroyed houses in the Kalinago Territory

were built with imported lumber, whereas houses built with local timber has held up better).

Colihaut Village Council – October 19, 2018

Persons met: 14 female and male council members and villagers.

Issues raised and information provided:

Regarding HRP grievance redress arrangements, the Village Council members made the point that the

Councils should not be tasked as the direct recipients of complaints from the residents in their areas.

Members of these local governance bodies already have a range of responsibilities on top of their daily

work to make a living. The work associated with receiving and logging complaints could potentially

become quite time-consuming and burdensome, especially if community members engage in discussions

of their case in the expectation of an immediate decision, or advocacy by the Village Council when the case

is discussed with the project.

The other issue discussed during the meeting concerned families – some of whom were present at the

meeting - who lived under some form of tenancy arrangement in hurricane destroyed houses. It was argued

that such families should also be able to be considered as eligible for housing reconstruction assistance. It

was further suggested that in cases where an eligible family, who had been tenants in a hurricane destroyed

house, owned land elsewhere, the replacement house should be built on this land (assuming it was found to

be hazard-free). In cases were the replacement house had to be built in situ, there should be some form of

security of tenancy (at least for a defined period), and rents for the replacement house should not be allowed

to exceed the existing fair market rate in the area.