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ENVIRONMENTAL AND SOCIAL MANAGEMENT FRAMEWORK

DOMINICA HOUSING RECOVERY PROJECTFINAL DRAFT MAY 2019

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

TABLE OF CONTENTSACRONYMS................................................................................................................................................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..................................................................58

Annex 2: Map of Dominica’s Health Districts........................................................................................62

Annex 3: Map of Dominica’s Village Districts.......................................................................................63

Annex 4: Guidelines for World Bank Code of Conduct for Contracted Entities....................................64

Annex 5: Role of Direct Players and Key Partners in the Implementation of Safeguards......................66

Annex 7: HRP Application Form............................................................................................................68

Annex 8: HRP Environmental and Social Management Plan (ESMP) for Small Construction and Rehabilitation Activities..........................................................................................................................73

Annex 9: Project Results Framework – Dominica Housing Recovery Project.......................................94

Annex 10: ESMF Mitigation Table.........................................................................................................95

Annex 11: Housing Recovery Project ESMF: Consultations................................................................107

ACRONYMS need to cross check on final review

BDA Building Damage AssessmentCCA Copper Chrome Arsenate (timber treatment chemical)CDEMA Caribbean Disaster Emergency Management AgencyCPA Country Poverty AssessmentCREAD Climate Resilient Emergency Agency for DominicaDSWMC Dominica Solid Waste Management CooperationEC$ East Caribbean DollarEIA Environmental Impact AssessmentESMF Environmental and Social Management FrameworkESMP Environmental and Social Management PlanEU European UnionFM Financial managementGDP Gross domestic productGRM Grievance Redress MechanismGoCD Government of the Commonwealth of DominicaHH HouseholdHRP Housing Recovery ProjectHTF Housing Task ForceICT Information and Communication Technology Unit (the Ministry of

Information, Science, Telecommunications and Technology)IST Implementation Support TeamM&E Monitoring and evaluationMIS Management Information SystemMoF Ministry of FinanceMoHL Ministry of Housing, Lands and Water ResourcesMoKA Ministry of Kalinago AffairsMoP Ministry of Planning and Economic DevelopmentNGO Nongovernmental organizationNP National ParkPAD Project Appraisal DocumentPDNA Post‐Disaster Needs AssessmentPDO Project Development ObjectivesPID/ISDS Project Information Document/Integrated Safeguards DatasheetPIU Project Implementation UnitPPD Physical Planning Division (Ministry of Planning and Economic

Development)TAC Technical Assistance CenterToR Terms of ReferenceVNA Vulnerability Needs Assessment

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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 5 | 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

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 7 | 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

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 9 | 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

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


Beneficiary Selection Review CommitteeRepresentative of the Village / Kalinago Council Representative of Religious Organisation Representative of a Credit Union, Financial Institution or Cooperative AssociationRepresentative of any NGO's or other Civic Group in the regionOther Prominent Citizen e.g. Justice of Peace, community activistProfessionals/Academia Shelter Managers

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.

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:


HRP Grievance Redress CommitteeRepresentative of the Village / Kalinago Council Representative of Religious Organisation Representative of a Credit Union, Financial Institution or Cooperative AssociationRepresentative of any NGO's or other Civic Group in the regionOther Prominent Citizen e.g. Justice of Peace, community activistProfessionals/Academia

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

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


Receive Grievance

Record

Screen

Acknowledge

Investigate

Act

Follow up and Close out

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.

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

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.

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.

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 (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 PoliciesOP/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 PoliciesOP/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:

HRP Beneficiary Selection Review CommitteeRepresentative of the Village / Kalinago Council Representative of Religious Organisation Representative of a Credit Union, Financial Institution or Cooperative AssociationRepresentative of any NGO's or other Civic Group in the regionOther Prominent Citizen e.g. Justice of Peace, community activistProfessionals/Academia Shelter Managers


Similarly, the proposed HRP Grievance Redress Committee structure will comprise representatives from the following but not limited to:

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


HRP Grievance Redress CommitteeRepresentative of the Village / Kalinago Council Representative of Religious Organisation Representative of a Credit Union, Financial Institution or Cooperative AssociationRepresentative of any NGO's or other Civic Group in the regionOther Prominent Citizen e.g. Justice of Peace, community activistProfessionals/Academia

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.

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,

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


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

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.


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 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.

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.


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 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 sizesq.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

11 The PDNA (p.16) assesses that 90 percent of the population lives along the island’s coastline.


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 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.

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

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. 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.


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 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.

14 In the Kalinago Territory, such meetings will involve the relevant Hamlet Development Committee and representatives from the Kalinago Council.


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 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

15 http://www.ilo.org/dyn/normlex/en/f?p=1000:11200:0::NO:11200:P11200_COUNTRY_ID:10331116 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

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

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 & VERIFICATIONSTEP 1: APPLICATION OF ELIGIBILITY

CRITERIASTEP 2: CATEGORICAL PRIORITIZATION

AMONG ELIGIBLE HOUSEHOLDSSTEP 3: VERIFICATION

AND VALIDATIONPHYSICAL

Attributes Criteria Compliance

Attributes Prioritization Compliance

Activity

Source

YES

NO

YES

NO

1. House size

Up to 500 sq. ft. 1. Protracted displacement

a. Household is still living in a shelter

Verification

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

Validation

Information on the application from homeowner

3. Primary Residence

House is primary residence prior to hurricane

3. Demographic Vulnerability

a. Single parent household with children under the age of 16

Validation

Final list is published for transparency and feedback

4. Right to the land

Ownership of the property or documented permission to use the property

b. Disabled head of household (including sight, mobility, speech, mental)

5. Location and risk

Low hazard risk area c. Elderly head of household

6. Not impacting protected 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-ECONOMIC7. Prior su

pport Applicant has not received direct reconstruction/structural restoration of their homes through Government or donor housing program

7. Poverty Status

a. Household is a recipient of any Public Assistance Program

8. Insurance coverage

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 TACs/Design & Supervision Firm. The design options comprise reconstruction of 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.

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 KalinagoAs 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

20 This is done by so-called Alaskan mill lumbering, which involves cutting boards with a frame-mounted chain-saw.


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.


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 status of construction, (ii) discuss and if possible, resolve complaints received through 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

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 BUILDINGCapacity 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 DetailAwareness 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 SystemCommunities 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.

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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 ResponsibilityDominica 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 Responsibilityof 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 ActThe 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 ActDominica 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 BoardApproved 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.

Any housing development to be 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.

Any housing development to be 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 ResponsibilityDominica 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 Responsibilityregardless 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 EntitiesThe 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 SafeguardsDirect Player Work FocusWorld 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 SafeguardsPartners Area of Cooperation Support Process WB-OPRoseau 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

Downed trees management (promoted) / last resort -

Lumber Salvaging Activity (use of

OP4.01

Utilization Unit 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 FirmTAC support (if required)

Labour & working conditions Code of Conduct OP4.01

Contractor; Design & Supervision FirmTAC support (if required)

Environment, Health & Safety Personnel Protective Equipment

OP4.01

Contractor; Design & Supervision Firm; TAC support (if required)

Job hazard management Job Hazard Analysis & Procedures to Follow

OP4.01

Contractor; Design & Supervision Firm; TAC support (if required)

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 onlyIndividual 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 DetailsFirst 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

Age

Form of disability (if applicable)

Total Number:


Section C: Employment Status (Please mark X where applicable)

Unemployed Self-employedEmployedRetired 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 AssistanceOver 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 PropertyRegistered/Permission to Occupy

Damage to Home (Please mark X where applicable)Minor damagePartially destroyedCompletely 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 Deed4. Certificate of disability from a medical professional (if applicable)5. Certificate/proof confirming the right to occupy land6. 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 ManagerHousing Recovery Project - Project Implementing Unit

Old Street, RoseauCommonwealth 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 DateApplication received

Procedural Check

Application returned for correction

MIS captured data

Data verified

Review completed/Data validated

Filed


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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 AssessmentOP 4.09 Pest ManagementOP 4.10 Indigenous Peoples PlanOP 4.11 Physical Cultural ResourcesThe 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.


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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

Part 3 Content reviewed by the MIS firm to incorporate the ESMP in the MIS where appropriate 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

Part 4 Content reviewed by the MIS firm to incorporate the ESMP in the MIS where appropriate 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


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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


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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

Have the local construction and Yes No


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environment inspectorates and communities been notified of upcoming

activities?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 below5. 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 below8. 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


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10. Individual wastewater treatment system [ ] Yes [ ] No See Part 3/ Section F below11. Pest control [ ] Yes [ ] No See Part 3/ Section G below

12. Hazardous or toxic materials [ ] Yes [ ] No See Part 3/ Section H below13. 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


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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



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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

24 These are Best Management Practices (BMPs) that should be applied at all sites, as possible.


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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.

(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


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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, 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 Traffic and Community (a) The Contractor or Design & Supervision Firm will enforce a generic 25 Diameter at Breast Height (DBH)


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hazards to public traffic and

pedestrians by construction

activities

Safety 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.

(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.


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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 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

26 Also known as Standard Operating Procedures.


87

(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, sanding, machining) timber treated with

Copper Chrome Arsenate (CCA)

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.

(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.


88

(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

(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

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


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safety 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.

(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


90

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.

(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?


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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.

SedimentationWhen 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 waste material) or other approved location by the


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ensuring compliance

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.

Controlled Verify that restrict access to the construction site is


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ensuring compliance

access to site 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

95

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: _______________________


96

Annex 9: Project Results Framework – Dominica Housing Recovery ProjectIndicator Name Frequency Data Source/Methodology Responsibility for

Data CollectionDirect project beneficiaries Semi annual Project's progress report (based

on TAC progress reports)PIU/MoP/MoHL

Percentage of which are Female Semi annualDirect 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

Semi annual Project's progress report (based on TAC progress reports and 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

on TAC progress reports and PPD database)

PIU/MoP/MoHL

This indicator measures uptake of TAC’s building permitting streamlining servicesNumber of subsidies disbursed Semi annual Project's progress report (based

on TAC progress reports and 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


PIU/MoP/MoHL

This indicator measures the efficiency of the Government in addressing the registered complaints.Number of communication campaigns delivered to affected communities and general public


PIU/MoP/MoHL

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 RESPONSIB

LE FOR MONITORIN

G/SUPERVISIO

N

FREQUENCY

MEANS OF VERIFICATI

ON

COST OF MITIGATIO

N/SOURCE

OF FUNDS

Component 1 – Support for Housing Recovery Systems and Capacity Building (US$3.5 million)Project Design phase1. 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

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/Component 3 (US$ 3 million) – Project Implementation and Administration

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deployment of technical services/TACs, Design & Supervision Firm 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 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,

Social Specialist in the PIU (Ministry of Housing and Lands - MoHL)

Social Specialist in the PIU (MoHL) with support from

Once during Project design

Project Progress Report,HRP Communicatio

Included in Project Cost/Component 3 (US$ 3 million) –


99

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

and HRP Beneficiary Selection Review Committee.

the Implementation Support Team (IST) within Ministry of Finance (MoF)

n Strategy on HRP website

Project Implementation and Administration

2. Screening of potential beneficiaries’ site for suitability for resilient home reconstruction (focusing on beneficiaries who lost homes less than 500 sqft) - assess adequacy

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 ProjectThe 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


100

of land based on site hazards and natural disasters risks.

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


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


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

Home ownerRegistry

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 ReportCopy of title/deed on file



101

commercial properties either.

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



Project Progress Report on Design & Supervision


5.b – Design of houses that are potentially unsuited for the topography or other physical features of the lot.

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



Project Progress Report on Design & Supervision


6. Technical Design of a New Physical Development Planning Office in the same site of the previous

6. – Although the Project will only finance the detailed design of the new building, the future construction (even if not

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


Upon implementation of Sub-component 1.3

Project Progress ReportRFP,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) –


102

building that was destroyed by the hurricane.

financed by the Bank) could incur potential EHS impacts if these aspects are not incorporated in the design phase.


Component 2 - Subsidies to homeowners on a demand-driven basis (US$ 33.5 million)Construction phase7. 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 implementationIndividual 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 in very small quantities, which,

7.b - Each Contractor or owner (when self-construction) will be required to follow an ESMP for individual small construction, that may include the need to consult with Forest, Wildlife

The Contractor or the Beneficiary through his own building personnel (self, relatives and/or community

The Design and Supervision Firm, the E&S Specialists in the PIU (MoHL) with

As a minimum, every other week supervisions by the Design &


Included in Project Cost/ sub-component 2.2 – Design and Supervision


103

however, if unregulated may lead to environmental degradation.

and National Parks Division and follow specific measures for trimming or removal of individual trees only if necessary on site.

members). support from the IST within MoF, and if required, Forestry Division.

Supervision Firm

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 Design and Supervision Firm, the E&S Specialists in the PIU (MoHL) with support from the IST within MoF.



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

7.d - Each Contractor or owner (when self-construction) will be required to follow an ESMP for individual small construction, including requirements for use of small quantities of pest

The Contractor or the Beneficiary through his own building personnel (self, relatives and/or community

The Design and Supervision Firm, the E&S Specialists in the PIU (MoHL) with

As a minimum, every other week supervisions by the Design &


Included in Project Cost/ sub-component 2.2 – Design and Supervision


104

products (given the small size of the homes) to control termite in building foundations and 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.

control products authorized by the Dominica Pest Control Board, and in consultation with Forest, Wildlife and National Parks, Environmental Health Department and the PIU and to be done through licensed registered professional contractors.

members). support from the IST within MoF, and when required the Forestry Division and Environmental Health Department.

Supervision Firm

of House Reconstruction (US$ 2.05 million) and Component 3 (US$ 3 million) – 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 (when self-construction) will be required to follow an ESMP for individual small construction, 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


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.


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) –


105

National Parks Division and skeletal remains to the Dominica Police Force Central Investigation Department (CID).


7.f – Although most of the construction will likely be made by beneficiaries themselves, relatives, friend and community members, it may also involve pre-qualified building contractors in a small scale, thus potentially involving minimal labor influx, potentially resulting in conflicts with existing communities.

7.f - Each Contractor or owner (when self-construction) will be required to follow an ESMP for individual small construction, 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 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).


The Design and Supervision Firm, and the E&S Specialists in the PIU (MoHL) with support from the IST within MoF.


Project Progress Report on ESMP implementation,Construction Labor Agreement,Workers’ Code of Conduct


7.g – Inadequate consideration of environmental, social, health and safety (ESHS) aspects during construction,

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


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


106

such as air pollution, increased noise, potential traffic increase and increase of risk of traffic accidents involving community members, etc.

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 control measures such as, for example, enclosures and covers, increase of moisture contents of materials, install sewage systems for workers, etc.




Project Progress Report on ESMP implementation


7.h – Potential health and safety risks for workers during building activities, such as cave-ins during excavations, falls from

7.h – The ESMF includes a generic ESMP (in Annex 8) to address the potential HS of small construction activities, and the Design & Supervision Firm will review and supervise the use of adequate PPEs and implementation of standard operating procedures for key activities on small


The Design and Supervision Firm, and the E&S Specialists in the PIU (MoHL) with support from the IST within

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

Included in Project Cost/ sub-component 2.2 – Design and Supervision of House Reconstruction (US$ 2.05


107

heights, slip and trips, dismembering when working with electrical or mechanic equipment, etc.

construction, such as excavation, working on heights, scaffolding, etc

MoF. construction 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 construction activities, and the Design & Supervision Firm will 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 access roads, limiting hours for the delivery of building materials, etc.




Project Progress Report on ESMP implementation,Traffic PlanSite 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 Implementation and Administration; cost of implementing the ESMP must be included in


108

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

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

7k Proper disposal of construction waste through a waste management plan which will include and in accordance with the national regulations: Ensuring that there aredaily 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


The Design and Supervision Firm, The PIU Safeguards specialists


Project Progress Report on ESMP implementation,Waste Management Procedure, Site visit



109

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

restoration of the affected area to its original state to the satisfaction of the HRP PIU and/or delegated agencies and local communities.

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. (Procedures are included in the ESMP)




Project Progress Report on ESMP implementation,Site visit


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




Project Progress Report on ESMP implementation,Site visit



110

developed will include a checklist which should be monitored and evaluated periodically.

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 construction activities, and the Design & Supervision Firm will review and supervise the implementation of the procedures for Site Decommissioning, including decontamination of the site, when required.



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 VillagePersons met: Charles Williams, Chief

Jacqueline Corbette, ClerkJumadine 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, 2018Persons 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.