V3. Indigenous Peoples Plan Housing Recovery Project Original: October 2018 Revision 1: July 2019 Revision 2: November 2020 Revision 3: February 2021 0 Contents 1.0 BACKGROUND ........................................................................................................................................... 3 1.2 LEGAL AND INSTITUTIONAL FRAMEWORK APPLICABLE TO INDIGENOUS PEOPLE............................................. 4 1.2.1 THE KALINAGO TERRITORY ACT OF 1978 ...............................................................................................................4 1.2.2 THE INDIGENOUS AND TRIBAL PEOPLES CONVENTION – ILO CONVENTION 169 ............................................................5 1.2.3 THE UNITED NATIONS DECLARATION ON INDIGENOUS PEOPLES .................................................................................6 1.2.4 KEY REQUIREMENTS OF OP 4.10. ........................................................................................................................7 2.0 BASELINE DATA ......................................................................................................................................... 8 2.1 DEMOGRAPHIC CHARACTERISTICS ................................................................................................................................9 2.2 POLITICAL & CULTURAL CHARACTERISTICS .....................................................................................................................9 2.3 SOCIO-ECONOMIC CHARACTERISTICS...................................................................................................................10 3.0 SUMMARY OF THE SOCIAL ASSESSMENT................................................................................................. 11 4.0 FREE, PRIOR AND INFORMED CONSULTATION ........................................................................................ 12 4.1 PROCESS WHICH GUIDED FRAMEWORK......................................................................................................... 13 4.1.1 FOCUS GROUP DISCUSSION ...................................................................................................................................13 4.1.2 HIGH LEVEL DISCUSSION .......................................................................................................................................14 4.1.3 COMMUNITY CONSULTATION ................................................................................................................................14 5.0 ACTION PLAN OF MEASURES TO ENSURE CULTURALLY APPROPRIATE .................................................... 14 SOCIO- ECONOMIC BENEFITS ............................................................................................................................... 14 6.0 BENEFITS, CHALLENGES AND MITIGATION MEASURES FOR THE HOUSING RECOVERY PROJECT ............. 15 6.1 POTENTIAL BENEFITS ...............................................................................................................................................16 6.2 POTENTIAL CHALLENGES ..........................................................................................................................................16 6.3 PROPOSED MITIGATION MEASURES ...........................................................................................................................16 7.0 IMPLEMENTATION, MONITORING AND EVALUATION .................................................................................... 17 8.0 GRIEVANCE REDRESS ..................................................................................................................................... 17 9.0 FINANCIAL PLAN ............................................................................................................................................ 18 10.0 CONCLUSION ................................................................................................................................................ 18 ANNEX 1. THE HRP HOMEOWNER JOURNEY ........................................................................................................ 19 ANNEX 2. HRP RESTRUCTURE AND IMPLEMENTATION ADJUSTMENT ................................................................. 20 ANNEX 3. THE HRP OPERATIONS IN RELATION TO INDIGENOUS PEOPLES ........................................................... 21 ANNEX 4. HRP GRIEVANCE REDRESS MECHANISM ............................................................................................... 22 ANNEX 5. PRE-IMPLEMENTATION CONSULTATION RESULTS ............................................................................... 32 ANNEX 5.1 FOCUS GROUP DISCUSSION ..........................................................................................................................32 ANNEX 5.2 HIGH LEVEL DISCUSSION ..............................................................................................................................35 ANNEX 5.3 COMMUNITY CONSULTATION .......................................................................................................................36 1 ANNEX 6.0 MEETING WITH KALINAGO COUNCIL PRIOR TO IPP PUBLIC DISCLOSURE ........................................... 38 ANNEX 7.0 MEETING WITH NEW KALINAGO COUNCIL POST IPP PUBLIC DISCLOSURE ......................................... 39 ANNEX 8.0 FINAL BENEFICIARY DESIGN CONSULTATIONS.................................................................................... 40 ANNEX 8.3 VIRTUAL UPDATE OF REVISED IPP ...................................................................................................... 42 ANNEX 8.4 CURRENT DATA RELEVANT TO THE IPP .............................................................................................. 43 2 1.0 Background The Kalinago People of Dominica are identified as indigenous people present in the project area, therefore the OP/BP 4.10 is triggered under the Housing Recovery Project. The World Bank was the first multilateral development bank to introduce an Indigenous Peoples Policy. Its first policy on Indigenous Peoples (IPs) was adopted in 1982. This policy OP/BP 4.10 is applicable to all World Bank-financed projects where Indigenous Peoples, as defined under the policy, are present in the project area.. Within each Indigenous People’s Plan (IPP), the World Bank requires the borrower to engage in a process of free, prior and informed consultation resulting in broad community support to the project by Indigenous Peoples. This IPP provides insight into the social assessment, literature review and data collection from consultations with Kalinago people and other stakeholders during project preparation for the Dominica Housing Recovery Project. The details herein also comprise specific actions to be implemented and monitored during program implementation and are also integrated into the Project Operations Manual. The Dominica Housing Recovery Project (HRP), financed by The World Bank, aims to improve the resilience of the housing stock, encourage resilient building practices, and provide support to vulnerable households following the devasting impacts of Hurricane Maria of 2017 in Dominica. The project supports the Government of the Commonwealth of Dominica (GoCD)’s housing strategy and aims to build a process that could be used for reconstruction or replacement of damaged homes throughout the country with any source of funding. The project would address deficiencies in planning processes and impediments to the uptake of resilient building practices in the country. The Kalinago Council was informed that the process for the development of the Indigenous Peoples Plan under World Bank’s Social Safeguard Policy 4.101 for this Project is as follows: 1. Screening by the Bank to identify whether Indigenous Peoples are present in, or have collective attachment to, the project area; 2. A social assessment by the borrower; 3. A process of free, prior, and informed consultation with the affected Indigenous Peoples’ communities at each stage of the project, and particularly during project preparation, to fully identify their views and ascertain their broad community support for the project; 4. The preparation of an Indigenous Peoples Plan; 5. Disclosure of the draft Indigenous Peoples Plan. 1 https://ppfdocuments.azureedge.net/3905.pdf 3 1.2 Legal and Institutional Framework Applicable to Indigenous People This section contains information of the legal and institutional framework governing the Kalinago Territory and relevant to the Project. The Indigenous Peoples Plan was developed and will be implemented incorporating and in line with the requirements of World Bank OP 4.10 and considers social, cultural, demographical and political characteristics within the Kalinago Territory. 1.2.1 The Kalinago Territory Act of 1978 The Kalinago Reserve Act of 1978 (the Act) provides for the establishment of a body corporate for the administration of the Reserve and for matters connected herewith.2 The Act provides authority and responsibility to the Kalinago Council for the management of the Kalinago Territory. Prior to March 2015, the Kalinago Territory was referred to as the Carib Reserve; an amendment dated 12th March 2015 cited the change from Kalinago Reserve Act to Kalinago Territory Act. The Act describes the establishment of the office of the Kalinago Chief, the Constitution, and powers of the Kalinago Council. Specifically, it gives various powers to the Kalinago Chief and the Kalinago Council and outlines responsibilities of the Minister responsible for the Council. The Act further outlines the means of conducting elections for Council Members and the Chief and indicates how funds are to be used on behalf of the Territory and provide the Kalinago Council with powers to institute various bylaws pertinent to the management of the community. The Council is further organized into Hamlet Development Committees, governed by a constitution prepared by the Council. There are 8 hamlets in the Territory; however, there are seven (7) Hamlet Development Committees (since 2 hamlets were combined). The committees serve as branches to the Kalinago Council which lends to the effective management of the Territory. The Department of Kalinago Affairs was established in the year 2000 to address the needs of the local Kalinago people in the Kalinago Territory and by extension, Dominica. It was headed by a Parliamentary Secretary. In 2005, the Department was changed to the Ministry of Kalinago Affairs. Following the 2019, general election, this was changed to the Ministry of Environment, Rural Modernisation and Kalinago Upliftment. The mission of the Kalinago Upliftment Department in this Ministry is to work towards the improvement of the socio-economic condition, the preservation and promotion of the cultural heritage of the people of the Kalinago Territory and Atkinson, and to facilitate the vigorous promotion of the integration of Dominica's Indigenous People into the socio- economic life of the wider Dominican society. 2 Kalinago Act of 1978 http://www.dominica.gov.dm/laws/chapters/chap25-90.pdf 4 Goals of Kalinago Upliftment3: 1. To promote collaborations and coordination across Government Ministries on indigenous policy and programs. 2. To set priorities for and to track progress of Dominica's agenda. 3. To enhance government's awareness of the Kalinago people, issues and best practices for consulting and engaging with the Kalinago people. 4. To work with the government to find ways to make the most of public funding. 5. To increase Kalinago people's access to government programs, services and information. 6. To reform the land issue process to help address historical grievances. 7. To encourage diversity, especially representation of the Kalinago people in Dominica Public Service. 8. To develop International/Regional level relations. Based on the Kalinago Territory Act, which is described above, the Beneficiary Application process of the Housing Recovery Project will engage the Kalinago Council (Council) in verification of land occupancy and not ownership as compared to other applicants in Dominica. Land titles are kept by the Kalinago council and not individual residents of the Kalinago Territory; therefore, the Council will provide documentation that illustrates an applicant’s permission for land occupancy. Furthermore, successful applicants will have to sign Housing Agreements that includes a clause that gives consent for construction of the new home on safer grounds. That means, if the original house was situated in an area deemed hazardous, and the option for construction of the new house is in an area that is occupied by subsistence activities on the same plot of land, it must be documented that the home owner agrees to have the new house built there. The village of Atkinson does not form part of the Kalinago Territory however, it forms part of the political constituency, hence the reason for its inclusion under the Ministry of Environment, Rural Modernization and Kalinago Upliftment of which the Minister is also the Parliamentary Representative for the Constituency. In discussions with the Kalinago Housing Committee, the Honorable Minister expressed concern that the community of Atkinson of which it is assumed that the residents form part of the Kalinago Territory is usually overlooked. 1.2.2 The Indigenous and Tribal Peoples Convention – ILO Convention 169 The Indigenous and Tribal Peoples Convention – ILO Convention 169 of 1989 entered into force September 5, 1991. In summary, the ILO Convention 169 has been ratified by twenty-three (23) countries to date; the most recent being Luxembourg. Convention 169 recognizes the aspirations of indigenous peoples to exercise control over their own institutions, ways of life and economic development and to maintain and develop their 3 http://www.kalinagoaffairs.gov.dm/aboutus 5 identities, languages and religions, within the framework of the States in which they live; and acknowledging that in many parts of the world these peoples are unable to enjoy their fundamental human rights to the same degree as the rest of the population of the States within which they live, and that their laws, values, customs and perspectives have often been eroded. The Convention therefore, positions at the frontline, the distinctive contributions of indigenous and tribal peoples to the cultural diversity and social and ecological harmony of humankind and to international co-operation and understanding.4 In September 2007, the Government of the Commonwealth of Dominica ratified ILO 169, the Indigenous and Tribal Peoples Convention5 – and signed the UN Declaration on the Rights of Indigenous Peoples. The Declaration establishes a universal framework of minimum standards for the survival, dignity, well-being and rights of the world's indigenous peoples. The Declaration addresses both individual and collective rights; cultural rights and identity; rights to education, health, employment, language, and others. It outlaws discrimination against indigenous peoples and promotes their full and effective participation in all matters that concern them. It also ensures their right to remain distinct and to pursue their own priorities in economic, social and cultural development and explicitly encourages harmonious and cooperative relations between States and indigenous peoples. 1.2.3 The United Nations Declaration on Indigenous Peoples The United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) was adopted by the General Assembly on Thursday, 13 September 2007, by a majority of 144 states. Today, the Declaration is the most comprehensive international instrument on the rights of indigenous peoples. It establishes a universal framework of minimum standards for the survival, dignity and well-being of the indigenous peoples of the world and it elaborates on existing human rights standards and fundamental freedoms as they apply to the specific situation of indigenous peoples. Relevant to the development of the Indigenous Peoples Plan, Articles 26, 27 and 28 of the Declaration provides guidance as follows: 1. Indigenous peoples have the right to the lands, territories and resources which they have traditionally owned, occupied or otherwise used or acquired. 2. Indigenous peoples have the right to own, use, develop and control the lands, territories and resources that they possess by reason of traditional ownership or other traditional occupation or use, as well as those which they have otherwise acquired. 3. States shall give legal recognition and protection to these lands, territories and resources. Such recognition shall be conducted with due respect to the customs, traditions and land tenure systems of the indigenous peoples concerned. 4 http://www.humanrights.se/wp-content/uploads/2012/01/C169-Indigenous-and-Tribal-Peoples- Convention.pdf 5 http://www.ilo.org/dyn/normlex/en/f?p=1000:11200:0::NO:11200:P11200_COUNTRY_ID:103311 6 4. States shall establish and implement, in conjunction with indigenous peoples concerned, a fair, independent, impartial, open and transparent process, giving due recognition to indigenous peoples’ laws, traditions, customs and land tenure systems, to recognize and adjudicate the rights of indigenous peoples pertaining to their lands, territories and resources, including those which were traditionally owned or otherwise occupied or used. Indigenous peoples shall have the right to participate in this process. 5. Indigenous peoples have the right to redress, by means that can include restitution or, when this is not possible, just, fair and equitable compensation, for the lands, territories and resources which they have traditionally owned or otherwise occupied or used, and which have been confiscated, taken, occupied, used or damaged without their free, prior and informed consent. 1.2.4 Key requirements of OP 4.10. The WB’s Operational Policy 4.10 (Indigenous Peoples) requires that special planning measures be established to protect the interests of indigenous peoples with a social and cultural identity distinct from the dominant society that may make them vulnerable to being disadvantaged in the development process. The Policy defines that indigenous peoples can be identified in particular geographical areas by the presence in varying degrees of the following characteristics: 1. Self-identification as members of a distinct indigenous cultural group and recognition of this identity by others; 2. Collective attachment to geographically distinct habitats or ancestral territories in the project area and to the natural resources in these habitats and territories; 3. Customary cultural, economic, social, or political institutions that are separate from those of the dominant society and culture; and 4. An indigenous language, often different from the official language of the country or region. As a prerequisite for Project approval, OP 4.10 requires the borrower to conduct free, prior and informed consultations with potentially affected indigenous peoples and to establish a pattern of broad community support for the Project and its objectives. It is important to note that the OP 4.10 refers to social groups and communities, and not to individuals. The primary objectives of OP 4.10 are: 1. To ensure that such groups are afforded meaningful opportunities to participate in planning project activities that affects them; 2. To ensure that opportunities to provide such groups with culturally appropriate benefits are considered; and 3. To ensure that any project impacts that adversely affect them are avoided or otherwise minimized and mitigated. This project was screened for the presence of indigenous people and a social assessment was conducted- results of which are outlined in Section 2.0. Following 7 screening and social assessment, the process of Free, Prior and Informed Consent was undertaken by the Government of Dominica. These processes culminated in the development of the first HRP Indigenous Peoples Plan in 2018, supported by the DVRP’s Project Coordinating Unit. This was later revised by the HRP’s Social Safeguards Specialist in 2019, and later updated and revised in 2020 to suit project design changes and activities. 2.0 Baseline Data This section contains information on the demographic, social, cultural, and political characteristics of the Indigenous Peoples’ communities present in the Project area, the 8 land and territories that they have traditionally owned or customarily used or occupied, and the natural resources on which they depend. 2.1 Demographic Characteristics The Kalinago Territory is comprised of 3, 782.03 acres of land stretching over 9 miles on the East, Atlantic coast of Dominica in the Parish of St. David. The Territory is divided into 8 hamlets, namely: Sineku, Gaulette River, Mahaut River, St. Cyr, Salybia, Crayfish River, Battaca and Touna Concorde. As per the 2011 Population and Housing Census, the population of the Kalinago Territory documented 2,112 persons; 1,209 males and 948 females. The total population distributed by age and as a percentage of the total population is as follows: Age Group Population % of Total Population 0-4 201 9.5% 5-9 201 9.5% 10 - 14 200 9.4% 15 - 19 215 10.1% 20 - 24 166 7.8% 25 - 29 115 5.4% 30 - 34 119 5.6% 35 – 39 133 6.2% 40 – 44 146 6.9% 45 – 49 126 5.9% 50 – 54 123 5.8% 55 – 59 81 3.8% 60 + 283 13.3% Not Stated 3 0.1% Table 1: Kalinago Territory Population Distribution by Age group (2011) The data detailed above, indicates a growing ageing population in the Kalinago Territory, since the 60 and above grouping recorded the highest percentage (13.3%) of the overall population. On the contrary, the population distribution for age range 15 – 19 years recorded 10.1% of the total population; or second highest age range within the Kalinago population. In terms of households, the 2011 Population and Housing Census registered 652 households; an increase of 12% from the 2001 Census data, when 579 households were recorded. Interestingly, whereas the number of households increased between the two periods, the average household size decreased from 3.8 in 2001 to 3.2 in 2011. 2.2 Political & Cultural Characteristics As mandated in the Kalinago Reserve Act of 1978, the lands in the Territory is the property of the Kalinago Council and no individual can own land or land titles in his or her name. The Council is solely responsible for allocating land for all purposes including housing, 9 public conveniences, government projects and community projects. The Council is comprised of seven (7) persons – the person elected as Chief and six (6) other persons elected as members. In terms of other rights and privileges, the Indigenous Peoples are entitled to all rights like all Dominicans including voting, passports and political participation. The Kalinago culture has evolved due to development activities undertaken on the national level. Their traditional arts and crafts products: baskets, mats, hats, jewelry and hammocks are made from locally sourced raw materials including dried palms and reeds. 2.3 Socio-economic Characteristics In terms of the socio-economic status of the Indigenous People, the 2009 Country Poverty Assessment stated; “in respect of ethnic origin, indigenous persons were more likely than any other group in the population to be poor; 49.8 percent or one in two persons of indigenous origin are poor. This is a significant finding as the indigenous population represents about 5 percent of the total population of Dominica (approximately 2145 persons- 2011 census). However, there has been a reduction in measured poverty among the group, given that in 2003, some 70 percent were poor and half were indigent.�6 The issue of land ownership or lack thereof, (Kalinago Council has ownership of lands in the Territory) poses serious concerns for individual socio-economic advancement. This significantly limits their access to credit at local banks since they do not possess required collateral i.e. certificate of titles as per the laws governing the Territory. However, according to the Kalinago Chief, the AID Bank facilitates loan applicants from the Kalinago Territory wishing to use occupied land as collateral for agricultural business. As a means for further interventions to improve the lives of the Indigenous People, the Government of the Commonwealth of Dominica, through loan assistance from the Caribbean Development Bank constructed the Kalinago Barana Aute (KBA)- which means “Kalinago Cultural Village by the sea�. The Village offers tours including cultural dances and site visits. In the shops, local creations are centered on larouma, calabash, pottery and coconut products, from which wood carvings, baskets and other artistic creations are created. 7 Other historic sites and/or tourist attractions within the Kalinago Territory includes L’escalier Tete Chien which is located in Sineku, Centipede Trail in St Cyr and the Horseback Ridge Trail located in Salybia. The issue of unemployment among the Kalinago People continues to escalate, particularly among the young persons. For instance, the unemployment rate for the 15 – 19 age group is at an alarming 55.0%, with the 20 – 24 age group at 26.7% and the 25 – 29 grouping at 20.2%. These aforementioned figures are the three highest among the population and suggest that specific interventions will be needed to gainfully engage persons within their productive years. 6 Dominica Country Poverty Assessment, Main Report, 2009 7 http://www.kalinagobaranaaute.com/features/crafts/ 10 The passage of Hurricane Maria offset further social and economic impacts on an already vulnerable population. The 2011 Population and Housing Census also registered an unemployment rate of 14.4 which indicates a 68% increase from 2001; and an increased labour force between 2001 and 2011, which recorded 890 and 953 persons respectively; an increase of 6.8%. 3.0 Summary of the Social Assessment A gender analysis of the data from the Population and Housing Census 2011 confirms that unemployment rate among males stands at 15.2% compared to 12.5% among Kalinago women. Interestingly, males dominate the total labour force in the Territory, registering 665 in 2011 vs 288 females; a 79% difference (Population and Housing Census 2011). 11 According to discussions with members of the Kalinago Council, it is agreed that the following are evident in the Kalinago Territory: 1. a strained agricultural sector due to periodic natural disasters and decrease in export demand for certain crops 2. low availability of raw materials over time hindered the local product manufacturing industry and caused a reduction in income from sales (eg. Larouma for craft and cassava for bread) and 3. low visibility of the seasonal tourism potential in the Territory. These existing circumstances were further exacerbated by Hurricane Maria; since farming plots were destroyed and local raw materials needed for basket weaving became scarce. In addition, the Kalinago Village (Barana Aute) was also impacted and required repairs prior to recommencement of business activities. Another income earner is the sale of cassava bread to visitors and distribution in other communities. Unfortunately, the production buildings were also severely impacted; adding to the ongoing economic plight. Following the passage of Hurricane Maria in September 2017, the housing stock in the Kalinago Territory was severely impacted. Initial investigations suggest that at least 885 homes were impacted by the hurricane, emphasizing the urgency to recover the housing stock to improve the quality of life for the Kalinago people. The data presented below analyzes the levels of damages to the housing stock in the Kalinago Territory post Hurricane Maria. Figure 1: Analysis of Damages to Housing Stock, Kalinago Territory, UNDP 4.0 Free, Prior and Informed Consultation This section contains the results of the free, prior, and informed consultation with the affected Indigenous Peoples’ communities that led to broad community support for the project. 12 One of the key project stakeholders for the Housing Recovery Project are the residents of the Kalinago Territory; particularly those whose homes were destroyed by Hurricane Maria. The process which guided the consultations for the development of the Indigenous Peoples Plan included the provision of overall guidance by Kalinago Territory Housing Committee comprising of representatives from the Ministry of Environment, Rural Modernization and Kalinago Upliftment, the Kalinago Council and the Ministry of Housing and Urban Development. It was agreed that all consultations at each stage of project preparation and implementation will be executed through the Ministry of Environment, Rural Modernization and Kalinago Upliftment and the Kalinago Council as representatives of the Kalinago people. The consultation process for the development of the Indigenous Peoples Plan (IPP) under the Housing Recovery Project included one focus group discussion, one (1) discussion with Kalinago Council and the Ministry of Environment, Rural Modernization and Kalinago Upliftment, and two (2) public consultations to support the spirit of free, prior and informed discussion at each level of the project life cycle. The focus group discussion significantly influenced the preparation of the Project Appraisal Document (PAD); whereas, the first public consultation provided the foundation for the preparation of the first draft IPP and the final consultation provided the opportunity for consensus and approval. 4.1 Process which Guided Framework Discussion (Kalinago Council & Ministry of Focus Group Environment, Rural Discussion Modernisation and Kalinago Upliftment Public Consultation 2 Public Consultation 1 (Provided opportunity (Influenced for consensus & preparation of project approval) appraisal document) Development of Indigenous People Plan 4.1.1 Focus group Discussion On February 6, 2018, representatives from the former 8Ministry of Environment, Climate Resilience, Disaster Management and Urban Renewal and World Bank met with officials from the former Ministry of Kalinago Affairs and the Kalinago Council to discuss the 8 They are both now merged into the Ministry of Environment, Rural Modernization and Kalinago Upliftment 13 Housing Recovery Project and its potential impacts on the Indigenous Peoples. The main objectives of the focus group discussions were to understand from the Kalinago People, their living condition experiences pre and post Hurricane Maria and to determine the most suitable strategy for project preparation and subsequent implementation. The participants were predominantly male representing 63%; whereas females accounted for 37%. In terms of participation by age, more middle-aged persons were represented which can be attributed to the fact that they are head of households and are ultimately responsible for re-construction of homes. The results of this discussion can be found in Annex 5.1. 4.1.2 High Level Discussion On May 24, 2018, a meeting was held at the St Cyr Resource Centre. The main purpose of the meeting was to introduce the Housing Recovery Project to the Kalinago Council and the Ministry of Environment, Rural Modernization and Kalinago Upliftment and to introduce the process involved in the development of the Indigenous Peoples Plan. At this meeting, the Indigenous Peoples were represented at the highest levels of governance with both the Minister of Kalinago Affairs and the Kalinago Council Chief forming an integral part of the team. The representatives from the Ministry of Environment, Climate Resilience, Disaster Management and Urban Renewal and the World Bank presented an overview of the Housing Recovery Project to the Committee can be found in Annex 5.2. 4.1.3 Community Consultation The first public consultation was held on June 11, 2018 in the Kalinago Territory. The Kalinago Council provided support in contacting participants and confirming logistical arrangements. A total of fourteen (14) persons participated in this initial consultation; six (6) males and eight (8) females as seen in Annex 5.3. In order to encourage knowledge sharing, the fourteen participants were divided into two (2) groups to discuss potential benefits, challenges and solutions. 5.0 Action Plan of Measures to Ensure Culturally Appropriate Socio- Economic Benefits Considering the sensitivity of the project combined with the exhaustive housing needs of the Kalinago People, clear and detailed measures are outlined herewith to support distribution of social and economic benefits of the Kalinago People. A few notable activities that include the Kalinago People include: 14 ACTION RESPONSIBILITY STAGE PROJECTED TIMEFRAME Define Eligibility Criteria to Project Pre-Project February to complement existing laws in the Implementation Implementation March 2019 Kalinago Territory Unit, Kalinago Council Select beneficiaries through MIS Project Project September 2019 and in collaboration with Implementation Implementation to Validation Committee Unit, January 2020 Kalinago Council Conduct continuous community Project Pre- Project February 2018 to consultation to ensure informed Implementation Implementation April 2019 consent Unit and During Implementation Conduct consultation on the Project During April 2019 Housing Recovery Project’s Implementation Implementation onwards eligibility criteria, selection Unit processes, Grievance Redress Mechanism and other procedures. Conduct consultations with the Project During April 2019 Kalinago and other stakeholders Implementation Implementation onwards on the IPP and revise as Unit necessary 6.0 Benefits, Challenges and Mitigation Measures for the Housing Recovery Project When potential adverse effects on Indigenous Peoples are identified, an appropriate action plan of measures to avoid, minimize, mitigate, or compensate for these adverse effects. During discussions at community levels, the participants were broken up into groups and prompted to brainstorm on potential benefits, negative impacts and mitigation measures of the project on the Kalinago Territory. A summary of information collected is provided below: 15 6.1 Potential Benefits 6.2 Potential Challenges • Improved Housing Structure; • Likelihood of another natural disaster; • Improved Livelihoods of the beneficiaries; • Change in national and local government; • Opportunities for local contractor • Beneficiary selection process maybe slow; certification; • Availability of Suitable Land; • Economic benefits and employment; • Reimbursement to persons who have • Inclusiveness (home-owner driven); undertaken repairs prior to project • Strengthen family units with improved implementation; environments; • Bureaucracy of Processes under the • Opportunities for skills development Project; (plumbing, electricals, construction); • Availability of qualified contractors; • Better standard of living for Kalinago • Size of future homes compared to number Peoples. of persons in the household • Expansion of starter homes may be difficult due to socio-economic conditions in the Kalinago Territory; • Re-location/Re-assignment of Lots. In summary, both groups identified similar impacts (both positive and negative) of the Housing Recovery Project. The areas identified reflect the sentiments of the participants and the number of participants (14) aided in controlled and honest discussion. Caution is advised against raising expectations of this project especially when one considers the demand for housing within the Territory. The Kalinago Council has appointed one member with the sole responsibility for housing in the territory. This member has the capacity and skills to participate in formal assessments and advise on designs and indigenous knowledge of the cultural heritage, lands and construction in the territory. Support for resilient design and construction has been echoed throughout consultation by potential beneficiaries. 6.3 Proposed Mitigation Measures • Employ construction supervisor to ensure adherence to standards • Train local contractors and laborers • Undertake periodic inventory of materials on site • House designs should pattern ‘green homes’ concept with at least one (1) solar unit per home as well as water tanks (introduce rainwater harvesting) • Undertake intense awareness program for Housing Recovery Project • Review of land use policy within the Kalinago Territory The mitigation measures suggested above indicate a well-thought out process by the participants. The areas identified outline the path towards long-term sustainable 16 development within the Kalinago Territory. There is need to provide technical support to review the existing land policy within the Territory, with a view for greater empowerment of the younger generation. Coupled with this support, is capacity building for members of the Kalinago Council who will be responsible to effectively govern the Territory. Tremendous economic potential exists within the Territory for economic activity given the rich preserved cultural heritage and unique art and craft industry, and retention of ethnic identity. 7.0 Implementation, Monitoring and Evaluation The mechanisms and benchmarks appropriate to the project for monitoring, evaluating, and reporting on the implementation of the IPP should include arrangement for the free, prior, and informed consultation with the affected Indigenous Peoples’ communities. The overall monitoring of the Indigenous Peoples Plan shall be that of the Project Implementing Unit. Within the Project Implementation Unit, the Social Safeguards Specialist shall be specifically responsible to monitor implementation of the IPP. The PIU shall include at the grant application, beneficiary selection and validation stages in the project implementation, the Kalinago Council and the Ministry of Environment, Rural Modernization and Kalinago Upliftment. The PIU’s Social Safeguards Specialist with the support of the Communications, Monitoring and Evaluation Specialist shall undertake periodic community consultations when necessary along with counterparts from the other WB projects to inform stakeholders on the status of implementation of the IPP and elements of the HRP. Consultations should include workshops, which started in July, 2019, on the HRP’s Environmental and Social Management Framework Prior to the application process, and meetings will be held with the validation committee on the eligibility criteria and project objectives. This committee will be comprised of members from different sectors in the community (not excluding members of the Kalinago Council) and will be engaged in the beneficiary vulnerability verification process. Consultations for skilled tradesmen, apprentices and contractors will be held according to the project’s implementation activities. 8.0 Grievance Redress The PIU has developed its Grievance Redress Mechanism (GRM) for this project, which is detailed and illustrated in Annex 4. The GRM outlined in Annex 4 is also available to receive any complaints from the Kalinago in relation to Project implementation. For potential grievances involving the Kalinago and the need to incorporate their traditional grievance management processes identified; it will be necessary for the PIU to engage various representatives from the Kalinago, to have the capacities necessary to facilitate timely resolution of grievances filed. 17 9.0 Financial Plan The table below presents a summary of costs associated to implementation of the IPP: ACTIVITY DESCRIPTION UNIT TOTAL COST Full Day Consultation on Prior to Application: 1 $2500 $7500.00 HRP Elements At confirmation of final beneficiary group: 2 Workshops for At registration of group of $2500 $5000.00 Contractors/Construction contractors: 2 workers Table 2. Projected activities that may incur financial costs 9 10.0 Conclusion The devastation caused by Hurricane Maria was especially evident within the Kalinago Territory. This is particularly manifested in the stories of daily struggles for basic services such as water, electricity and telecommunications. Even more alarming is the psycho- social impacts on the most vulnerable such as the elderly, children, single headed households, persons living with disabilities and the unemployed within the Territory. Resilient reconstruction of homes has been one of the greatest challenges given the limited economic activities as a result of the impacts of Hurricane Maria. From the initial discussions held, the support of the Kalinago People towards the implementation of the Housing Recovery Project is resolute. Their concern is focused on timeframe for actual implementation and the need for considerations for recovery costs 9 The support of the Communications, Monitoring and Evaluation Specialist is integral in implementing the planned awareness activities in accordance with this IPP as well as the Communications Strategy. From May 2019 to August 2019, the specialist was unavailable. Pre- application awareness campaigns were significantly affected and as the application period opened in September 2019, the project utilized the radio media to communicate and raise awareness on the national level. Consultations were also hindered by COVID-19 national lockdown between March and June 2020. 18 for those whose homes were completely destroyed and required immediate shelter. This document was circulated on October 11th, 2018 to the Kalinago People through the APPLICATION & assistance of the Ministry of Environment, Rural SELECTION Modernization and Kalinago Upliftment and the Kalinago Council respectively and is publicly available in the Project website. Applications were opened to all residents and citizens of Dominica residing in the small destroyed homes prior to and during Hurricane Maria. Social Mobilisers were stationed in various communities and homeowners voluntarily applied to the project via the Management Information Systems’ Survey App used by the social mobilizers. Eligible applications would move on to three stages of verification and validation. This included site survey review, validation committee review and land documentation review. For applicants from the Kalinago Territory, land documentation review involved verification and ANNEX 1. The HRP Homeowner Journey authorization from the Kalinago Council. As the Housing Recovery Project began implementation, Ultimately, the applicant or activities involved the development of the Management Kalinago Council would submit Information System (MIS) and associated processes and Authorization Letters of the eligible applicant, and he/she procedures in conjunction with a technical firm. The would be considered for the final contracting of the design & supervision firm was especially beneficiary list. important for achieving specific project goals and outcomes that would also reflect the proposed solutions to challenges highlighted during consultations with the Kalinago people. 19 ANNEX 2. HRP Restructure and Implementation Adjustment In October 2019, the Government of the Commonwealth of Dominica requested a review of the project that would address key findings and considerations for effective delivery consistent with the overall development objectives of the project and dovetails responses undertaken by the Government in its NHRRP (National Housing Repair and Reconstruction Program). 10 Henceforth, the following restructure to the HRP design was approved between the GoCD and the World Bank: 1. Home Design: Use of government pre-approved designs for resilient housing consisting of two-bedroom units with a size of 540 square feet. Additional design options will be prepared under the Design and Supervision consultancy, thereby providing beneficiaries with design options. 2. Grant Allocation: Increase the grant amount up to XCD 125,000 (USD 46,250) per beneficiary based on the estimated cost of the two-bedroom unit described above. 10 The Housing Recovery Project Revised Project Operations Manual 20 3. Alternative Site: Allow homeowners to construct their new resilient standalone home at a different vacant location in cases where the existing site is unavailable, inaccessible, and/or unsuitable. The alternative site will be required to be in the same community, meaning the same village in which the homeowner resided, and the site was located at the time of Hurricane Maria when the building was destroyed. 4. Target Beneficiaries: Reduce the number of target beneficiaries from 1,700 to 676 potential beneficiaries. This reduction is due to the increase in the amount of grant per beneficiary from XCD 50,000 up to ECD 125,000. 5. Eligibility Criteria: Adjust the criteria to allow homeowner access to the grant where prior support received does not exceed XCD10,000 and has not changed substantially post Hurricane Maria house condition in regard to meeting the resilient criteria. ANNEX 3. The HRP Operations in Relation to Indigenous Peoples The Social Safeguards Specialist will lead activities that relate to indigenous peoples on the project according to the HRP Indigenous Peoples Plan (IPP). Communications, Monitoring and Evaluation will be critical to support the implementation of the IPP and related activities throughout the project duration. The following parameters must be applied: 11 1. The IPP updated version must be publicly disclosed on Government and the World Bank websites. 2. Project reports will include the results framework outputs on indigenous peoples. 3. The project criteria for the housing grant is applicable to all residents of Dominica inclusive of all indigenous peoples throughout the island including the Kalinago Territory. 4. Land ownership for the Kalinago Territory will fall under the management of the Kalinago Council in accordance with their guidelines, which is accepted by the Physical Planning Department (PPD) PPD. 11 The Housing Recovery Project Revised Project Operations Manual 21 5. Regular consultations will be held with the Kalinago Chief and the Kalinago Council on all project matters pertaining to the Kalinago people to ensure they are informed about the project and its potential impacts and how they can support and participate. 6. A validation committee will be established within the Kalinago Territory, and the Kalinago Council would be responsible for nominating suitable candidates for this committee. 7. If and when necessary, the Kalinago Council would be responsible for grievance redress that are specific to Kalinago Territory applicants, as they have appointed council members to manage different sectors in their governance system. The established Grievance Redress Mechanism (GRM) for the Project will be applied as a function of resolving issues pertaining to the HRP. 8. An information and communications strategy and outreach plan will be developed to ensure that residents of the Kalinago Territory are aware of the project, the selection criteria, the GRM in place for the project, and 9. Consultations will be held to engage the Kalinago people through appropriate mediums to ensure their free, prior informed consent and that their customs, choices and preferences are communicated and considered during decision- making. ANNEX 4. HRP Grievance Redress Mechanism The Grievance Redress Mechanism (GRM) applies to all stakeholders of the HRP’s operations during project implementation, including during selection of beneficiaries, reconstruction and monitoring activities. For grievances filed in the MIS, there will be an acknowledgement within 2 working days to the complainant from the Social Safeguards Specialist or any available member of the PIU. Within that period, it is recorded and screened and a response created. An investigation is carried out starting from the date the grievance is officially received by the PIU. For Level 1 cases, investigations may take 5 to 10 working days. Level 2 cases may take 10 to 15 working days for an investigation to be carried out and completed, while level 3 cases may take 15 to 20 working days. Once investigations are be carried out and completed, an action plan has to be developed, and a response prepared. The Social Safeguards Specialist shall screen the grievance to determine the level of the complaint (level 1, level 2, level 3) and assign to the appropriate PIU member who will become the grievance owner. The GRM is managed by the project’s Social Safeguards 22 Specialist with support from the relevant team members including: Environment Specialist, Procurement Specialist, Financial Specialist, Implementation Support Team (IST) Safeguards Advisor and Project Implementation Unit (PIU) Project Manager. In particular, for grievances classified as level 2 and 3 cases, the Grievance Owner will direct the matter to the Project Manager who will work with the support of the IST. The Project Manager and IST Safeguards Advisor will meet to work through the outstanding and difficult Level 3 grievances and decide jointly on the actions required and communications to the complainant. If they 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 Urban Development. If the complainant is not satisfied with the resolution, he/she may write an appeal to the grievance owner and a grievance redress committee meeting will be initiated with members who were nominated from the following categories: • HRP Project Manager (non-voting member) • Religious leader • Finance executive (private sector) • Senior public officer (retired) • Academic professional • Business professional (private sector) • Construction/Environmental professional (academic/private sector) 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. Grievances that require verification from a village council, likewise the Kalinago Council specifically are as follows: - Home ownership verification - Previous housing assistance - Present housing assistance - Land ownership/ authorization These are the only situations that will require consultation with the Kalinago Council in resolving a grievance as all grievances are treated individually and all applicants, including Kalinago people are considered private citizens. Grievances or complaints which affect the Kalinago people as an indigenous group or Kalinago communities will require consultation with the Kalinago Council in order to resolve. INTRODUCTION The purpose of this document, the Grievance Redress Mechanism (GRM), is to formalise the management of grievances, complaints, inquiries, concerns, grievances and feedback of stakeholders to strengthen relationships and minimize the social risks to the 23 Housing Recovery Project (HRP). The GRM provides an avenue for stakeholders to voice their concerns and gives transparency on how grievances will be managed internally, which aims to reduce conflict and strengthen relationships between stakeholders, the Project Implementation Unit (PIU) and Project partners. The following table provides definitions of key terms used throughout the grievance process. Grievance Mechanism Definitions • Grievance: An issue, concern, problem, or claim (perceived or actual) that an individual or community group brings to the attention of the Project. • Grievance Mechanism: A tool to accept, assess, and resolve individual or community complaints concerning the performance or activities of the Project, its contracted entities or employees. This includes Project-related adverse economic, environmental and social impacts. • Grievance Owner: A member of the PIU who is assigned to coordinate, investigate and develop an action plan for a particular grievance logged. • Stakeholders: Individuals (including beneficiaries) or community groups who are not directly responsible for the Project implementation but are interested parties that can influence the activities of the project through their feedback. This includes neighbours, NGOs, the government, political groups, local councils, and the surrounding communities. • Grievance Recipient: Staff member of the PIU, particularly the Administrative Assistant, Office Assistant or Social Safeguards Specialist who receive grievances via email, telephone, online Grievance and Complaints Logging System or in person. SCOPE OF THE GRIEVANCE REDRESS MECHANISM The Grievance Redress Mechanism (GRM) is available to all Project stakeholders, and will be maintained throughout project implementation, including during selection of beneficiaries, reconstruction and monitoring activities. For grievances filed in the MIS, there will be an acknowledgement to the complainant from the Social Safeguards Specialist or any available member of the PIU within 2 working days. Within that period, it is recorded, screened and a response created by the Social Safeguards Specialist. An investigation is carried out starting from the date the grievance is officially acknowledged and assigned. For Level 1 cases, investigations may take 5 to 10 working days. Level 2 cases may take 10 to 15 working days for an investigation to be carried out and completed, while level 3 cases may take 15 to 20 working days. The complainant shall be informed of the process outcome timeframe by the Grievance Owner or Grievance Recipient (PIU staff). The Grievance Owner, with the support of the Project Manager and IST Safeguards Advisor will meet to work through the outstanding and difficult Level 2 grievances and 24 decide jointly on the actions required and communications to the complainant. The Project Manager will meet with the IST Safeguards Advisor to resolve difficult Level 3 grievances, and if they 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 Urban Development. If the complainant is not satisfied with the resolution, he/she may write an appeal to the grievance owner and a grievance redress committee meeting will be initiated with members who were nominated from the following categories: • HRP Project Manager (non-voting member) • Religious leader • Finance executive (private sector) • Senior public officer (retired) • Academic professional • Business professional (private sector) • Construction/Environmental professional (academic/private sector) 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 first version of the Grievance Redress Mechanism (GRM) 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). Categories of Complaints The following general categories of complaints/grievances will be considered to be within the scope of the project’s GRM: • Communications – information or consultation related issues. • Project and process – any grievance related to the project description, process (e.g. eligibility) design or scope of the project. • Project performance – a grievance related to the project performance, failure to implement as promised or commitments of the project. • Legal – grievance accusing the project or personnel of breaking the law or government regulations. • Health safety, indigenous peoples, land, gender-based violence or environment or community issues (HSEC) – complaints related to any of the environmental and social safeguard standards of the World Bank applicable to the Project. • Personnel – related to the behavior of PIU staff and contractors. THE GRIEVANCE MECHANISM PROCESS 25 Receive Grievance The Management Information System (MIS) will provide public access to lodge grievances during the project implementation period. The system will not facilitate complaints submission unless all required fields are entered. The Administrative Assistant or the Social Safeguards Specialist receive all grievances that are lodged via email, or online through the MIS, or other methods (such as phone or in person verbal complaints) and ensures that the relevant information is provided in order to record, assess and respond to the grievance. Anonymous complaints will be accepted. Record The recipient will record the grievance using the Grievance and Complaints Logging System (GCLS). Screen The Social Safeguard Specialist will screen the grievance, and define or redefine its level and category depending on the information received. See below Table 2 categorizing the different levels. Grievance Category Level Description Internal response Specialist/Support When an answer can Respond immediately to be provided complainant. Record immediately and/or and report as part of Housing Recovery overall reporting Relevant PIU Level 1 Project PIU team are process. Does not Specialists already working on a require internal resolution. consultation One off grievance that Needs input from requires considered Project Manager, IST Supervisor level Level 2 response and and other internal team Support actions/commitments members and to resolve complaint. specialists. 26 Repeated, and Needs input from extensive grievances CREAD and relevant that may jeopardize Ministry’s Permanent Executive level Level 3 the reputation of the Secretary (if necessary) Support Housing Recovery Project. Acknowledge A grievance will be acknowledged, by the recipient, within two (2) working days of a grievance being submitted and screened. Communication will be made with the complainant either verbally or in written form (stakeholders will outline their preferred method of contact on form). The acknowledgement of a grievance should include a summary of the grievance, method that will be taken to resolve the grievance and an estimated timeframe in which the grievance will be resolved. If required, the acknowledgment provides an opportunity to ask for any additional information or to clarify any issues. Assign Once acknowledged, the Social Safeguards Specialist will assign the grievance to the relevant PIU staff to investigate. If an anonymous complaint is received, and there is no way to acknowledge, the complaint will be assigned to the relevant grievance owner who will investigate and continue the process. Investigate The Grievance Owner is responsible for investigating the grievance within the specified timeframe for the grievance level. The investigation may require the Grievance Owner to recommend site visits, consult employees, contact stakeholders and complete other activities. Meetings, discussions and activities all need to be recorded and documented during the investigation. Information gathered during the investigation will be analyzed and will assist in determining how the grievance is handled and what steps need to be taken to resolve the grievance. Actions and Commitments Following the investigation, the Grievance Owner will use the findings to create an action plan outlining steps to be taken to resolve the grievance. He or she is responsible for assigning actions, monitoring actions undertaken and making sure deadlines are adhered to. Once all actions have been completed and he or she feels that the grievance has been resolved, he or she will then formally advise the stakeholder via the preferred method of contact. Follow up and Close Out The Social Safeguards Specialist or Administrative Assistant will contact the stakeholder/s once the grievance is resolved and a response is prepared. When contacting the stakeholder, he or she will verify that the outcome was satisfactory and also gather any feedback on the grievance process. This will be recorded and saved in the GCLS in the MIS. 27 If required, the Social Safeguards Specialist may need to follow up with the stakeholder on numerous occasions to confirm all parties are satisfied. Escalation If the stakeholder is not satisfied with the resolution and/or does not agree with the proposed actions, then the Grievance Owner needs to escalate the matter to the Project Manager upon being informed by the Social Safeguards Specialist. The Project Manager may seek advice from other independent parties which can include the Permanent Secretary of the relevant Ministry and/or CREAD. The Project Manager, will review all documentation gathered throughout the grievance investigation with the independent party/parties to provide information required to resolve the grievance. Appeal If still unsatisfied, the complainant may submit a written appeal to the Grievance Owner. Within five (5) working days of the receipt of the appeal, the Project Manager shall call for the activation of the Grievance Redress Committee to hear the grievance and render a recommendation. The committee shall provide opportunities for the complainant to make oral and/or written presentations. The committee’s deliberation will not be conducted under strict rules of legal evidence and therefore the committee’s disposition of the g rievance will take the form of findings of fact and conclusions. A course of action shall be recommended to Project Manager within 10 working days after completion of the hearing. Within 10 working days after the recommendation of the grievance redress committee, the Grievance Owner shall notify the complainant of the decision. The decision shall include a statement of the findings and conclusions supporting the decision, and shall be final. This process is not intended to replace the national or formal legal channels such as the court system, and the complainant has the option to use alternative legal remedies if he or she remains unsatisfied. Reporting The Project Management Team will receive quarterly updates on overall stakeholder grievances from the HRP PIU. Information outlining the number of grievances, time to resolution and outcomes of grievances will be communicated. All consulting firms contracted with the project will report according to their TOR. Records All records, including grievance forms, investigation notes, interviews and minutes of meetings will be securely filed in a password protected, project grievance filing system (GCLS in MIS) and the HRP’s intranet to ensure privacy and confidentiality is maintained for all parties involved. All names or contact details of complainants will be held confidential and will not be released to an external party without the complainant’s written permission. GRIEVANCE REPORTING CHANNELS 28 The PIU will communicate this procedure to its external and internal stakeholders to raise awareness and offer transparency of how stakeholders can voice their grievances. Various channels for stakeholders to vocalize their grievances formally include: HRP Online form: Stakeholders can complete an online grievance form located on the HRP website: www.hrp.gov.dm. This is the main form of communication for which complaints will be addressed through the Management Information System (MIS). Email: The complainant may send an email to the Administrative Assistant at adminassistanthrp@dominica.gov.dm. Telephone: Complainants can call the HRP’s PIU at (767) 616-9766. If it is an inquiry that can be addressed immediately, the administrative assistant can attend to the inquiry over the phone, if there are intricate details, he or she may lodge the grievance into the MIS or direct the call to the Social Safeguards Specialist. In person: Stakeholders can visit the HRP Office on 40 Old Street, Roseau to lodge an official complaint or make an inquiry. In person complaints can also be received by PIU staff and consultants when they are in the field. Design & Supervision Staff: The contracted firms and their employers should be trained and briefed on this grievance procedure. If they receive grievances from a community member they should process them through their existing community grievance procedure and record them adequately or pass on the grievance to the Social Safeguards Specialist for screening and assigning. Grievances that are received by the design and supervision staff should be documented with sufficient detail and reported back to the PIU so that they can be included in the log managed by the PIU for inclusion in Project reports. PERSONNEL ROLES AND RESPONSIBILITIES Role/ Position Title Responsibility • Investigate the grievance and liaising with the Grievance Owner stakeholder/s. • Develop resolutions and actions to rectify any issues. • Document any interactions with stakeholders. Social Safeguards • Manages the Grievance and Complaints Logging Specialist System in the MIS and monitor any correspondence. • Assign a grievance owner • Ensure the grievance mechanism procedure is being adhered to and followed correctly. • Follow up and track progress of grievances. 29 Role/ Position Title Responsibility • Project Manager • Provide information and assistance in developing a • Implementation Support response and close out of a level 2 grievance. Team (IST) Safeguards • Develop resolutions and actions to rectify any issues of Advisor level 3 grievances. • Communications, Raise awareness of the grievance mechanism among Monitoring & Evaluation contracted firms and relevant stakeholders Specialist • Design & Supervision • Report grievance to the Social Safeguard Firm Specialist/Environmental Specialist Contractors • Lodge the Grievance or Complaint in the Grievance & Complaints Logging System (GCLS) • Explain the mechanism to their employees and ensuring they all understand how to receive, and address adequately grievances and report grievances with sufficient detail • Grievance Redress • Determine action plan and steer resolution process to Committee provide recommendations for grievances that are appealed by complainant. Figure 1 below describes and illustrates the steps that will be taken to resolve grievances. 30 The updated version of the Grievance Redress Mechanism (GRM) is included in the updated PIU Operations Manual and the Environmental and Social Management Framework (ESMF) with the objective to formalize the management of grievances at the PIU level, to address any grievances on the environmental, health, safety and social risks to the Project. The following process chart details the steps which shall be taken to address grievances filed: Figure 2. Grievance Mechanism Descriptive Flowchart INVESTIGATE The investigation is ESCALATION & carried out within APPEAL 5-10 working days FOLLOW UP If not satisfied, the by grievance & matter will be owner. escalated to the SCREEN Level 2 cases will CLOSE OUT project manager take 10 to 15 ACTIONS & who will review RECORD Screening is done ACKNOWLEDGE working days and COMMITMENTS The Social RECEIVE to determine the and decide on Grivance is logged The grievance is will be managed by An action plan is Safeguards seeking advice Complaint received grievance category Specialist or the by the PIU achkowledged the Project developed and from the IST or through different and to direct Administrative in MIS and gets a investigation. within 2 working Manager and IST. communicated to independent channels captured Assistant will parties. unique identifier days of being Level 3 cases will complainant once or the MIS. Grievance owner is contact the code. submitted. take 15 to 20 all actions are The complainant identified and completed. complainant once assigned. working days. the grievance is must file a written Any meeting will resolved to verify appeal to the that the outcome Grievance Owner, be minuted and was satisfied. who will submit to relayed back to the the Grievance grievance owner Redress who records in the Committee. system. 31 ANNEX 5. Pre-Implementation Consultation Results ANNEX 5.1 Focus Group Discussion The participants were predominantly male representing 63%; whereas females accounted for 37%. In terms of participation by age, more middle-aged persons were represented which can be attributed to the fact that they are head of households and are ultimately responsible for re-construction of homes. The table below provides data on participants by age and sex: Age Groups Participation Male Female Total 15-19 0 1 1 20-24 0 0 0 25-29 1 2 3 30-34 0 2 2 35-39 0 0 0 40-44 1 0 1 45-49 1 0 1 50-54 0 0 0 55-59 4 0 4 60+ 3 1 4 TOTAL 10 6 16 Table 3: Analysis of Participants – Focus Group Discussion Participatory Assessment Housing Damages An analysis of the data collected from the focus group discussions concluded that out of the 16 participants, six (6) respondents reported complete destruction of their homes, four respondents (4) stated that their homes were partially destroyed and six (6) stated that their roofs were completely destroyed. The experiences of the Kalinago Peoples with regards to living conditions and the impact of Hurricane Maria are detailed below: Question #1: What were your housing conditions at the time of the hurricane? What impact did Hurricane Maria have on your house? Describe the number of persons living in the home. i. “We had a family of 8 at the time hurricane strike…house damaged, concrete and lumber structure…I am 58 years old.� ii. “We had a wooden structure, our home was completely destroyed; 7-member household (2 adults, 5 children) my entire family presently in shelter, children in school.� iii. “There are five (5) members in my family. The house was com pletely destroyed, concrete structure; I have built temporary shelter for family.� Repairs to Housing Structure 32 When asked about the status of repairs post Hurricane Maria majority of the participants indicated their inability to undertake repairs due to financial constraints and lack of collateral to obtain personal loans. The mood projected a sense of hopelessness and despair and the need for immediate intervention. Question #2: Have you started any repairs to the housing structure since the hurricane? Please describe what has been done, and who carried out the work and the costs? i. “Our land is held in common, many people are self-employed. People build based on savings due to no collateral. It is very difficult when you talk about rebuilding …and who is going to meet the costs considering 5-month span before the next hurricane season. The question of material, most of the material is inferior and most reports indicate that our local lumber is better.� ii. “Finally finish building my house after twenty-five years; Maria come and take away everything…I am 58 years old…� iii. “I just used some old galvanize to cover my roof… finance, money…without money you cannot get materials.� iv. “Most people are unemployed; so, we will remain in the same situati on we are in now. We are just waiting for things to happen…we cannot do anything.� Home Insurance Due to communal land ownership practice within the Kalinago Territory, home insurance is almost non- existent. This we learned is as a result of economic conditions as well as tradition. Question #3: Do any of you have home insurance? If yes, what support has been provided by your home insurance? i. “Nothing is insured here.� ii. “I am too poor to pay insurance.� iii. “The tradition here people are not insured.� iv. “It has a lot to do with finances; and to be insured house has to be up to a certain standard.� v. “I don’t exactly live in the territory so I have insurance; it took a while and basically what you get is not enough.� Beneficiary Identification The general consensus from the group for the selection of beneficiaries under the Housing Recovery Project was to focus on the most vulnerable. It was felt that these beneficiaries should include the children, female-headed households, persons living with disabilities and the poor. Question #4: Based on your personal experience and your knowledge of the damaged caused to homes in Dominica, what groups of people do you think should be prioritized for housing support (if resources are limited)? i. “Children� ii. “Poor (unemployed; part-time employment)� iii. “Female-headed households� 33 iv. “Infirmed/Disabled Persons� Recommendations for Project Design When asked about possible project design ideas, the respondents encouraged focus on climate resilient structures to include renewable energy sources for electricity and a more consistent water supply. This suggestion was married to consideration for the continuation of sustainable livelihood practices that will provide beneficiaries with opportunities to continue subsistence farming. Question #5: What are your expectations of the project? i. “The project should deliver building a home that is capable of withstanding hurricanes, should be water and power independent. It should also take in consideration the cultural and traditional aspect of people living with backyard gardens to sustain themselves.� 34 ANNEX 5.2 High Level Discussion Project elements discussed: 1. The Housing Recovery Project was designed to provide support to a significant number of people whose homes were totally destroyed by Hurricane Maria. 2. The financing agreement for the Project was signed on May 10, 2018 between the World Bank and the Government of the Commonwealth of Dominica. 3. By way of information, nationally 18% (4,503 homes) were completely destroyed. 4. The Housing Recovery Project will seek to build 1,700 climate resilient starter homes across Dominica; starter homes sizes will not exceed 500 sq. ft. 5. Beneficiaries of the project will be the “most vulnerable�. 6. 35% of beneficiaries must be single-headed households. 7. Beneficiaries will be given a provision of EC$50,000 each towards construction of their starter homes and these funds will be administered by the Ministry of Finance and Investment. 8. The homeowner/beneficiary is expected to drive the process with support from a Design and Supervision Firm and the Project Implementation Unit. 35 ANNEX 5.3 Community Consultation The objectives of this consultation were: 1. To provide the Kalinago community with a greater level of detail on the planned investments – Housing Recovery Project; 2. To present an opportunity for comments, clarifications, questions, concerns, suggestions to be aired and discussed; 3. To receive Community feedback on the potential positive as well as negative impacts of the investments; and 4. To identify mitigation measures to be included in the project and implemented via the IPP. Age Groups Participation Male Female Total 15-19 0 0 0 20-24 0 0 0 25-29 1 1 2 30-34 0 2 2 35-39 1 0 1 40-44 1 0 1 45-49 0 1 1 50-54 0 2 2 55-59 2 1 3 60+ 1 1 2 TOTAL 6 8 14 Table 4: Analysis of Participants by Age & Sex – First Consultation 36 Photo 1: Community Consultation, June 2018 Photo 2: Participants sharing thoughts, June 2018 Photo 3. Participant sharing her thoughts, June 2018 37 ANNEX 6.0 Meeting with Kalinago Council prior to IPP Public Disclosure Members of the former Kalinago Council were invited to attend an IPP Review Meeting at the HRP Office on Thursday, 18th April, 2019. They were furnished with the draft revised IPP both electronically and in hard copy. The PIU discussed the HRP and the revised IPP with the members who attended- former chief, Charles Williams and Jumadine Frederick, the Kalinago Council’s housing officer. Some of the highlights of this meeting are as follows: • The language of the IPP should be gender sensitive and single mother/father should be changed to “vulnerable families�, bearing in mind also that there were a lot of single men within the territory. • The dependents of the applicant’s household must be Kalinago in order to be prioritized. • The preservation of their cultural identity is important during project activities. • The Kalinago Council verifies land occupancy through an authorization letter, and must authorize building through an application form. The site is assessed and recommendations are made as it pertains to hazards found in the area. The Housing Officer for the council will do site assessments with a technical team and they have their own set of criteria to meet for housing approval within the Territory. • Kalinago living outside of the territory may apply and form part of consultations specific for the Kalinago people. • The Kalinago sell land from person to person and renting is not uncommon in the Kalinago Territory. • The size of the house to be reconstructed, 300 sq. ft., was a bit of a concern • Consultations held during the development of the IPP were recalled, including a second consultation on October 11th, 2018 with Government’s Social Planner. 38 ANNEX 7.0 Meeting with New Kalinago Council post IPP Public Disclosure A full day consultation was held in the Kalinago Territory on Wednesday 9th October, 2019. This coincided with one of the World Bank’s Missions to Dominica and so, the World Bank Safeguards Specialists participated. The consultations main objectives were: 1. To introduce the newly formed Kalinago Council to the HRP and WB Environmental and Social Safeguards policies and procedures- namely the ESMF, IPP and GRM 2. To meet with the new Kalinago Chief to discuss expectations and plans as it related to the HRP, as well as ongoing development activities in the Kalinago Territory 3. To meet and formalize the Validation Committee nominees and orient them to the HRP and validation process. Results of Validation Committee Formalization and Orientation: • There were seven (7) validation committee members of which two (2) were Kalinago Council members. • The validation committee along with the Kalinago Chief recommended that a standardized reporting sheet be developed to carry out the applicant summary review. This recommendation was taken into consideration and is being used to validate all applicants reaching this stage in the selection process • The Kalinago Validation Committee, through the council members who were part of the committee, had access to all records of residents, particularly housing records. Therefore, they developed their own system for verifying applicants to the Housing Recovery Project. 39 ANNEX 8.0 Final Beneficiary Design Consultations Following the Orientation of the first cohort of beneficiaries to the HRP, the design and supervision firm, embarked on assessment of a pilot group, which would steer the way forward for the house design finalization process. Of that group, at least one Kalinago applicant would have the opportunity to review preliminary designs, and give feedback to the design firm. This was held on Monday 5th October, 2020 during four (4) separate sessions in order to adhere to COVID-19 social distancing protocol. On October 8th, 2020, the preliminary designs were shared with the Kalinago Council during a half day consultation in the Kalinago Territory. At this consultation, the council members were introduced to the design firm and held a discussion on the adaptability of the designs to the territory. They were also informed of the update required for the revised IPP and the sections that will be updated to suit project adjustments and developments. Below is a summary of the consultation: Article 25 presented their preliminary designs to the Kalinago Council, who reviewed and discussed adaptability to the Kalinago Territory. The council members described the current housing projects that are taking place and described current living conditions, house designs, lifestyle and traditions. Following this interaction, the PIU presented the revised Indigenous People Plan with specific reference to the engagement of contractors and skilled tradesmen and planned consultations. It was agreed that the update would be done virtually with support from the Kalinago Chief, and the PIU would facilitate the registration of contractors and skilled tradesmen from the Kalinago Territory the following week. Preliminary Designs and its adaptability to the Kalinago Territory: • The Kalinago would prefer traditional styles but are concerned about the resilience of the materials and environmental degradation or deforestation. Although they mentioned that designs should incorporate local wood species as there are homes designed by local contractors using local materials which survived Hurricane Maria winds (built in 1960s), it was preferred that the most resilient materials and designs be used within the Kalinago Territory. It was agreed that the council members would show Article 25 a few of these houses that they mentioned. • It is important to have private yard for pets and backyard farming. • Pre-fabricated homes are not adaptable to terrain in most cases. • HRP houses will adapt to terrain given the attention to custom-fit designs. • Local houses are usually built with a fireside outside in the yard. • Households these days have about 3 to 4 children. • Most residents of the Kalinago Territory are recipients of the 70+ allowance, pauper’s allowance • and work under the NEP. • The Home-stay program is a source of income for Kalinago families, and so future houses should consider the possibility of an additional room. It would be important to find out if there are applicants to the project who are qualified and whose source of income was the Home-stay programme. Update of Indigenous Peoples Plan: • The council asked for an updated list of approved beneficiaries so they can verify if these persons are already accepted on other projects. They also shared a list with the PIU. • Some concerns were raised regarding the willing of houses by the homeowner • It was agreed that the following week, the HRP PIU would facilitate the registration of contractors and skilled tradesmen. This activity was planned for Thursday 15th October 2020 between 2pm and 5pm at the St. Cyr Resource Centre. • It was also discussed that non-skilled laborers above 18 years old should be facilitated through an apprenticeship programme so that they can gain experience in construction. 40 • The Indigenous Peoples Plan will be updated to reflect changes in the GRM, project cycle/homeowner journey, and consultations plan and budget. The Kalinago Chief agreed to support the update of the document. Meeting participants: Name Organization Role Debra Phillip Kalinago Council Council member Marion Valmond Kalinago Council Council member- Housing sector Lorenzo Micah Sanford Kalinago Council Kalinago Chief Anthony Lucien Kalinago Council Council member Gabriel Thomas Kalinago Council Council member Alexander Burton Kalinago Council Council member Jahna McLawrence HRP-PIU Social Safeguards Specialist Lolita Raffoul HRP-PIU Environmental Specialist Regie Ephson World Bank Project Management Consultant Branca Pegado Article 25 Architect Bea Sennewald Article 25 Architect Gregor Fortune Fortune-Edgehill Engineer Photo 4. Article 25 (Design Firm) introducing themselves and presenting designs Photo 5. Kalinago Council reviewing designs and giving feedback 41 ANNEX 8.3 Virtual Update of Revised IPP In order to update the Revised IPP of 2019, the Kalinago Council was invited to a virtual meeting on Wednesday, 18th November, 2020. The Kalinago Chief was unable to attend, however, the council’s new housing officer, Marion Valmond and another councilor, responsible for Education and Sports, Alexander Burton, participated. The revised IPP was shared with the Kalinago Council and they reviewed together with the Social Safeguards Specialist via Zoom. Some of the highlights are as follows: • The registration of skilled tradesmen and contractors in the Kalinago Territory did not take place because there wasn’t a large enough number within that region, and given the COVID-19 social distancing protocol, it would not be practical to hold a registration session. Therefore, the housing officer confirmed that at least 3 qualified contractors were directed to the HRP Office to register. • Non-skilled laborers above 18 years old would be facilitated if a contractor who is contracted under the project wishes to hire and train them. Although it is a home- owner driven project, and beneficiaries may choose to participate in construction works or have whoever they please to assist in the works to gain experience, the project is designed to avoid delays, health, safety, social and environmental risks, and be as cost-effective as possible during construction. • As it relates to the “Proposed Solutions/Mitigation Measures� section of the IPP, the council members were updated on the following- which would be included in the IPP report: o Employ construction supervisor to ensure adherence to standards: A Design & Supervision Firm was contracted for design and construction phase of all houses o Design firm train local contractors and laborers: Three (3) contractor workshops were held for all contractors and skilled tradesmen registered with the HRP. The contractors will choose how and who they employ for each house that they are selected to reconstruct. o Undertake periodic inventory of materials on site: This will be a part of the contractor’s procedures o House designs should pattern ‘green homes’ concept with at least one (1) solar unit per home as well as water tanks (introduce rainwater harvesting): The design firm, has submitted resilient, environmentally sustainable designs for review and approval by the PPD and subsequently, selection by beneficiaries o Undertake intense awareness programme for Housing Recovery Project: A Facebook page was developed and ads aired via radio. o Review of land use policy within the Kalinago Territory: This needs to be revisited, as new Kalinago Council members indicated that a land use policy was being developed but was paused. • The Ministry names would be updated and the project adjustments would be included in the updated IPP. • It was agreed that the updated IPP would be again shared with them and reviewed by the World Bank for approval to disclose on its website and the HRP website. 42 ANNEX 8.4 Current Data Relevant to the IPP 1. Out of the 885 Hurricane Maria-affected homes in the Kalinago Territory, 487 were completely destroyed. Along with the implementation of the HRP, three other housing projects are ongoing in the Kalinago Territory to support the households of the completely destroyed homes. 2. Out of 2,800 applications captured in the HRP’s MIS, 650 were from the Kalinago Territory (23.21%). 3. Out of the 78 applicants who successfully enrolled with the HRP, 25 were from the Kalinago Territory (32.05%) 4. Out of 228 applicants who have made it to Final Beneficiary Approval stage, 60 are from the Kalinago Territory (26.3%) This information will support the implementation of the IPP according to the project dynamics. Financial plans will have to change to suit the project activities and decisions based on COVID-19 social distancing protocols and participant distribution- Kalinago potential beneficiaries and contractors. The following illustrate the data of all final beneficiaries to the project as of November 2020 and will be closely monitored throughout the project to ensure positive effects on the Kalinago People: Head of Household Age 60-65 over 65 7% 11% 40 to 60 49% 40 to 60 under 40 over 65 under 40 33% 60-65 Figure 3. Pie chart showing current age distribution among head of households who are final beneficiaries of the HRP (49% are middle aged). Information gathered at time of application. 43 Employment Status 2% employed 22% 33% seasonally employed self employed 18% unemployed 25% retired Figure 4. Pie chart showing current employment status among final beneficiaries of the HRP (33% are unemployed). Information gathered at time of application. Marital Status by Sex 41 9 1 6 0 1 1 1 SINGLE MARRIED DIVORCED/SEPARATED WIDOW/WIDOWER Female Male Figure 5. Bar chart showing current martial status by sex among head of households who are final beneficiaries of the HRP (41% are single male). Information captured at time of application. 44