Tanzania - Secondary Education Development Program Project : resettlement plan

RP244 THE UNITED REPUBLIC OF TANZANIA Ministry of Education And Culture SECONDARY EDUCATION DEVELOPMENT PROGRAM (SEDP) RESETTLEMENT POLICY FRAMEWORK (RPF) May 13, 2004 FILE COPY  TABLE OF CONTENTS GLOSSARY OF KEY TERMS .II 1. INTRODUCTION .3 2. PRINCIPLES AND OBJECTIVES GOVERNING RESETTLEMENT PREPARATION AND IMPLEMENTATION .8 3. DESCRIPTION OF THE PROCESS FOR PREPARING AND APPROVING RESETTLEMENT PLANS .10 4. LAND ACQUISITION AND LIKELY CATEGORIES OF IMPACT .15 5. ELIGIBILITY CRITERIA FOR DEFINING VARIOUS CATEGORIES OF PROJECT AFFECTED PERSONS .19 6. A LEGAL FRAMEWORK REVIEWING THE FIT BETWEEN THE LAWS AND REGULATIONS OF THE UNITED REPUBLIC OF TANZANIA AND BANK POLICY REQUIREMENTS AND MEASURES PROPOSED TO BRIDGE ANY GAPS BETWEEN THEM .21 7. METHODS OF VALUING AFFECTED ASSETS .24 8. ORGANIZATIONAL PROCEDURES FOR THE DELIVERY OF ENTITLEMENTS, INCLUDING, FOR PROJECTS INVOLVING PRIVATE SECTOR INTERMEDIARIES, THE RESPONSIBILITIES OF THE FINANCIAL INTERMEDIARY, THE GOVERNMENT, AND THE PRIVATE DEVELOPER .33 9. A DESCRIPTION OF THE IMPLEMENTATION PROCESS, LINKING RESETTLEMENT IMPLEMENTATION TO CIVIL WORKS .35 10. A DESCRIPTION OF GRIEVANCE REDRESS MECHANISMS .37 11. A DESCRIPTION OF THE ARRANGEMENTS FOR FUNDING RESETTLEMENT AND COMPENSATION, INCLUDING THE PREPARATION AND REVIEW OF COSTS ESTIMATES, THE FLOW OF FUNDS, AND CONTINGENCY ARRANGEMENTS . 39 -12. A DESCRIPTION OF MECHANISMS FOR CONSULTATIONS WITH, AND PARTICIPATION OF, DISPLACED (ECONOMICALLY OR PHYSICALLY) PERSONS IN PLANNING, IMPLEMENTATION, AND MONITORING .40 13. ARRANGEMENTS FOR MONITORING BY THE IMPLEMENTATION AGENCY AND, IF REQUIRED, BY INDEPENDENT MONITORS .41 ANNEX 1.45 ANNEX 2: TEMPLATE FOR PREPARING RESETTLEMENT AND COMPENSATION PLANS (RAPS) .46  GLOSSARY OF KEY TERMS * Cut - off Date - refers to a day on and beyond which any person who occupies land required for project use, will not be eligible for compensation. The date is often the day when the assessment of persons and their property in the project area commences. * Environmental and Social Management Framework (ESMF) - report is a safeguards instrument (document) which establishes a mechanism to determine and assess future potential environmental and social impacts of SEDP funded activities in the secondary school construction program, and then to set out mitigation, monitoring and institutional measures to be taken during design, implementation and operation of the project activities to eliminate adverse environmental and social impacts, offset them, or reduce them to acceptable levels. This instrument has been prepared as a separate and stand- alone document to be used in conjunction with the RPF. * Market rate - based on commercial terms according to Tanzania law for sale of land. * Project Affected Person(s) (PAPs)- are persons affected by land use or acquisition needs of the School Boards. These person(s) are affected because they may lose shelter, lose, denied, or restricted access to economic assets, income sources, or means of livelihood. These persons are affected whether or not they must move to another location. * Resettlement and Compensation Plan (RAP), is also known as a Resettlement Action Plan or Resettlement Plan - is a resettlement instrument (document) to be prepared when school locations are identified, that require land acquisition that leads to physical displacement of persons, and/or loss of shelter, and /or loss of livelihoods and/or loss, denial or restriction of access to economic resources. RAPs are prepared by the party impacting people and livelihoods (in this case the school boards) in this manner and contain specific and legal binding requirements to be taken by that party to resettle and compensate the affected party before project activities causing this adverse impact are implemented. * Resettlement Policy Framework (RPF): The RPF has been prepared as a resettlement instrument to be used throughout the SEDP implementation. The RPF will be disclosed to set out the resettlement and compensation principles, organizational arrangements and design criteria to be applied to meet the needs of the people who may be affected by the program. The RAP is prepared consistent with the provisions of the RPF. ii  1. INTRODUCTION 1.1 An exceedingly small proportion of the Tanzanian age group completes secondary education. At most 5% of the age group completes lower secondary and 1.5% completes upper secondary. As a result, less than 5% of the labor force has obtained secondary education. The main cause is restricted initial access and low retention. Only about one in four or five primary school completers proceeds to lower secondary education in Tanzania, compared with one out of two in Uganda (2001). Relatively high dropout rates in Forms II and III - 17% and 14%, respectively, in 1998 - reduce enrollments even further. Thus, the overall gross enrollment ratio for secondary education was only 7 percent in 2000, compared with a regional average of 28 percent. Only about one in four of those who successfully complete Form IV proceeds to the upper level. Currently participation rates are particularly low for low-income youth, rural students and for females (at the upper secondary level). 1.2 1% of the very poor were likely to have completed secondary education in the mid-1990s compared to over 11 % from the highest income group. In terms of gender, the balance is almost even at the lower secondary level, but tips strongly in favor of males at upper secondary. At lower secondary female students comprise almost half of the students, but this drops to only a third of the students at the upper level. Dropout rates also tend to be significantly higher among students from the lower income quintile and for girls between lower and higher secondary levels. 1.3 The low coverage of secondary education reflects constraints on supply and demand for secondary school places. After independence Tanzania expanded secondary school places but the policy was still to restrict entry to secondary education so as to focus on universal primary education. Public secondary education was mainly provided in a few high quality boarding schools to which access was governed by strict selection procedures. This policy seems to have continued since the Government has financed no new secondary school construction over the past 15 years, although a number of existing schools have been expanded. 1.4 This limited provision of secondary education is unsustainable. The pressure to expand secondary school places is likely to mount rapidly in the coming years as more and more students complete their primary schooling -- especially with the introduction of free primary education that has raised the gross enrollment rate in primary education to 100% in 2002 compared to 77% in 2000. The government will have to transform secondary education progressively from one servicing a small, elite clientele into one catering to a larger and more diverse group of children. Managing the sub-sector's expansion in a fiscally sustainable manner is a rapidly emerging policy issue. 1.5 The Government of Tanzania realizes this issue and is making a concerted effort to address it. Education is one of the priority sectors specified in the Government of Tanzania's Vision 2025 and its PRSP. Within this context, the govemment is deepening a comprehensive Education Sector Development Program (ESDP). The ESDP has defined the following general priorities: * Priority in spending on basic education; * Improvement in equitable access to quality secondary education; * Demand-driven and market-oriented post-secondary and higher education; and 3  * Institutional development to improve sector management and strengthen implementation capacity. 1.6 As part of this strategy, the Government of Tanzania has asked the World Bank for support of its Secondary Education Development Program (SEDP). The Project Development Objective of the Secondary Education Development Program (SEDP) is to promote economic and social development and reduce poverty through human resource development at the secondary level, especially for disadvantaged groups. The specific objectives of the SEDP are: * To increase the proportion of the relevant age group completing secondary education, especially underserved groups. * To improve learning outcomes of secondary students, especially at the lower level. * To enable the public, including local authorities and private sectors to manage secondary education effectively. 1.7 To achieve these objectives, the program is structured into specifically linked sub- component activities per specific objectives as follows: Objective 1: Increase the proportion of the relevant age group completing secondary education, especially underserved groups. (indicator: achievement of targeted enrollment completion ratios by age group for lower and upper secondary). Objective 2: Improve learning outcomes of students, especially at lower secondary level. (indicator: raised educational attainment of students as shown by continuous assessments and performance on public examinations). Objective 3: Enable the public administration to manage secondary education effectively. (indicators: authority devolved and exercised well at LGA and school levels; better central policy development and standards setting for cost- effective delivery of quality of secondary education, and improved oversight). 1.8 Specifically, Component 1 (Objective 1) will finance the construction of new secondary schools and the expansion/rehabilitation of existing secondary schools, inter alia. 1.9 The identification of sites for secondary school construction will be based on the needs of local communities as expressed by them through their districts and regions and/or the findings from a soon to be commissioned school mapping exercise. 4  * I 1.10 Under Component 1, therefore, land will have to be acquired to build these new schools on and to support the expansion of some existing schools. It is expected that in a vast majority of cases due to joint partnership manifested through effective participation and consultation between the GoT/MoE the Local Government Authorities (LGAs) and their local communities, land can be acquired using participatory techniques. 1.11 To this effect the GoT has prepared guidelines for the establishment of new secondary schools, which seeks community mobilization and participation and guidelines for identifying school sites. 1.12 For instance, a Secondary School Site must be large enough to accommodate the following; * 16 classrooms/streams * Assembly Hall * 3 Science Laboratories (for Physics, Chemistry and Biology) * 3 Special Classrooms (Geography etc.) * Library * 16 Staff Houses * Administration Block (with offices for Head, D/Head, Staff rooms, Waiting areas, Secretariat etc.) * Toilet Block * Kitchen and Eatery * Sporting Facilities 1.13 Because Tanzania is such a large country, approximately 945,000 km2 of land, with a population of 36 m, the average population density being as low as 38 persons/ sq. km, significant efforts would be made to select these sites to avoid or minimize impacts on livelihoods, people, land, property and on access to natural and other economic resources, as far as possible. 1.14 Notwithstanding, land acquisition or land use by some school management boards to support their planned construction activities under this program, may lead to either the physical or economic displacement of people or their loss, denial or restriction of access to economic resources and therefore ultimately to resettlement and compensation of people in some, perhaps only a few minority of cases for the types of investments proposed in this program. 1.15 When this occurs, the World Bank Operational Policy OP4. 12 on Involuntary Resettlement and certain laws of Tanzania will be triggered. This is possible because of the uneven and varying settlement patterns and population densities across Tanzania, since 5  significantly large portions of the country are designated as environmentally sensitive areas', such as the national parks and the surrounding/adjacent areas of many wetlands, lakes and rivers, etc. The areas around national parks and game reserves are generally very lightly populated and those around wetlands, river and lakes are more densely populated due to livelihood opportunities for many Tanzanians, from use of economic resources in these ecosystems. 1.16 At this stage however, the Government of the Tanzania is not required to prepare a Resettlement Plan since the school locations have not yet been identified and therefore their land needs have consequently not been determined also. However, the Government of the Tanzania is required by the World Bank to prepare a Resettlement Policy Framework (RPF) during project preparation to be publicly disclosed in Tanzania and at the info shop of the Bank. 1.17 The RPF establishes the resettlement and compensation principles, organizational arrangements and design criteria to be applied to meet the needs of the people who may be affected by the project. The RPF is prepared to the standards of the Government of the Tanzania's own laws and policies on resettlement and the policy of the World Bank, OP4.12. 1.18 When the school mapping exercise is complete and the District Secondary Schools Development Plans (DSSDP) are finalized and approved for funding under the SEDP, specific planning information on the location of these schools would be available and land/sites will be identified, resettlement/compensation plans will be closely coordinated with the planning and implementation of civil works and then subsequently prepared consistent with this policy framework by the School Boards and will be submitted to the LGA, for approval before any land acquisition, resettlement, loss, denial of, and restriction to economic resources or any other impact on livelihood occurs. 1.19 This RPF covers the following sections; 2. Principles and objectives governing resettlement preparation and implementation. 3. A description of the process for preparing and approving resettlement plans. 4. Land acquisition and likely categories of impact. 5. Eligibility criteria for defining various categories of project affected persons. 6. A legal Framework reviewing the fit between the laws of Tanzania and regulations and Bank policy requirements and measures proposed to bridge any gaps between them. 7. Methods of valuing affected assets. 8. Organizational procedures for the delivery of entitlements, including, for projects involving private sector intermediaries, the responsibilities of the financial intermediary, the government, and the private developer. Tanzania has a much bigger land surface area devoted to resource conservation (29%) than most countries. The hierarchical protected-area system consists of national parks (12), game reserves (28), the Ngorongoro Conservation Area (1), and game-controlled areas (38), comprising a total of 240,000 km2. In addition to the wildlife-protected areas, there are 540 forest reserves covering 132,000 kM2, equivalent to 15% of the total woodland and forest area in Tanzania. There is also the Mafia Island Marine Park. 6  9. A description of the implementation process, linking resettlement implementation to civil works. 10. A description of the grievance redress mechanisms. 11. A description of the arrangements for funding resettlement, including the preparation and review of cost estimates, the flow of funds, and contingency arrangements. 12. A description of mechanisms for consultations with, and participation of, displaced persons in planning, implementation, and monitoring. 13. Arrangements for monitoring by the implementation agency and, if required, by independent monitors. 1.20 This RPF governs all activities funded under the SEDP, and is to be used in conjunction with the Environmental and Social Management Framework (ESMF) that has also been prepared for this project as a separate stand alone document, also disclosed at the Bank info shop and in Tanzania. 7  2. PRINCIPLES AND OBJECTIVES GOVERNING RESETTLEMENT PREPARATION AND IMPLEMENTATION. 2.1 The impacts due to involuntary resettlement from development projects, if left unmitigated, often gives rise to severe economic, social and environmental risks resulting in production systems being dismantled, people facing impoverishment when their productive skills may be less applicable and the competition for resources greater; community institutions and social networks being weakened; kin groups being dispersed; and cultural identity, traditional authority, and the potential for mutual help are diminished or lost. The resettlement policy, in most cases, is not triggered because people are being affected by physical displacement. It is triggered because the project activity causes land acquisition, whereby a physical piece of land is needed and people may be affected because they are cultivating on that land, they may have buildings on the land, they may use the land for water and grazing of animals or they may otherwise access the land economically, spiritually or any other way which may not be possible during and after the project is implemented. Therefore, people are in most cases compensated for their loss (of land, property or access) either in kind or in cash of which the former is preferred. Therefore, the objectives of this policy are the following: (i) Involuntary resettlement and land acquisition should be avoided where feasible, or minimized, exploring all viable alternatives. (ii) Where involuntary resettlement and land acquisition is unavoidable, resettlement and compensation activities should be conceived and executed as sustainable development programs, providing sufficient investment resources to give the persons affected and/or displaced by the project the opportunity to share in project benefits. Affected and/or displaced and compensated persons should be meaningfully consulted and should have opportunities to participate in planning and implementing resettlement programs. (iii) Affected and/or displaced and compensated persons should be assisted in their efforts to improve their livelihoods and standards of living or at least to restore them, in real terms, to pre-displacement levels or levels prevailing prior to the beginning of project implementation, whichever is higher. Affected people, according to the Bank policy, refers to people who are directly affected socially and economically by the bank assisted investment projects, caused by: (a) the involuntary taking of land and other assets resulting in: a. relocation or loss of shelter b. loss of assets or access to assets c. loss of income sources or means of livelihood, whether or not the affected persons must move to another location; or (b) the involuntary restriction or access to legally designated parks and protected areas results in adverse impacts on the livelihood of the affected and/or displaced persons. 8  The Bank Safeguard Policy OP 4.12 applies to all components under the program, whether or not they are directly funded in whole or in part by the Bank. 2.2 The policy applies to all economically and/or physically displaced persons regardless of the total number affected, the severity of impact and whether or not they have legal title to the land. Particular attention should be paid to the needs of vulnerable groups among those economically and/or physically displaced; especially those below the poverty line; the land less, the elderly, women and children, indigenous groups, ethnic minorities and other historically disadvantaged groups or other economically and/or physically displaced persons who may not be protected through Tanzania's Land compensation legislation. 2.3 In particular for SEDP, the policy also requires that the implementation of individual resettlement plans are a prerequisite for the implementation of the program activities requiring land acquisition, that is before any construction activity starts to ensure that displacement or restriction to access does not occur before necessary measures for resettlement and compensation are in place. It is further required that these measures include provision of compensation and of other assistance required for relocation, prior to displacement, and preparation and provision of resettlement sites with adequate facilities, where required. In particular, the taking of land and related assets may take place only after compensation has been paid and where applicable, resettlement sites, new homes, related infrastructure, public services and moving allowances have been provided to affected and/or displaced persons. Furthermore, where relocation or loss of shelter occurs, the policy further requires that measures to assist the affected and/or displaced persons are implemented in accordance with the resettlement plan of action. 2.4 It is particularly important to neutralize to the extent possible any socio-economic pressures in the communities that are likely to be exacerbated by involuntary resettlement, by facilitating the participation of those impacted in the construction activities. Therefore, offering impacted people the opportunity to continue to participate in the planning process that would lead to the preparation of Resettlement Plans is mandatory and Section L of this RPF deals with this requirement. 2.5 Also, offering impacted people the opportunity for employment during the construction of the schools will provide additional income generating opportunities to a significant number of impacted persons who may potentially have to be resettled. Therefore, the opportunity for employment of affected people by local building contractors is being taken advantage of in this RPF, by including it for discussion in the consultative process with the local communities. 2.6 Furthermore, it is worthy to note that rush migration to selected land/sites/areas may occur by those wishing to take advantage of the rules of eligibility described earlier in this Section. Were this to happen it would bring to bear additional pressures on the whole planning process and compensation budgets. This has major considerations therefore when establishing the cut-off dates. 2.7 A major object of this RPF is to ensure that affected individuals and households, and affected and/or displaced communities are meaningfully consulted, have participated in the planning process, are adequately compensated to the extent that at least their pre-displacement incomes have been restored and that the process has been a fair and transparent one. 9  3. DESCRIPTION OF THE PROCESS FOR PREPARING AND APPROVING RESETTLEMENT PLANS. 3.1 As stated earlier, the World Bank policy on Involuntary Resettlement OP 4.12 is triggered because the SEDP will finance the construction of new secondary schools and the expansion/rehabilitation of others that may require land acquisition, potentially leading in a minority of cases to loss, denial, or restriction of access to economic resources. Since the location of these sites were not known at the time of the preparation of the project, the preparation and disclosure of this RPF is a conditionality for appraisal of this program. However, during implementation of this program, in a process defined here below, the selection of these sites would be made. When that happens, land would be acquired or access to economic resources may be lost, denied or restricted and people may then be affected. At that stage, OP 4.12 calls for the preparation of individual Resettlement Plans that must be consistent with this RPF. 3.2 To address the impacts under this policy, resettlement plans must include measures to ensure that the affected and/or displaced persons are; (a) informed about their options and rights pertaining to resettlement. (b) consulted on, offered choices among, and provided with technically and economically feasible resettlement alternatives. (c) And provided prompt and effective compensation at full replacement cost for losses of assets and access attributable to the program. (d) enabled to restore and preferably improve their living standards compared to program ones. 3.3 Therefore, the first stage in the process of preparing the individual resettlement plans is the screening process to identify the land acquisition and land use needs that will cause resettlement. The resettlement and compensation plans will contain the analysis of alternative sites undertaken during the land screening process. 3.4 The land screening process presented here below is designed to be part of the School Boards2 planning stage, thereby ensuring that their application for funding under the SEDP, which they would have to submit to their respective district also complies with the requirements of OP 4.12 and the laws of Tanzania relating to land acquisition/use and resettlement. The modus operandi for the identification of areas for construction of new secondary schools and expansion/rehabilitation of existine secondary schools would be; Step 1: This process starts when approval3 of the list of schools to be included in the construction program of District Secondary School Development Plan (DSSDP)4 is approved. Step 2: For a new school, the school management board is appointed/elected. For existing schools who are approved for expansion/rehabilitation, it is assumed that they already have a School Board in place. 2 In line with MoE guidelines, all secondary schools must elect/appoint a School Board, that will inter alia, provide management oversight for the school. 3The decision on where a secondary school is to be built will be made by the districts. 4Refer to Section 9, Fig 9.2, of the ESMF. 10  Step 3: The School Board will request suitable and appropriate land from the Village Administration5 of the village in which the school is to be located. Using Participatory methods, the Village Administration will consult with local communities within the schools boundary area, to select the required land to allocate to the School Board, using the following criteria; * The site should normally not be within an Environmentally Sensitive Area (ESA)6. * The site should ideally be located within 500meters of a settlement area. * There should be a sustainable source of potable water within 1 km of the site. * The site should be at least 20,000m2 in size or large enough to accommodate the building schedule for a new secondary school. The building schedule is contained in Section A, Paragraph 12. of this RPF. * The site owners and/or users if any are consulted and are invited to participate in the activities of the local community regarding the school. * The School Board must be able to secure legal title to the land. * The outer boundaries of the site should be clearly marked and the length of the sides should be measured in meters. * There should not be any natural or manmade features on the site that could make construction difficult or that could pose danger to building structures or humans such as bedrock, gullies, water pipes, swamps, floodplains and rock falls. * There should not be any natural or man made features within 100 meters of the site that could pose danger to pupils once the school is established, e.g. very steep cliffs, electricity pylons, etc. * The site must conform to and be consistent with the local development plan for that area/district. * The site should not lead to either the physical displacement of people, loss of their shelter, loss of assets, loss of income sources or means of livelihood, or their loss, denial or restriction of access to economic resources. If it does impact any one of these, chose another site. If this is not possible then OP 4.12 is triggered and those affected must be compensated, consistent with the provisions of this RPF. Step 4: If the School Board determines that the site is suitable because it satisfies the criteria above, then the allocated land/site would be accepted. Go To Step 10. Step 5: If the site does not meet the criteria above the Village Administration will be advised to allocate another piece of land/site until a site is found that satisfies the screening criteria. 5 The Village Administration is a Corporate Body under the Decentralization Law in Tanzania. 6 ESA - are defined in Annex I 11  The LGAs will assist the School Board and the Village Administration if they so request that assistance. Step 6: For situations where resettlement cannot be avoided, OP 4.12 will apply. For each parcel of land that has potential PAPs, so determined using the process described above, the cut- off date7 will be immediately established using participatory methods again, acceptable according to local traditions. Step 7: For each parcel of land that has potential PAPs, the School Committee will request its service providers to carry out (i) a socio-economic study and (ii) a census8 to identify the potential PAPs on the individual, household and vulnerable groups level and to calculate their household incomes, as the first step in the preparation of the RAPs. Step 8: On completion of the socio-economic study and the baseline census the School Board will prepare a Resettlement and Compensation Plan (RAP) for each site/parcel of land that is affected by resettlement and compensation. There will be as many RAPs as there are affected parcels of land. 3.5 Where the impacts on the entire displaced population are minor (i.e. if affected people are not physically displaced and less than 10% of their productive assets are lost) or fewer than 200 people are displaced, and then the bank may approve the preparation of an Abbreviated Resettlement Plan (ARAP). The contents of the ARAP are to be: (a) a census survey of displaced persons and valuation of assets. (b) Description of compensation and other resettlement assistance to be provided. (c) Consultations with displaced people about acceptable alternatives. (d) Institutional responsibility for implementation and procedures for grievance redress (e) Arrangements for monitoring and implementation, and (f) A timetable and budget. 7 The significance of establishing a cut of date is discussed in Section E. 8 The purpose of the socio-economic study is to collect base line data within the chosen/targeted sites/areas thereby enabling the social assessment of potentially affected populations/communities. The socio- economic study would focus on the identification of stakeholders (demographic data), the participation process, identification of affected people (including owners and users of land) and impact on their property and their production systems, the institutional analysis and the system for monitoring and evaluation. Detailed calculation of individual and household economies and identification of all impacts will be undertaken as part of the socio-economic study and be the determinant in the potential compensation process. Standard characteristics of the affected households, including a description of production systems, labor, and household organization, and baseline information on livelihoods (including production levels and incomes derived from both formal and informal economic activities) and standards of living and health status of the PAPs. Under this study a comprehensive base line census would be carried out to identify potentially affected people on the individual and household levels, vulnerable groups (women, children, the elderly, female headed households, black farm workers, HIV/AIDS affected persons etc.) and to discourage inflow of people ineligible for assistance. 12  3.6 For impacts that are not considered minor, the preparation of a Resettlement Action Plan (RAP) is required for each site. World bank OP 4.12 article 25 and Annex A sets the requirements of the RAP to include; (a) Description of the project (b) Potential Impacts (c) Objectives (d) Socioeconomic Studies (e) Legal Framework (f) Institutional Framework. (g) Eligibility (h) Valuation of and compensation for losses (i) Resettlement measures (j) Site selection, site preparation, and relocation (k) Housing, infrastructure, and social services (1) Environmental protection and management (m) Community participation (n) Integration with host populations (o) Grievance procedures (p) Organizational responsibilities (q) Implementation schedule (r) Cost and budget (s) Monitoring and evaluation 3.7 The RAPs cover the elements above, as relevant. When any element is not relevant to the School Boards circumstances, it should be noted in the RAP. Step 9: The School Board, then forward forwards the RAP together with the modified designs9 for screening and approval to the respective LGAs in compliance with the local planning laws and SEDP institutional and administrative requirements. All school construction activities that trigger OP4.12 and their resettlement plans would be subject to the final approval of the World Bank to ensure compliance with bank safeguards. Thus ensuring 9 See ESMF, Section 9.1(j) 13  that before land is actually acquired or access to resources is lost, denied or restricted, that the individual resettlement plans are consistent with this RPF. Step 10: For School construction activities that do not have any resettlement issues and do not trigger OP 4.12, then the provisions of this RPF do not apply and the School Board is referred to the ESMF at this stage. 3.8 Approval of funding for any school construction activities that needs to acquire or use land under the SEDP, the School Board must first comply with all local laws and seek clearance of the local authorities to use/acquire the land for that purpose, consistent with the provisions of this RPF. For investments on land that is already owned or in use by the school board, the LGA and MoEC will only approve funding once it is satisfied that the provisions of this RPF were met in cases where OP 4.12 apply. 3.9 Furthermore, the LGAs should as a guideline considers the cumulative factor and not approve multiple sites that have individual high impact intensity. For example, where land acquisition is required to such an extent that it would require more than 20% of a community's or individual's total land under use or when the mitigation measures are so cumbersome that their efficacy cannot be predetermine or they cost more than 15% of the investment budget. 3.10 Before the decision to approve a site is taken, the respective LGAs would need to approve or disapprove the resettlement and compensation plans of the School Boards construction program in totality with the overall environmental and social screening process that has been applied for each of their proposed investments and to also approve or disapprove of the proposed mitigation measures, if any. The ESMF contains the environmental and social screening process. 3.11 The Capacity of the LGAs will be built by training'