Involuntary Resettlement
0P 4.12: Financial Intermediaries and
Resettlement Planning Instruments
A Resettlement Overview
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What does OP 4.12 require financial
intermediaries to do?
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What are the purposes of resettlement planning?
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What specific and recurring issues require
attention in Turkey projects?
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What is a Resettlement Action Plan (RAP) and
what does it require?
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What is a Resettlement Policy Framework (RPF)
and what does it require?
Role of Financial Intermediaries

Prepare and agree a Resettlement Policy
Framework with the Bank
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Screen all proposed on-lending activities for land
acquisition and associated resettlement impacts
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If RPF deemed unnecessary, legal documents
require compliance if impacts should arise
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For all subprojects involving relevant impacts,
Bank approval of a resettlement plan required
before accepted for financing
Delegation of Clearance to FIs

Bank may delegate in writing authority to review
and clear resettlement plans to FIs
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Requires demonstrated capacity to review plans
and ensure policy consistency in implementation
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Legal documents establish delegation, as well as
Bank recourse if review process is inadequate

Bank Provide arrangements and resources for
implementation of mitigation measures
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Resettlement plans subject to ex-post Bank
review
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Implementation subject to Bank supervision
Key Planning Objectives
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Identify adverse impacts for avoidance,
minimization or mitigation
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Assist affected people to improve, or at least
restore, incomes and living standards
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Provide arrangements and resources for
implementation of mitigation measures

Mitigating risks for affected people helps
minimize risks to borrower and Bank, too
Key Planning Considerations
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Resettlement planning and implementation is
the borrower’s responsibility
But plans and implementation must be
consistent with Bank principles and standards
Implementers and affected people should be
involved in planning process
Compensation and other necessary assistance
provided before impacts are imposed
Financial intermediary must coordinate
planning and implementation
Likely FI Coordination Issues

Making sure subclients are aware of, and
understand, requirements for Bank financing

Reaching agreement to change normal
procedures or provide additional assistance

Prepare stand-alone resettlement plans
consistent with Bank requirements

Ensure appropriate timing and sequencing of
planning and implementation

Ensure appropriate documentation and reporting
Recurring Issues in Turkey Projects

Defining the project: Sequencing and “linkage” in
application of Bank policy

Bridging the eligibility gap: Assisting people who
lack full legal recognition

Covering all costs: ‘Replacement cost’ valuation,
transaction costs and transitional support

Going beyond compensation: Income restoration
and development opportunities

Ensuring adequate consultation under emergency
expropriation procedures
Resettlement Policy Framework

RPF establishes principles, procedures and
responsibilities for planning and implementation

Prepared when it is impossible to finalize a
project or subproject RAP by appraisal
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Technical planning cannot be done if location,
nature and scale of impacts are not known

Bank acceptance of RAP required prior to
‘approval of financing’ and initiation of works
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RPF should establish due diligence reporting
requirement for sites already acquired
Core Content of RPF
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Description of project and estimated impacts
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Explanation why full planning is not possible
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Key principles and objectives
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Policy and regulatory gap analysis
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Plan preparation and approval process
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Organizational roles and procedures
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Consultation, disclosure and grievance redress
commitments
Recurring RPF Transition Issues

RPF should be prepared by borrower, to show
understanding and acceptance of obligations
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RPF provides tentative agreement; RAP
reviewed and approved based on final design

RPF should reflect level of information
available at appraisal stage
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Planning or implementation issues often arise
if borrower ownership or coordination is weak
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In FI projects, implementation issues arise if
subclients do not know or accept requirements
Resettlement Action Plan

Provides an institutional and technical basis for
identifying and mitigating resettlement impacts
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Scope of planning should be commensurate with
scale and complexity of impacts:
Planning requirements are more extensive when relatively large
numbers of people are affected, when incomes and livelihoods are
affected, or when planning for resettlement sites is necessary
An abbreviated resettlement plan is acceptable when less than
200 people are affected, when there is no need for income
restoration, and when resettlement sites are not necessary

Bank acceptance of the RAP is required prior to
subproject approval for financing
RAP: Institutional Aspects
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Policy and regulatory gap analysis
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Timetable linked to project implementation
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Organizational roles and capacity assessment
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Internal and external monitoring arrangements
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Consultation and information dissemination
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Grievance procedures
RAP: Technical Content
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Description of project and impacts
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Impact avoidance and minimization efforts
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Identification of affected persons and impacts
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Valuation, compensation and assistance
measures
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Relocation site plan (if relevant)
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Income restoration plan (if relevant)
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Budget and financial arrangements
Conducting Census and Inventory
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100% census is essential for identifying and
enumerating all affected people
Inventory of affected assets essential to
categorization of impacts and formulation of
assistance
Income-related impacts and other potential
socioeconomic issues can be considered on
sample survey basis
Full and timely data gathering is key to
establishing eligibility, budgeting, monitoring and
resolution of grievances
Recurring Practical Problems
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RAP inputs and processes are more timeintensive than usual domestic practice
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Consultation and information disclosure
requirements may be more extensive
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Clarifying responsibilities and inter-agency
coordination can be difficult
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Different Bank measures and procedures
bureaucratically difficult to implement
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Bridging gaps: borrower often lacks authority to
go beyond existing regulations or practice
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Monitoring and adapting to contingencies