External Social Safeguard Monitoring First Progress Report

Project No. 45203-006 Semestral Report December 2018

Bangladesh: Natural Gas Infrastructure and Efficiency Improvement Project (Component 2 – -Bakhrabad Gas Transmission Pipeline)

Prepared by Md. Abdus Samad for the Gas Transmission Company Limited, Government of and the Asian Development Bank.

This social safeguard monitoring report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB's Board of Directors, Management, or staff, and may be preliminary in nature.

In preparing any country program or strategy, financing any project, or by making any designation of or reference to a particular territory or geographic area in this document, the Asian Development Bank does not intend to make any judgments as to the legal or other status of any territory or area.

Gas Transmission Company Limited (A Company of Petrobangla) Government of the People’s Republic of Bangladesh Ministry of Power, Energy & Mineral Resources Energy & Mineral Resources Division External Monitoring Expert Services to carry out the External Monitoring & Evaluation (M&E) and reporting of the Implementation of Resettlement Action Plan (RAP) under the “Construction of Chattogram-Feni-Bakhrabad Gas Transmission Parallel Pipeline Project”

1st Progress Report December, 2018 Submitted to 1. Mr. Yoojung Jang- Social Development Specialist 2. Mr. Hong Wei Zhang- Senior Finance Specialist Asian Development Bank For Construction of Chittagong-Feni-Bakhrabad Gas Transmission Parallel Pipeline Project Ref: Contract No. GTCL- SD3 Dated 9th August, 2018 between Gas Transmission Company Limited (GTCL) and Md. Abdus Samad, the Individual Consultant ( External Monitoring Expert) for the implementation of Resettlement Action Plan (RAP) under “Construction of Chattogram-Feni-Bakhrabad Gas Transmission Parallel Pipeline Project” Submitted by Md. Abdus Samad External Monitoring Expert For Implementation of Resettlement Action Plan of “Construction of Chattogram-Feni-Bakhrabad Gas Transmission Parallel Pipeline Project”

Subject: Submission of 1st Progress Report, December, 2018 Ref : External Monitoring Expert Services to carry out the External Monitoring & Evaluation (M&E) and reporting of the Implementation of Resettlement Action Plan(RAP) under “Construction of Chattogram-Feni-Bakhrabad Gas Transmission Parallel Pipeline Project”

Contract No: GTCL-SD3 Dated 9th August, 2018 ADB Loan No: 3461/3462 BAN Dear Sir, In reference to the above subject, I am submitting the 1st Progress Report for the Implementation of Resettlement Action Plan(RAP) under “Construction of Chattogram- Feni-Bakhrabad Gas Transmission Parallel Pipeline Project” for your kind information and necessary action. With best regards,

Md. Abdus Samad External Monitoring Expert Construction of Chattogram-Feni-Bakhrabad Gas Transmission Parallel Pipeline Project

Table of Contents Items Pages Abbreviations ...... 5 Glossary ………………………………………………………….…………..7 1. Background of the Project …………………………………………… 10 2. Purpose of the Project……………………………………………… 11 3. Objective of the project……………………………………………. 11 4. Objective of ADB and AIIB……………………………………….. 11-12 5. Bangladesh Government Legal Policy…………………………….. 12 6. Assets to be Acquired by the Project……………………………… 13 7. Scope of works…………………………………………………….. 15 8. Methodology of works…………………………………………….. 16 9. Indicators of verification…………………………………………… 16 10. Implementation of RAP…………………………………………... 17 10.1 Land Acquisition process by DC………………………………... 17 10.2 Updating RAP by INGO ………………………………………... 17 10.3 Socio-economic survey………………………………………….. 18 10.4 JVC collected Information………………………………………. 19 10.5 Collection of Market price by INGO…………………………… 20 10.6 Personal contact with APs by INGO…………………………… 21 10.7 Distribution of leaflets by INGO………………………………… 22 10.8 Video Filming …………………………………………………… 22 10.9 Formation of JVC/PVAC/GRC………………………………….. 23 10.10 Notices served under section 3 and 4…………………………24 10.11 Land acquisition ……………………………………………….. 26 10.12 Consultation, information campaign, participation………… 27 11. Overall implementation of RAP…………………………………... 28 11. External Monitoring………………………………………………. 29

List of Tables

Table-1 List of assets to be acquired…………………………… 14 Table-2 Tasks Performed by INGO…………………………. 18 Table-3 Field level implementation……………………………. 19 Table-4 Joint Venture Committee……………………………… 20 Table-5 Market price collection rate…………...... 21 Table-6 Personal Contact with Affected Persons per District…... 21 Table-7 Distribution of leaflets…………………… ………….. 22 Table-8 Video Filming Conducted per District…………………… 22 Table- 9 Formation of JVC/PVAC/GRC………...... 23 Table-10 JVC/PVAC/GRC in Three Districts ……………………. 24 Table-11 Performance of INGO…………………...... 24 Table-12 Notices served under 1982 ordinance and 2017 Act 26 Table-13 Land Acquisition status of DCs……………………. 27 Table-14 Individual and joint functions of DC/GTCL/INGO… 29

Abbreviations AB Acquiring Body AC Assistant Commissioner (Land) ADB Asian Development Bank AIIB Asian Infrastructure Investment Bank ADC Additional Deputy Commissioner (Revenue) Ahs Affected Households AM Area Manager APs Affected Persons BBS Bangladesh Bureau of Statistics BGFCL Bangladesh Gas Fields Company Limited BFD Bangladesh Forest Department CBE Commercial and Business Enterprises CCL Cash Compensation under Law CEO Chief Executive Officer CMP Current Market Price CPR Common Property Resources DAE Department of Agriculture Extension DC Deputy Commissioner DCI Direct Calorie Intake DORP Development Organization of the Rural Poor DoF Department of Forest DoF Department of Fisheries ERD Economic Relations Division FGD Focus Group Discussion FW Field Worker GoB Government of Bangladesh GRC Grievance Redress Committee Ha Hectorage HIES Household Income and Expenditure Survey ID Identity Card JVS Joint Verification Survey JVC Joint Verification Committee Km Kilometer LAP Land Acquisition Plan LAR Land Acquisition and Resettlement LGI Local Government Institution LMS Land Market Survey M&E Monitoring and Evaluation NGO Non-Government Organization PAH Project Affected Households PAP Project Affected Person PAU Project Affected Unit PCU Project Coordination Unit PD Project Director PIU Project Implementation Unit PMU Project Management Unit PVAC Property Valuation Advisory Committee PWD Public Works Department R&R Resettlement & Rehabilitation

RP Resettlement Plan RB Requiring Body RoW Right of Way RV Replacement Value STG Structure Transfer Grant ToR Terms of Reference

Glossary

Affected persons (APs) includes any person, affected households (AHs), firms, or private institution who, on account of changes that result from the Project will have their (i) standard of living adversely affected; (ii) right, title, or interest in any house, land (including residential, commercial, agriculture, forest, and/or grazing land), water resources, or any other moveable or fixed assets acquired, possessed, restricted, or otherwise adversely affected, in full or part, permanently or temporarily; (iii) business, occupation, place of work or residence, or habitat adversely affected, with or without displacement.

Assistance means support, rehabilitation and restoration measures extended in cash and/or kind over and above the compensation for lost assets.

Awardees refers to person with interests in land to be acquired by the Project after their ownership of said land has been confirmed by the office of the respective Deputy Commissioner as well as person with interests in other assets to be acquired by the Project. Compensation for acquired assets is provided to awardees through notification under Section 7 of Acquisition and Requisition of Immovable Property Ordinance, 1982 and under section 8 of Acquisition and Requisition of Immovable Property Act, 2017.

Compensation includes payments in cash or kind for assets acquired by the Project at replacement cost or current market price.

Cut-off date refers to the date after which eligibility for compensation or resettlement assistance will not be considered. Date of service of notice under section 3 of Acquisition and Requisition of Immovable Property Ordinance, 1982 or under section 4(1) of Acquisition and Requisition of Immovable Property Act, 2017 is considered to be the cut-off date for recognition of legal compensation and the start date of carrying out the census/inventory of losses is considered as the cut-off date for eligibility of resettlement benefits.

Displaced persons refers to those who are physically displaced (relocation, loss of residential land, or loss of shelter) and/or economically displaced (loss of land, assets, access to assets, income sources, or means of livelihoods) as a result of (i) involuntary acquisition of land, or (ii) involuntary restriction on land use or on access to legally designated parks and protected areas.

Eminent domains refer to regulatory authority of the government to obtain land for public purpose/interest or use of as described in the Acquisition and Requisition of Immovable Property Ordinance, 1982 and the Acquisition and Requisition of Immovable Property Act, 2017.

Encroachers include those people who extend attached private land into public land or who extend their use of titled land into adjacent non-titled land before the cut-off date. Encroachers will not be eligible for claiming compensation for land assets for the affected area which is an extension to their existing titled land.

Entitlements include the range of measures comprising cash or kind compensation, relocation cost, income restoration assistance, transfer assistance, income substitution, and business restoration which are due to AHs, depending on the type and degree/nature of their losses, to restore their social and economic condition.

Household includes all persons living and eating together (sharing the same kitchen and cooking food together as a single-family unit.

Inventory of losses refers to the assets listed during the survey/census as a preliminary record of affected or lost assets.

Khas land includes to the state-owned land which the government is entitled to both lease out and give away to citizens of the country who do not own land. Khas land is considered as an important livelihood source for the extreme poor and can generate and protect them achieving livelihood, particularly for those with low quality, under-sized and flood prone land.

Non-titled persons refers to those who have no means of recognizable rights or claims to the land they are occupying and include peoples using private or public land without permission, permit or grant i.e., those people without legal right and title to land and/or structures occupied or used by them.

ADB Policy explicitly states that people cannot be denied resettlement assistance those are involved in any way with the land acquired for the development of the Project.

Parcha/RoR is a record of right of a landowner.

Project affected Families include residential households and commercial and business enterprises except CPRs.

Project Affected Unit combines residential households (HHs), commercial and business enterprises (CBEs), common property resources (CPRs) and other affected entitles as a whole.

Project means Chattogram-Feni-Bakhrabad Gas Transmission Parallel Pipeline Project of Gas Transmission Company Limited (GTCL).

Relocation means displacement or physical moving of APs from the affected area to a new area/site and rebuilding homes, infrastructures, provision of assets, including productive land/employment and reestablishing income, livelihoods, living and social systems.

Replacement cost refers to the value of assets to replace the loss at current market price, or its nearest equivalent, and is the amount of cash or kind needed to replace an asset in its existing condition, without deduction of transaction costs or for any material salvaged. The calculation of full replacement cost will consider; (i) transaction costs; (ii) interest accrued; (iii) transitional and restoration costs; and (iv) other applicable costs, if any.

Replacement land refers to land acquired by the Project that is compensated through provision of alternative land, rather than cash, of the same size and/or productive capacity as the land lost and is acceptable to the AP. In this Project, there is no provision for replacement land. However, additional project assistance is allowed in the form CMP as grant to the affected persons to buy land lost to the Project.

Resettlement refers to mitigation of all the impacts associated with land acquisition including restriction of access to, or use of land, acquisition of assets, or impacts on income generation as a result of land acquisition.

Squatters includes non-titled and other households, business and common establishments on land owned by the government. Under this Project it includes GTCL acquired land or government land on which people have their structures or income earning sources.

Structure includes all buildings, including primary and secondary structures including houses and ancillary buildings, commercial enterprises, living quarters, community facilities and infrastructures, shops, businesses, fences and walls.

Vulnerable Households include (i) female headed; (ii) headed by elderly/ disabled people without means of support; (iii) households that are below the latest nationally defined poverty line; (iv) Households of indigenous population or ethnic minority; and (v) landless households or severely affected households subject to the result of social economic survey.

1. Background of the Project

1. Construction of Chattogram-Feni-Bakhrabad Gas Transmission Parallel Pipeline Project includes construction of gas transmission pipeline (181 km) from Selimpur, Fouzdarhat of Chattogramto Bakhrabad of Cumilla with associated 9 (nine) Mainline Valve Station (MLV), one (1) Metering Station and two (2) Town Bordering Stations (TBS) located in three districts; Cumilla, Feni and Chattogram and comprises 11 and 186 mauza/revenue villages.

2. The implementing NGO, DORP will provide services for implementation of Resettlement Plan (RP) and assist in land acquisition & requisition of this project. In order to fulfill the existing and rising gas demand of the country as well as demand of Chattogram district, this project from Chattogramto Bakhrabad via Feni has been taken for construction. The pipeline will pass through Sitakunda and Mirsaraiupazila of Chattogram district; FeniSadar and Chagalnaia upazila of and Nangalkot, Chouddagram, Laksam, Borura, Chandina, Debidwar and of Cumilla district.

3. DORP will provide services for the implementation of Resettlement Plan at the time of construction around 181 km (8 meter width for acquisition and 15 meter width for requisition). It will also provide services for construction of 9 Mainline Valve Stations (25mx35m), 2 TBS (100mx100m), 1 Metering Station (100mx100m), Feni psig Trap & Propose Compressor Station (100mx100m). The pipeline will cross four rivers including associated above ground installations along the RoW. The Project has been prepared with approval of a Resettlement Plan (RP) with the help of consultant having compensation package to address the needs of various group of peoples affected by the gas transmission line construction.

4. The project will primarily follow the existing parallel RoW, an estimated 408.87 acres of land to acquisition and 745.1 acres of land to requisition of agricultural land, homesteads and commercial plots to construct the pipeline. A socio-economic survey was conducted by the feasibility study consultant as per ADB’s guideline to assess the overall project impact, collect baseline data survey on land acquisition, requisition, loss of assets and livelihoods; and for the resettlement planning. The feasibility study consultant had submitted a Resettlement Plan (RP) that was approved by the ADB and AIIB. In the RAP, there was broadly stated mitigation of losses and restoration of socio-economic status of the PAPs.

5. The External Monitoring Expert will review and verify the executing agencies' monitoring information and the progress of resettlement as stipulated in the latest resettlement plan. Assess the effectiveness of the executing agency and implementing NGO in updating the resettlement plan and implementing its requirements, and advise the Executing Agency. Monitor and advise the executing agency on carrying out full and meaningful consultation on the latest resettlement plan. Assess whether the updated restoration and enhancement of living standards of the displaced persons, have been achieved. Take measures to mitigate all vulnerable and non- vulnerable titled and non-titled displaced persons have been implemented in accordance with the requirements of the latest resettlement plan. Advise on any social safeguards compliance issues and design corrective actions in cooperation with the executing agency and consultation with the affected persons. Monitor and assess the implementation of these corrective actions.

2. Purpose of the Project

6. The Government of the People’s Republic of Bangladesh has imported LNG to ease the country’s energy crisis and accelerate economic growth and address the current and future challenges of psig demand. A 36" ODx181.0 kmxl000 psig Gas Transmission Parallel Pipeline from Fouzdarhat of Chattogram district to Bakhrabad of Cumilla district via Feni is under

implementation of construction for supplying surplus re-gasified imported LNG to national gas grid to meet the overall gas demand of the country after meeting the demand of Chattogram areas.

3. Objective of the Project

7. The major objectives of engaging the External Monitoring Expert are to:  monitor implementation of the resettlement plan and prepare periodic external monitoring reports;  review compensation and entitlement activities and verify the result of internal monitoring;  assess whether resettlement objectives have been met; especially whether livelihoods and living standards have been restored or enhanced;  assess resettlement efficiency, effectiveness, impact and sustainability drawing lessons as a guide to future resettlement policy making and planning; and  ascertain whether the resettlement entitlements were appropriate in meeting the objectives.

4. Objectives of ADB Safeguard Policy on Involuntary Resettlement

a. For any ADB operation requiring involuntary resettlement, resettlement planning is an integral part of project design and from the early stages of the project cycle; this operation will be taken into account following the basic principles: (i) Involuntary resettlement (IR) will be avoided or minimized as much as possible and where IR is unavoidable, displaced persons (DPs) will be compensated full replacement close for their losses; (ii) Improve, or at least restore, the livelihoods of all DPs and provide physically and economically displaced persons with needed assistance. (iii) Carry out meaningful consultations with affected persons, host communities, and concerned nongovernment organizations. Inform all displaced persons of their entitlements and resettlement options. (iv) Develop procedures in a transparent, consistent, and equitable manner if land acquisition is through negotiated settlement to ensure that those people who enter into negotiated settlements will maintain the same or better income and livelihood status. (v) Ensure that displaced persons without titles to land or any recognizable legal rights to land are eligible for resettlement assistance and compensation for loss of non-land assets. (vi) Prepare and disclosure a resettlement plan elaborating on displaced persons’ entitlements, the income and livelihood restoration strategy, institutional arrangements, monitoring and reporting framework, budget, and time-bound implementation schedule. (vii) Conceive and execute involuntary resettlement as part of a development project or program. Include the full costs of resettlement in the presentation of project’s costs and benefits. Pay compensation and provide other resettlement entitlements before physical or economic displacement. (viii) Monitor and assess resettlement outcomes, their impacts on the standards of living of displaced persons, and whether the objectives of the resettlement plan have been achieved by taking into account the baseline conditions and the results of resettlement monitoring. Disclose monitoring reports.

5. AIIB Policy on the project Implementation

8. Asian Infrastructure Investment Bank’s objective is to improve economic and social development in Asia by investing in high quality, financially viable and environmental friendly infrastructure projects. Environmental and social sustainability is a fundamental aspect of the Bank’s support for infrastructure development and enhanced interconnectivity in Asia.

6. Bangladesh Government’s Legal and Policy Framework

9. The legal and policy framework of the government of Bangladesh for land acquisition and resettlement underwent reforms over the years. The key legal instrument for Land Acquisition and Requisition is the Acquisition and Requisition of Immovable Property Ordinance (ARIPO), 1982 and the latest and recent Act ‘The Acquisition and Requisition of Immovable Property Act, 2017’. The 1982 Ordinance is considered as a stride towards conceding the fact that government continues to reaffirm its commitment towards creating an enabling policy environment so that the compensation covers: i) land and assets permanently acquired (including standing structures, crops, trees, houses); and ii) any other damages caused by such acquisition.

10. The Acquisition and Requisition of Immovable Property Act, 2017 has come into operation on September, 2017. Through this Act, Government declared a great deal of opportunities to the affected people where they will get more financial benefits to cover their loss of properties and restore livelihoods in the pre-project level or more.

11. The Safeguard Policy Statement (SPS) of ADB requires full compensation at the rate of full replacement cost and livelihood restoration. The Safeguard Policy Statement (SPS) builds upon the three previous safeguard policies on the Environment Policy of 2002, Involuntary Resettlement Policy of 1995, and Indigenous Peoples Policyof 1998, and brings them into a consolidated policy frame work.The SPS applies to all ADB-supported projects reviewed by ADB's management after 20 January 2010.

12. According to 1982 Ordinance or 2017 Act, Deputy Commissioner of the district is the absolute authority to acquire both movable and immovable properties in accordance with the law. Land acquisition is accomplished through administrative instructions. The GOB established District Land Allocation Committee (DLAC) and a Central Land Allocation Committee (CLAC) in 1976. DLAC is responsible for land allocation at the district level, while CLAC deals with land allocation in City. However, CLAC has the authority to review all land acquisition cases before final decision is made at the different levels.

7. Brief statement on acquired properties and affected persons in draft RP

13. The draft Resettlement Plan (RP) has been prepared for the Gas Transmission Company Limited (GTCL) of Bangladesh and the proposed project includes construction of gas transmission pipeline (181 km) from Selimpur, Foujdarhat of Chattogramto Bakhrabad of Cumilla with associated nine (9) Mainline Valve Stations (MLV), one (1) Metering Station and two (2) Town Border Stations (TBS). Construction of Chattogram-Bakhrabad Gas Transmission Pipeline is

located throughout three districts: , Feni and Chattogram. There are 11 /thanas and 186 mauzas/revenue villages1.

14. This draft RP will be updated during the detailed design and final engineering design and route survey which is the subject to further modification and finalization at the later stage during final design and prior to the construction. The purpose of the RP is to mitigate the impacts caused due to land acquisition and involuntary resettlement and to compensate and rehabilitate the displaced persons (DPs)/affected persons (APs). The RP is based on GoB's laws and policies related to land acquisition and involuntary resettlement and ADB Safeguard Policy Statement, 2009 .The draft RP contains the findings of inventory of loss (IoL), surveys of all affected structures, assets and census survey of affected households and persons. Summary details of draft RP of properties to be affected on land acquisition and resettlement impact is given in the Table-1.

Table-1: List of Assets to be Acquired Sl. No Category of loss Unit Total A Land Required for the project Acres 1040.42 A1 Total length of alignment km 181 Total Land for Acquisition A2 (permanent Impact for 8 meters Acres 370.92 1 Private Land for Acres 367.70 Acquisition(Permanent land acquisition for 8 Government Land for Acquisition 2 (permanent Impact for 8 Acres 3.22 Total Land for Requisition A3 (Temporary land occupation for Acres 669.70 Loss of Crop Area due to both B Acquisition and Requisition Acres 980.43 Affected Crop Area due to B1 Acquisition (8 meters) Acres 310.73 Affected Crop Area due to B2 Reacquisition (15 meters) Acres 669.70 Number of physically displaced C1 titled HHs Nos 708 Number of physically displaced C2 population (titled) Nos 3,387 1 Losing residential structures only Nos 632 Losing business/commercial 2 structures Nos 50 Losing residential cum commercial 3 structure Nos 26 Number of physically displaced C3 Non-titled Hhs Nos 84 Number of physically displaced C4 Non-titled population Nos 367

1 Twelve (12) upazilas/ thanas and 191 mouzas/ revenue villages were originally reported in the draft resettlement plan (August 2016) that was prepared by the Feasibility Study Consultant. However, the actual location has been updated to 11 upazilas and 186 mauzas.

HHs losing secondary structures D only Nos 100 HHs losing business only (having E business license) Nos 21 F HHs losing trees only Nos 1 G HHs losing agricultural land only Nos 431 H Number of affected CPR Nos 33 I Private/political offices Nos 4 Sl. No. Category of loss Unit Total J Total affected no-titled Hhs Nos 1382 K Total affected non-titled Nos 100 Encroacher affected by Land 1 Acquisition Nos 7 Squatter (government land) affected 2 by Acquisition Nos 17 Informal settler/Utholi (private land)- 3 affected by Acquisition Nos 76 Total affected population (titled and L non-titled) Nos 5693 Male Affected Persons by 1 Acquisition Nos 3074 Female Affected Persons by 2 Acquisition Nos 2619 M Total affected primary structure sft 781602 Loss of Primary Structures due to M1 Acquisition i Nos 1980 1 Residential structures Nos 17532 2 Business/commercial structures Nos 112 Residential cum commercial 3 structures Nos 100 4 Common property resources (CPR) Nos 15 Loss of Secondary Structures due M2 to Acquisition Nos 1804 Loss of Income for Employees due N to Acquisition Nos 70 Loss of temporary Income for N1 Share/Cropper and farmers Nos 331 Vulnerable Households affected by Acquisition(titled 397+non-titled O 22) Nos 419 1 Female headed house (FHH) Nos 109

2 In the previously prepared External Monitoring Inception Report (September 2018), a typographical error was made and stated that 1953 residential structures were to be acquired. Actual number of residential structures to be acquired is 1753, as stated in Draft Resettlement Plan (August 2016).

Headed by physically challenged 2 people Nos 14 Headed by elderly (above 60 years) 3 people Nos 197 4 HHs below poverty line Nos 99

8. Scope of Works (i) Review and verify the executing agencies' monitoring information and the progress of resettlement as stipulated in the latest resettlement plan; (ii) Assess the effectiveness of the executing agency and implementing NGO in updating the resettlement plans and implementing its requirements, and advise the executing agency about required improvements; (iii) Monitor the INGO’s implementation on Socio- economic-Survey; (iv) Monitoring on the consultation meeting, personal contact, focus group discussion, distribution of leaflets, brochure etc to the affected persons by the INGO; (v) Monitoring on the collection of property valuation assessment by the INGO; (vi) Monitoring on the active participation to assist APs/DPs to prepare their all land and property documents submitting to the DCs office by the INGO; (vii)Monitor and advise the executing agency on carrying out full and meaningful consultation on the latest resettlement plan; (viii) Advise the executing agency on any social safeguards compliance issues and design corrective actions in cooperation with the executing agency and consultation with the affected persons; and monitor and assess the implementation of these corrective actions; (ix)Prepare quarterly, semi-annual/half yearly external social monitoring reports, and submit these to the executing agency and ADB.

8. Methodology of Verifications a. Collection of SES forms to verify these in the field level on random sampling of mouza; b. Personal contact with APs/DPs on random sampling to know the implementation of RAP by the INGO whether distribution of leaflets, consultations, FGD meeting how conducted by INGO; c. Verification of collected present market price by INGO; d. Inspection of INGO area offices and examinations of documents prepared for RAP implementation; e. Verification of notices served by the DCs to APs/DPs for land and properties acquisition; f. Verification of different committees and members formed by the government according the RAP implementation policies.

9. Indicators of Verification  Basic information on displaced persons’ households  Location of the project  Composition and structure, ages, education, and skill levels  Gender of household heads  Ethnic group  Access to health, education, utilities, and other social services  Housing type  Land and other resource-owning and resource-using patterns  Occupations and employment patterns  Income sources and levels

 Agricultural production data (for rural households)  Participation in neighborhood or community groups  Access to cultural sites and events  Valuation of all assets

10.Implementation of Resettlement Action Plan

10.1 Land Acquisition Updating:The following prime responsibilities of INGO are the basis for implementation of the project action plan andif any information is found from, on check households survey and documents verification that are belonging to negligence/omission of the duties of INGO, then it will be reflected in the monitoring report:  Implementation of land Acquisition and Requisition of Chattogram-Feni-Bakhrabad Gas Transmission Parallel Pipeline Project;  The field data collected by the INGO on thebasis of socio-economic survey;  Recordedvideo film of affected properties;  Notices served to the land and properties affected persons from the DCs office;  Market pricecollection rate based on the present price;  Focus group discussion, personalcontact, distribution of leaflets etc.;

10.2 Updating of Resettlement Action Plan (RAP) by the INGO

15. Implementation of resettlement action plan of this project has been assigned on an INGO by GTCL through a competitive bidding process. Contract agreement with the selected INGO was signed on 31.10.2017 and the INGO has managed to mobilize on assignment on 1st January, 2018. The INGO is responsible for overall implementation of Resettlement Action Plan as well as to provide assistance to GTCL in Land Acquisition and technical support. The INGO will identify, inform and mobilize displaced persons eligible for compensation and assistances, prepare AP files, entitlement cards and payment statement and ensure all eligible DPs receive their due compensation and entitlements. The responsibilities of INGO also include coordination with the Deputy Commissioners and assisting the DPs in getting cash compensation under law (CCL) and managing alternative land and housing for relocation. Active participation to provide technical and desk support to JVC, PVAC and GRC remain important tasks of the INGO to encourage the APs/DPs in the resettlement process following the updated Resettlement Plan.

16. From January to June 2018, the engaged INGO performed the following tasks according to the Table-2 for 3 (three) districts under the project area.

Table-2: Tasks Performed by INGO

Description Chattogram Feni Cumilla Total Target Progress Staff recruitment 4 3 4 11 15

Staff orientation 1 1 1 3 3

SES survey 610 536 983 2129 1096

SES data entry 610 536 983 2129 1096

Finalization of the 1 1 1 1 1 alignment

Land market 15 34 101 150 172 survey

Personal contact 270 258 225 753 640

Leaflets 375 450 510 1335 1100 distribution

Joint verification of 47 34 2 83 104 land and property

Video filming 47 - - 47 74

Community - 2 4 6 12 meeting

Notices served 250 553 - 803 803 under section 4(1) of Land Acquisition Act, 2017

Notices served and 26 16 40 82 32 collect for JVC, PVAC and GRC

Collect data and 50 35 - 85 85 compose uma and cha forms

Land and property - 35 101 136 186 valuation survey

FGD meeting - - - - -

Consultation - - - - - meeting

10.3 Socioeconomic Survey

17. The socio-economic survey data collected by DORP about the APs and the entitlements of the HHs, commercial and business enterprises, common resources properties are verified and monitored in the project implementation area during the period January-June, 2018. The following steps and sequence are taken for the monitoring of the SES:

 To assess the personal and community wise impact in terms of all inventory of losses;  To assess the afterward acquisition of negative impacts and identify a number of appropriate suggestions and possible measures to rectify them;  To make alternative programs to enhance the negative impacts on the APs level;  Extensive steps to achieve individual community participation in the resettlement action programs.

18. Methods applied for verification of socio-economic survey are as follows:

 Written SES forms selected on the basis of random sampling of APs (not less than 20%) at mouza wise;  Reviewed understanding of the current status of the APs;  Losses of the property;  Collected the previous data (not less than 20%) by the INGO;  Structured questionnaire to collect information in consultation with the project PMU.

19. Table-3 below shows the field level information at the time of inspection and verification.

Table-3: Field-level Implementation Name of the district No. of APs Found actual information Number to be enlisted in the verified (%) SES list

Chattogram 610 On verification a few no. of APs Targeted 20% but found from the APs list. They are found 3-4 persons unsatisfactory no.

Feni 536 No APs/persons found those are Targeted 20% but enlisted in the SES forms/ lists found none

Cumilla 983 No persons found at the time of Targeted 20% but SES enlisted APs verification found none

Findings of the verification: a. No completed SES forms of the APs were supplied by the INGO; b. SES forms are used by the INGO for data entry and to determine inventory of losses of the affected persons. Normally, the forms are kept in the area offices of the INGO for field use. At the time of inspection, the INGO staff clarified that all of the SES forms were sent to INGO Headquarters in Dhaka for data entry and would be returned to the field offices. c. Found a very few persons who are enlisted in the SES forms (3-4 APs only) at the time of inspection of the project area but found actual APs who are not enlisted in the SES forms; d. APs who are residing in homesteads within the RoW or near the vicinity of the RoW were available at the time of verifications; e. APs who are owner of agricultural lands only could not identify near the project area and the INGO could not able to identify them at the time of verification.

10.4 JVC Collected Information

20. According to the provision of Land Acquisition and Requisition of Immovable Property Ordinance, 1982 and Acquisition and Requisition of Immovable Property Act, 2017, the physical properties of the affected persons within the RoW were assessed by the Joint Verification Committee. The JVC is formed according to the provision of the project:

a. Project Director/DGM of GTCL- Convenor b. Representative of DC-Member c. Representative of INGO- Member Secretary

21. The data and information collected by the JVC was not verified or evaluated during the reporting period January-June,2018, as records are kept in DC office and inspection was done in the districts. The joint verification committee of three districts implemented their verifications as shown in Table-4.

Table-4: Joint Venture Committee

Name of the district Total no of No. of joint verification done No. verified mouza under the by the JVC project area

Chattogram 50 47 The papers are lying with DC office

Feni 35 34 The papers are lying with DC office

Cumilla 101 101 The papers are lying with DC office

Note: The papers are lying with DC office means DC office mainly preserves joint verification reports for any action. GTCL also keeps these records. The INGO only provides assistance to the JVC but does not keep reports onsite.

Findings: a. Joint verification was done by DC office and GTCL with the help of INGO; b. Joint verification in Cumilla was done before appointment of this INGO except one upazilla (Chouddagram); c. Verification was not done, due to unavailability of papers (lying with DC office); d. INGO keeps no records except statement only because JVC records are preserved in the office of DC and GTCL for any action. Joint verification reports include the following: description of land, trees, structures, crops and other properties. This report is followed in the preparation of field book prepared by DC office to take action at the time of CCL payment. e. Joint verification will be verified afterwards collecting the data from the DC offices.

10.5 Collection of Market Price of Land and Property

22. The INGO surveyed market price of different kinds of lands such as; homesteads, non- agricultural land, agricultural land, land involving ponds and water etc to provide additional compensation to the affected people which were evaluated and monitored at an authentic and acceptable condition. The evaluating period was January-June, 2018.To carry out the process successfully, the following methods were observed:  Location (mouza) wise existing market value of lands within this project;  Assess the collected rate to be considered by the PVAC;  To recommend the standard rate of land property to the Implementing Authority;

23. The following data presented (Table -5) on the market price collected by the INGO to be considered at the time of paying additional land value by the project unit.

Table-5: Market Price Collection Rate

Name of the district No. of locations (mouza) Actual no. of No. of mouza verified for collecting land price mouza rate collected

Chattogram 50 15 5 (33%)

Feni 35 34 Papers were not available with the AM

Cumilla 101 101 Papers were not available with the AM.

Note: At the time of inspection, the market price documents collected were sent to the INGO head office in Dhaka for data entry. As a result, the Area Managers were not able to provide the market rate information they collected.

Findings of the verification: a. INGO collected present market price of 15 mouza of Chattogram district and verified 20 persons of 5 mouza and found satisfactory of the collected rate; b. Market price of mouza of Cumilla and Feni collected by the INGO staffs sent INGO HQ at Dhaka for data entry but could not received as yet by the AMs; c. Market price data should be preserved in the area office for the RAP implementation.

10.6 Personal contact with the APs

24. Personal contact is one of the prime duty to the INGO staffs. RAP implementation mainly depends on personal contact. Personal contact helps APs to get leaflets, preparation of land record for field book and CCL payment effectively, ROR change and updating of records of the APs, grievance redress process etc. How the personal contact was done by the INGO is shown in the following (Table-6) from the lists prepared by it and the implementation period was January-June, 2018.

Table-6: Personal Contact with Affected Persons per District

Name of the district Total no. of persons No. of persons contacted by INGO examined

Chattogram 270 65 (24%)

Feni 258 55 (21.3%)

Cumilla 225 50 (22%)

Findings: a. The INGO staffs of 3 districts made personal contact and found the contacted APs satisfactory; b. Every persons examined by me told that the INGO staffs on regular basis comes to them and informed about the progress of the project; c. APs of homesteads under the area of the RoW are well known to them; d. They visited regularly the affected person’s homesteads.

10.7 Distribution of leaflets to the affected persons

25. For RAP implementation, INGO distributed personal leaflets to the APs level. They distributed in three districts for each mouza the leaflets to let the full idea about the project implementation, to let the compensation and other benefits they are entitled at the time of implementation of the project. On random basis some mouza were selected for verification of the APs. The following Table-7 shows the leaflet distribution picture of the project area during period of January-June, 2018.

Table-7: Distribution of Leaflets

Name of the district No. of leaflets distributed by the INGO No. of mouza verified at random selection (%)

Chattogram 375 95 (25%)

Feni 450 100 (22%)

Cumilla 510 115 (22.5%)

Findings: a. Distribution of leaflets at AP level by the INGO is satisfactory; b. INGO does not keep office registers mouza-wise. Upon verification with the INGO’s three area offices, they explained that they distributed leaflets received from the INGO head office. The staff members distributed leaflets to the APs but do not maintain registers. However, they record the number of leaflets distributed. INGO was advised by the External Monitoring Expert to keep a register with the names of the APs. The INGO head office in Dhaka printed the leaflets and sent them to the area mangers for distribution. c. APs are satisfied with the coordination of INGOs communications.

10.8 Video filming

26. Video filming is one of the major tasks of the RAP implementation stage. This function is done by the office of the DCs. Video filming of the RoW indicates the actual situation of the affected person’s status. It reflects the land and all kinds of structures, trees, crops, business enterprises and other properties situated on the acquired land.

The following mouza wise video filming is presented in the table-8 below.

Table-8: Video Filming Conducted per District

Name of the district No. of mouza were Verification of the Duration of RAP in video video filmed mouza video filmed film (January-June, 2018)

Chattogram 47 0 Video filming is done by DC office only

Feni 0 0 Video filming is done by DC office only

Cumilla 100 0 Video filming is done by DC office only

Findings: a. Video filming was done by the DC office only; b. INGO keeps only information. Video filming is done by DC office on land, trees, structures, crops, etc and preserved in DC office for Field Book preparation. These field books are distributed to GTCL, INGO, PWD, DoF, etc for their necessary action.

10.9 Formation of JVC, PVAC and GRC

27. These committees were formed according to the notification of the government circular. Before serving notices to the affected persons, joint verification is required to find out the actual landowner in possession of the land. Proper verification of the land and other properties to be acquired by the DC will help to compensate the actual affected people. There are some rules to form JVC, PVAC and GRC. The Table-9 will show the formation of the above committees.

Table-9: Formation of JVC/PVAC/GRC

Name of the Formation Functions committees

JVC a. Project Director/DGM of GTCL – i. Joint verification of the land and properties situated on that land Convenor

b. Representative of deputy ii. Video filming commissioner- Member iii. Determination of the value of land c. Representative of INGO- Member and all other properties Secretary iv. Preparation of the field book mentioning all the properties attached with it

v. Preparation of award book for CCL payment

PVAC a. Project Director/DGM– Convenor i. The committee will collect local b. Representative of DC- Member current market rate of land, trees, c. Representative of PWD-Member crops, structures, fish, and other d. Representative of UP chairman- properties attached with the affected Member e. Representative of INGO- Member land Secretary ii. Recommend the additional top up value for the compensation to pay for the affected persons, if required.

GRC a. Project Director/DGM – Convenor i. Receive complaints from the b. Representative of DC- Member affected people in the case of any c. Representative of woman member grievance against compensation of the respective upazila chairman- Member ii. Send the case to the project d. Representative of UP chairman- authority, if the complaint can’t but to Member remedy e. Representative of the affected peoples- Member iii. If the case can’t mitigate by the f. Representative of INGO- Member project unit, send the case to GRC. Secretary iv. Recommend to the project authority any remedy to the affected person(s) for justified compensation

28. Verification of the formation of committee and the performance of the INGO: Inspected committees formed in three districts of the Project Area. Government (the concern ministry) circulated notification for formation of the local committees. Accordingly, GTCL sent notification to the respective deputy commissioners, upazila parishad chairman, PWD, union parishad chairman, pourasava, and the INGO to form the respective committees. GTCL arrange to form three committees with the respective representatives of DC, PWD, chairman of upazila parishad, union parishad ,pourasava, affected people and sent to the Ministry.Table -10 will show the formation of the committees of JVC, PVAC and GRC applicable for three district of the Project Area.

Table-10:JVC/PVAC/GRC in Three Districts

Name of the Name of the No. of representatives Comments committee district

JVC Chattogram GTCL-1

DC- 1

INGO- 1

Total= 3

Feni GTCL-1

DC- 1

INGO- 1

Total=3

Cumilla GTCL-1

DC- 1

INGO- 1

Total= 3

PVAC Chattogram GTCL-1

DC- 1

PWD- 1

Union parishad- 19

Pourasava- 3

INGO- 1

Total= 26

Feni GTCL-1

DC- 1

PWD- 1

Union parishad- 8

Pourasava- 1

INGO- 1

Total= 13

Cumilla GTCL-1

DC- 1

PWD- 1

Union parishad- 31

Pourasava- 3

INGO- 1

Total = 38

GRC Chattogram GTCL-1

DC- 1

PWD- 1

Union parishad- 19

Upazila parishad-2

Pourasava- 3

AP - 1

INGO- 1

Total= 29

Feni GTCL-1 No AP member DC- 1

PWD- 1

Union parishad- 8

Upazila parishad-2

Pourasava- 1

INGO- 1

Total= 15

Cumilla GTCL-1

DC- 1

PWD- 1

Union parishad- 31

Upazila parishad-7

Pourasava- 3

AP - 1

INGO- 1

Total= 46

INGO collected the names of members of the committees from GTCL and the performance of INGO is shown below of Table-11.

Table-11: Performance of INGO

Name of the district Notices served and the Verification of the Period of number of representatives of numbers taken all implementation JVC/PVAC/GRC collected by members for the INGO verification

Chattogram 26 16 (40%) January-June, 2018 Feni 16 11 (60%)

Cumilla 40 23 (57%)

Findings: a. Notices served to the DC, PWD and GTCL for nominating representatives were done in the government level; b. Notices served to nominate the representatives of upazila parishad, union parishad, pourasava and affected persons were done by GTCL; c. Nominations of representatives of DC, PWD, INGO, union parishad, pourasava, upazila parishad and affected persons were sent by the respective authorities to the Ministry with copy to the DC and GTCL; d. INGO assisted the respective chairmen in some cases to sent the names of representatives;

e. INGO collected names of all level representatives from the concern GTCL local office and prepared a list of the district committees. f. Some union parishad members who were nominated as representatives by their chairmen, do not know their nominations as yet. g. Local representatives of PVAC and GRC are nominated by DC and GTCL according to the project provision. The INGO prepared lists of local representatives nominated by their organizational chairmen and sent to the DC and GTCL for attending as members of PVAC and GRC. Mobile phone numbers were also provided. At the time of inspection, some of these nominations were not yet verified as some of the representatives of PVAC/GRC did not answer when called on their mobile phones.

10.10 Notices served under the Ordinance of 1982 and new land acquisition Act, 2017 on the affected persons

29. Notice service to the affected persons under section 3, 6 and 7 of 1982 Ordinance and 4, 7, 8 of Act, 2017 are directly applicable to the deputy commissioners of the concerned district. Notices served under section 3 and 6 of Cumilla district is already been completed for 6upazila. Notices served under section 4 and 7 is completed in Chouddagram upazila and Feni district. Notices served under section 4 is completed in Chattogram district. The following Table-12 will show the total picture of notice serving of the project.

Table-12: Notices Served under 1982 Ordinance and 2017 Act

Name of the district Notices served No. of Notices No. of Implementation under section of upazila served upazila period under Land Land Acquisition Acquisition Act,2018 Ordinance, 1982

Cumilla 3, 6 6 4 (1) 1 January-June, 2018 Feni 4,7 2

Chattogram 4 (1) 2

Note: This 1st progress report has been prepared for the period January 2018 to June 2018. Some achievements were made during July 2018 to December 2018 and will be reported in the 2nd progress report.

10.11 Land acquisition process

30. Land acquisition expresses the project authority to avoid any negative impacts due to the project interventions or to mitigate them ensuring the affected people willbe able to maintain or improve their livelihood at the end of the project.

31. The potential impact of economic, social status of PAPs from project activities including land acquisition (include involuntary restrictions) will be identified, such as loss of access to assets

or resources or restrictions on land use, which may be minimized, mitigated, or compensation through the social assessment process. If these impacts are found to be significantly adverse at any stage of the project, the project proponent will be required to develop and implement a management plan to restore the livelihood of affected persons to, at least, pre-project level or better. Land acquisition is activated after creating land acquisition case in the Land Acquisition office of Deputy Commissioner. To implement the land acquisition, the three DCs create several LA cases and subsequently taken for implementation of acquisition.

a. Land acquisition status of three districts under the project area is shown in Table- 13 below during the period January–June, 2018.

Table-13: Land Acquisition Status of DCs Amount of District LA case no. Amount of Field book Notices Notices Award land to be land to be signed book Served served acquired requisition prepare under under (acre) ed section 3 &4 section d (as per 6/7(as per applicable) applicable) Cumilla 8-14/2016- 168.7575 300.3369 Signed Executed Executed Not 17 prepare d Total= 7 nos. Not Feni 1/2017- 18 70.4723 117.6590 Signed Executed Executed prepare 1ka/2017-18 d 1kha/2017- 18 Total=3 nos. Not Chattog 7-8/2017-18 129.203 234.2490 Not signed Executed Not ram executed prepare Total= 2 d nos.

b. Collection of rate of land, structure, trees, crops based on the current market is determined by the JVC. INGO in every case, has to help the Deputy Commissioner collecting government rates of land, structure, trees, crops etc from the concerned Sub-registry offices, Agriculture Extension offices, PWD offices, Fisheries offices.DC determines government rates on land, structures, trees and fruits, crops, fish etc to compensate to the affected persons.

10.12 Consultation, Information Campaign and Participatory Process

32. Consultation and disclosure of information on project resettlement policy, processes and roles of stakeholders are important part of the project management unit with the direct assistance of INGO. Representatives of communities (affected persons) and local government institutes have been involved and participates in Grievance Redress Committees (GRC) and Property Valuation

Advisory Committees (PVAC) to foster an easier implementation process. Consultation, focus group discussion, personal contact, community meetings have been introduced to help the affected persons intheir payment procedure easy. As per the guidelines of ADB and AIIB, GTCL has disclosed the RP in a form of leaflets and entitlement matrix to the local stakeholders.

11. Overall Implementation of Resettlement Plan a. RAP implemented by the Project PIU:The Resettlement Plan (RP) for the Chattogram-Feni-BakhrabadGas Transmission project was prepared and planned to ensure to compensate the displaced persons prior to the displacement and commencement of civil works. GTCL project authority will ensure that no physical or economic displacement of affected households will occur until (i) compensation at full replacement cost has been paid to each displaced person for project components or sections that are ready to be constructed. GTCL under the Ministry of Power and Mineral Resources is representing the Government of Bangladesh as the Executing Agency of the Project. GTCL has established a Project Implementation Unit (PIU) at its HQ headed by a Project Director. A Resettlement Unit is also established within the PIU, which is also responsible for implementation of the RP in terms of compensation disbursement and resettlement of the project displaced persons including livelihood restoration in the process of construction of gas line and resettlement of DPs. b. RAP implemented by INGO: The INGO is responsible for overall implementation of resettlement plan and is headed by a Team Leader whose office is in Dhaka HQ for management of the Resettlement Implementation and provision of direct assistance to the PIU of GTCL gas transmission project. The INGO has also established three Area Offices located in three district areas, one in Cumilla, covering Cumilla district, one in Feni for covering Feni district and last one is in Chattogram to cover Chattogram district. The manpower of the three areas includes one Area Manager for each district and 11 other field staffs for the three Area offices.

33. The following Table-14 will show individual and joint functions by the office of GTCL, DC, INGO and others based on the works completed during the period January-June, 2018.

Table-14: Individual and Joint Functions of DC/GTCL/INGO

Sl Name of the task Joint function Individual function

1 Socio-economic survey - INGO

2 Joint verification DC/GTCL/INGO -

2 Land market price collection DC/INGO -

3 Video filming DC/GTCL/INGO -

3 Field book DC/GTCL/INGO -

4 Personal contact/ community - INGO meeting/FGD /leaflets distribution/consultation with APs

5 Notices service for land titled holders DC/INGO -

6 Formation of JVC/PVAC/ GRC DC/GTCL/INGO -

7 Compose and collection of uma and cha DC/INGO - forms

8 Land and other properties market rate - INGO collection for top up payment

8 Land and properties valuation DC/INGO/PWD/Fisheries - assessment /Agriculture

Note: Joint and individual functions of the three agencies DC, GTCL and INGO are summarized above. These three agencies work jointly, and the records are preserved in DC office and GTCL office. There is no division of labour. In the above table, the INGO has some responsibilities assigned to them by GTCL. The INGO will report to GTCL/DC. INGO’s records are kept in their office.

12. External Monitoring during the period January to June, 2018

34. External Monitoring consists of verifying the status of affected persons, evaluating whether resettlement goals are being achieved, and providing recommendations for improvements of activities performed by INGO and the PIU. After submission of the Inception Report, the External Monitor has twice inspected the field level performance of INGO and the status of the affected persons. The inspection reports prepared based on such inspections have been submitted to the GTCL; this monitoring report has been submitted to ADB with copy to GTCL.

35. The following problems were identified and will reflect overall conditions of the affected persons regarding acquisition of the land and properties during the period of January to June, 2018.

(i) Problems found with INGO: a. Insufficient number of field workers to discharge regular responsibilities along the project site; b. Irregular and insufficient payment of pay and allowances to the field worker by the INGO; c. SES forms filled up by field workers (FW) found incorrect and long pending in the HQ; d. In some cases, the INGO staff did not differentiate between FGD meeting and community meeting and consultation, and conducted meetings under the same procedure; e. Regular progress reports given by the INGO HQ to GTCL authority do not always match with the Area office report; f. Local representatives of PVAC and GRC are not fully aware about the project and the committees;

g. Some unexecuted notices were returned by the process server; notice awardees were then told to get the notices from the DC office itself but they were embarrassed to do so; h. Video filming for trees, structures, and other properties did not contain the all items reported by some affected persons; i. Affected persons are willing to go to the district office with their documents (although the papers not always ready) but due to some communication gaps, it hampers progress and DC office faces problems.

(ii) Problems found in the affected persons level: a. Notices under section 3 and 4 or under section 7 and 8 are normally received by the original landowners who could not hand them over to the subsequent purchasers. It is the land purchaser’s responsibility to enter his name in the register of local land office for updating and to submit their registered purchase document. Until and unless the land purchaser do not go to the land office for mutation in the land office, generally he can’t claim his compensation money from the DC office. b. Affected persons are demanding compensation before start of works; This claim is in normal sense of the APs to the IA. But that do not happen normally after the civil works start. DC made CCL payment before start of the civil works. DC/GTCL obey the ADB’s SPS policy c. Compensation on land, trees, crops, structure is being claimed by APs at a time; ‘At a time’ means the APs general claim is to pay all types of compensation (land, trees, structures etc) together but not one after another. d. In some case, notices served from the DC office were received by one person for a plot of land but other owners are claiming individual notices to be sent to them; f. Persons affected by land requisition are confused why they are not receiving from the DC office the same notices issued to affected persons of land acquisition; g. Sometimes, for co-owned properties, notice is served to one person only but not to the co-owner/s who then question the project authority; h. It may make the compensation disbursement difficult when the acquired land is undivided but one of the heirs is in possession. The issue of who will then receive the money is a question raised in all three sites Feni, Chattogram and Chouddagram of Cumilla.

(iii) Recommendations a. SES forms should be updated by INGO before CCL payment b. Purpose of FGD, Consultation and Community meetings should be individually understood carefully through proper training and then start the meeting works c. Local representatives of PVAC and GRC should be given proper training by GTCL and DC before starting their regular meeting d. Unexecuted notices of the APs may be executed by the INGO staffs for quick response e. DC should visit the project on regular basis and to see the conditions of affected persons whether they are satisfied with the compensation money f. At the time of first notice to the affected persons, DC has to give additional information to them to modify/rectify their land documents without delay g. Joint family land should be identified first by the INGO and then decide who will receive money by DC h. Joint family land notice should be given to each member but in one person

i. When the question is acquisition and requisition simultaneously, then the respective notices should be served after proper understanding of the APs, otherwise, they misunderstand

Submitted by

Md. Abdus Samad Individual Consultant CFBGTPPP