ROYAL GOVERNMENT OF (RGC)

Land Allocation for Social and Economic Development (LASED) Project (Credit No. 44410-KH and Grant No. H3860-KH);

and Associated JSDF-Funded Projects on:

(1) Strengthening Good Governance in Land Distribution Project (TF091833) (2) Strengthening Civil Society-Government Partnership to Deliver Land Tenure Security Project (TF091836) (3) Community Empowerment Through Access to Land Project (TF091839)

Mid-Term Review and Sixth Joint IDA-GIZ Implementation Support Mission October 3-21, 2011

Aide Memoire

I. BACKGROUND

1. Overview. The World Bank (the Bank) Team1 and GIZ Team2 assembled in Cambodia on October 3-21, 2011 to carry out the Mid-Term Review (MTR) and Implementation Support Mission for the: (a) “Land Allocation for Social and Economic Development (LASED) Project”; and (b) associated NGO-implemented social land concession (SLC) projects supported under the World Bank’s Japan Social Development Fund (JSDF) namely: (i) “Strengthening Good Governance in Land Distribution Project” being implemented by Wathnakpheap (WP); (ii) “Strengthening Civil Society-Government Partnership to Deliver Land Tenure Security Project” being implemented by Habitat for Humanity International in Cambodia (HFHI-C); and (iii) “Community Empowerment through Access to Land Project” being implemented by Life with Dignity (LWD).

2. The mission held meetings and discussions in with the: (a) officials of the Ministry of Land Management, Urban Planning and Construction (MLMUPC), National Committee for Sub-national Democratic Development (NCDD); (b) staff of General Secretariat for Social Land Concessions (GSSLC) and Secretariat of the National Committee for Sub-national Democratic Development (NCDDS); (c) representatives and staff of associated partner–NGOs implementing SLC activities/projects; and (d) Cambodian Mine Action Centre (CMAC). Field visits and meetings with officials and representatives at the sub-national level (provincial, district and commune) were also undertaken in the Provinces of: (a) Kratie; (b) Kampong Cham; (c) Kampong Thom; (d) Battambang; (e) Kampong Speu; and (f) Kampong Chhnang.

3. Mission Objectives. The primary objectives of the mission were to review the project implementation progress to date, assess the key achievements and factors affecting progress, and recommend measures to improve

1 The World Bank Team was led by Ms. Mudita Chamroeun (Task Team Leader, EASTS) and included Messrs/Mmes. Steven Schonberger (Lead Operations Officer, AFTAR), Maria Theresa G. Quinones (Senior Operations Officer, EASPS), Sarin Kim (Implementation Support Specialist, EASTS), Munichan Kung (Rural Development Officer, EASTS), Satoshi Ishihara (Senior Social Development Specialist, EASTS), Josefo Tuyor (Senior Environment Specialist, EASPS), Bunlong Lang (Environment Specialist, EASTS), Saroeun Bou (Communications Officer, EACSF), Seida Heng (Financial Management Specialist, EAPFM), Kimhin Sun (Financial Management Specialist, EAPFM), Sreng Sok (Procurement Specialist, EAPPR), Sirirat Sirijaratwong (Procurement Analyst, EAPPR), Latharo Lor (Procurement Specialist, EAPPR), Yasuo Konishi (Consultant, JCTF), Julian Abrams (Infrastructure Specialist, Consultant, FAO-CP), Nuno Santos (Economist FAO; desk review), Jonathan Mills Lindsay (Senior Counsel, LEGEN; desk review) and Narya Ou (Program Assistant, EACSF). Ms. Jeeva A. Perumalpillai-Essex (Sustainable Development Leader, EASTS) and Mr. Luc Lecuit (Senior Operations Officer, EACTF) joined some of the mission meetings. The team also met with Mr. Qimiao Fan (Country Manager, EACSF). 2 The GIZ Team was led by Dr. Franz-Volker Mueller (GIZ Land Team Leader) and included Messrs/Mmes. Dr. Helmut Albert (Head of Section, Agricultural Policy and Rural Areas), Thorben Kruse (Land Rights Program Adviser), Frank Sobek (Chief Technical Advisor, GIZ IP/GOPA), Mr. Phat Phalit (Technical Advisor, GIZ IP/GoPA) and other field staff/consultants. 1 implementation and increase the project’s likelihood of meeting its development objectives, including potential restructuring or reallocation of funds, as well as identifying other operational and technical requirements for possible expansion of the program by the Government. The detailed mission TORs is attached as Annex 1.

4. The mission conveys its sincere thanks and appreciation for the collaboration and support extended to the mission by the MLMUPC3, MOI4; GSSLC; and NCDDS. The mission would also like to thank the local authorities and officials in the provinces, districts and communes visited; GIZ and GIZ contracted IP/GOPA Field Teams; WP; HFHI-C; and LWD for their cooperation, support and active participation in the mission activities.

5. This Aide Memoire summarizes the mission’s overall assessments of the project performance, including key lessons learned, highlights the key issues and risk which require prompt attention by the Government’s Implementing Agencies (IAs) at different levels, and presents the agreed Action Plan to address the identified issues. This Aide Memoire is subject to the confirmation of the World Bank Management.

II. ACHIEVEMENT OF PROJECT DEVELOPMENT OBJECTIVE (PDO)

6. Continued good progress has been made by the project towards achieving its PDO given the current level of implementation progress, and the updated risk assessment which confirms that risk identified have been successfully mitigated so far and a need to continue to close monitoring. The project’s relevance has likewise been re-confirmed as it is one of the components of the government’s sub-sector program on land distribution, as manifested in the priority given to the implementation of other Government Social land Concession (SLC) Programs nationwide. The SLC processes piloted under the project function well for registering land for SLCs which have resulted in the achievement of the following outcome indicators. Please see Annex 2 for the details of the Results Framework and Monitoring, and Annex 3 for the details of the review of the Critical Risks and possible controversial aspects identified in the Project Appraisal Document (PAD).

(a) Adoption of improved soil management and agricultural production systems. Close to 100% (MTR target is 40%) of land recipients who have settled in the first four sites are into backyard and agricultural farming, using improved agricultural technology learned in their previous life with labor force selling, and the training and technical assistance provided by GIZ and the sub-national agencies. To date, around 1,044 hectares have been planted with annual and permanent crops – with cassava (74%) as the most popular crop due to its high demand and good price in the market. Oher crops planted are rice, beans, corn and tree crops.

(b) Selection of land recipients according to the agreed criteria. All the land recipients (100% vs. MTR target of 90%) in the first four sites were selected based on the agreed criteria stated in the Project Implementation Manual (PIM). The same selection process and criteria will be adopted in the succeeding sites.

(c) Adoption of dispute resolution mechanism. A total of 331 complaints were registered regarding the selection of beneficiaries through the official complaint handling mechanisms. The complaints constitute about 7% of the total number of applicants. All (vs. MTR target of 70%) have been carefully reviewed following the provisions in the PIM. Of the cases filed, 42% have been fully addressed, while the rest were dismissed as these refer to complaints from applicants who were not qualified to get lands as per the criteria, but still insisted to be part of the project and thus lodged these complaints. Wathnakpheap (a JSDF- partner Local NGO) has also helped in the dissemination of the dispute resolution process, and assisted the complainants in preparing documents and/or lodging complaints. Continuous efforts to address complaints and information dissemination to the wider public will be critically important.

3 The Kick-Off and Wrap-Up Meetings were chaired by H. E. Prak Ham (Secretary of State, MLMUPC). 4 The mission met with H.E. Ngan Chamroeun, Deputy Director General, General Department of Local Administration, and Deputy Head of NCDDS, Ministry of Interior 2

III. LESSONS LEARNED

7. The mission worked closely with the RGC, commune officials, land recipients, JSDF-partner NGOs, GIZ and other stakeholders to identify key lessons learned from the LASED implementation experience to date (Annex 4). The Bank mission acknowledges the rich documentation prepared by GIZ on the lessons learned. All these lessons are intended as input in the continued LASED implementation and sustainability of initial gains, as well as to the on-going and planned SLC and related activities of the RGC and its partners. The lessons learned indicate that LASED is on-track in terms of demonstrating the feasibility to implement the processes of transparent and participatory land and beneficiary selection, and provision of assistance to land recipients. However, the ability to sustain and scale-up these activities depends on the following:

(a) Further refinement of the procedures and framework for SLCs. LASED has demonstrated that clear operational processes, based on RGC legal framework, combined with effective communication and transparency can bring national and local level authorities, communities, NGOs and development partners into a common, collaborative Government-led effort to support poverty reduction with better results for the target group – even in the traditionally conflictive domain of land management. However, for further scaling up, it will be helpful to review the experience of LASED regarding land screening and identification, target land recipient selection and rural development investment, including that of other national and locally-initiated SLCs to identify opportunities to streamline and simplify procedures while maintaining the high level of transparency and participation of stakeholders. Such may require adjustments to the current regulatory framework for state land management and SLCs.

(b) Ensuring that SLC land rights are effectively protected from new claims and encroachers. LASED is demonstrating that the provision of land to the poor, even with relatively limited additional support, can be an effective mechanism for poverty reduction through economic growth. Land recipients are working hard to quickly convert their land into productive farms which can move them relatively rapidly to food security and beyond to income generation which contributes to agricultural sector growth and diversification. However, the willingness of land recipients to continue to invest in their land is dependent on demonstrating that their tenure security will be protected from any new claims or from the continuing encroachments on the LASED-SLC sites.

(c) Greater predictability in confirming the allocation of state lands to SLCs. LASED has demonstrated that RGC can utilize formal, transparent, consensus-based approach for identifying and transferring state land to SLCs. However, the ability to scale-up this experience is unclear given the continuing challenges in reaching consensus on the allocation of state land from current claims and management to SLCs, both at commune and the national level.

8. In view of the above lessons learned, it was agreed that the national project team (GSSLC and NCDD) as well as the LASED sub-national level will be organizing a workshop in the first quarter of CY2012, to discuss in detail the above and come up with an action plan aimed at improving the sustainability and scaling-up of these activities.

IV. HIGHLIGHTS OF LASED PROJECT IMPLEMENTATION

9. After a slow project start-up, the mission is pleased to note that project implementation has improved with significant activities implemented since the December 2010 mission, including implementation of all the 15 key actions that were agreed during the last mission. Around 40% of the component indicators have been fully achieved and the rest are likely to be achieved (except for the target number of communes). The Bank mission highly appreciates GIZ’s continuous technical assistance and additional investment support in the pilot sites such as cash for work, preparation of land, access tracks and agricultural inputs. These have been crucial in the development of the communities and their agricultural production activities, especially during the time that delays in mobilizing and utilizing IDA funding were encountered. (Annexes 5 and 6). The ability to successfully complete implementation within the remaining 18 months of the project will require a strong focus on effective coordination and 3

implementation of procurement planning, bidding document preparation and execution of procurement procedures for infrastructure, goods and services for the SLC sites. It was agreed that the national project team (NCDD and GSSLC) and the World Bank Team (TTL, Procurement Specialist and Financial Management Specialist) will meet weekly to review progress in procurement and identify any bottlenecks which could impede progress towards completion.

A. COMPONENT 1: COMMUNE-BASED SOCIAL LAND CONCESSIONS (SLC) PLANNING AND LAND ALLOCATION

10. Status of LASED-SLC Sites. A total of 6,850.59 hectares (68.5% of target) has been registered as state private land in five communes, with a total of 1,614 land recipients (54% of target). Majority (98%) of these were sourced from degraded forest lands, with the remaining 2% from recovered illegally occupied lands. Several attempts were made to register lands from cancelled economic land concessions (ELC) but have not been successful to date. The registered sites have submitted their SLC plans to their respective Provincial Land Use and Allocation Committees (PLUAC). The processing of the sixth and seventh communes (with estimated 4,048 hectares and 1,500 land recipients) is ongoing and is expected to bring the total area to more than the targeted 10,000 hectares and 3,000 land recipients. However, the target of 20 communes cannot be achieved as the existing sites were much bigger than originally expected in terms of area covered as well as the number of land recipients. Nevertheless, another two sites are being proposed in Kratie Province5 which may possibly increase the number of communes to nine. The decision on these two sites, however, will greatly depend on the funds and time remaining to the project. Below is the summary of the seven firmed-up LASED-SLC sites:

Table 1. Status of SLC/LASED Site Processing (Identification, Screening and Registration) As of October 10, 2011 SLC/LASED Site Estimated Actual Area (Proposed and Actual) Status of Processing Potential Area Registered (has.) & (has.) No. of Recipients A. KRATIE PROVINCE*: 1. Chet Borey District, Changkrang Land registered as state private land on July 10, 2007 for 612 612 Commune SLC/LASED use. (331 recipients) 2. Chet Borey District, Sambok Land registered as state private land on July 10, 2007 for 3,294 3,294 Commune SLC/LASED use. (554 recipients) 3. Chet Borey District, Dar Commune Land registered as state private land on September 20, 617 572 2010 for SLC/LASED use. (in the process of selecting recipients) 4. Chet Borey District, Thmei Undergoing land identification process. 1,015 (in the process of Commune selecting recipients)- 5. Prek Prasab District, Chambak Undergoing final land screening and review at the 1,500 - Commune national level. B. : 1. , Choam Kravien Land registered as state private land on August 17, 2007 863 863 Commune for SLC/LASED use. (250 recipients) C. : 1. , Tipo Commune Zone 1: 1,508 hectares registered as state private land 3,025 1,508 on May 21, 2010 for SLC/LASED use. (479 recipients in Zone 2: Undergoing land registration process (about Zone 1 only) 1,533 hectares with 300 target land recipients). TOTAL: Seven (7) 10,926 6,850.59 (1,614 recipients)

5 Two additional SLC sites were proposed by Kratie Province during the mission. These are: (a) Prek Prasab District, Soab Commune (2,601 hectares) which is undergoing final land screening and review at the national level; and (b) Chetr Borei District, Kantuot Commune (1,000 hectares) which was already submitted by the Commune Council to PLUAC. 4

11. UXO Clearance. The Cambodian Mine Action Centre (CMAC) has completed in May 2011 (under a 9- month contract) the removal of UXOs in the LASED-SLC site in Memot District, Choam Kravien Commune (Kampomg Cham Province). The cleared area totals to 867.65 hectares wherein 10 personal anti-mines, 2 tank anti-mines, 2,707unexployded bombs and 128,976 pieces of fragments were found, removed and destroyed. Upon the completion of UXO clearing activities in the area, the land recipients have immediately established their houses and started cultivating the agricultural lands awarded to them. While CMAC has assured that the LASED-SLC site as safe, they have indicated that surrounding areas may still be contaminated with UXOs. Information campaigns on these and the risks of UXOs were conducted by CMAC to the LASED recipients. Nevertheless, it was agreed that in collaboration with CMAC, the project team at the sub-national level (led by the Provincial Safeguards Focal Person) will ensure that information campaigns continue to remind the land recipients of potential risks in areas surrounding/outside the LASED-SLC site.

B. COMPONENT 2: RURAL DEVELOPMENT SERVICES AND INVESTMENTS

12. Technical Services and Investment Support. Activities under this component have started to pick up to support the 1,243 households that have settled in the first four sites. In addition to the support provided by GIZ during the initial years of project, all the settled households (100% of target) have been provided with food for work (835,250.5 kilos of rice), residential starter kits (1,282) and agricultural starter kits (1,564). A total of 4,306.3 hectares have been distributed to 958 households who were provided with agricultural and residential lands with a total area of 2,901.3 and 839.4 hectares, respectively. As indicated above, some 1,044.3 hectares have (36%) have been planted to annual or permanent crops, with 74% planted to cassava.

13. In terms of public infrastructure and services, 14% (target is 80%) have so far been provided based on the investment plan, with the rest either under construction or still being procured. These came from LASED, GIZ and other private individuals, and include the following: 47 kilometers of all weather road or late-rite roads, 159 access tracks, 55 pump wells, 114 open wells and 18 ponds. Health posts, primary schools and community market places are under construction (about 40% completed). The mission reviewed the technical design and specifications of some of the infrastructures and found them generally appropriate. The 6-kilometer access road to SLC site in Tipo (currently under procurement) has been damaged by the flood due to heavy rainfall and has been impassable by car or motorcycle for several weeks already. Even in a normal wet season the road would likely to be extremely difficult for any type of motor vehicle. This finding strongly supports the decision to allocate funds for construction of the access road.

14. Capacity building and technical assistance training were also provided. Various types of livelihood improvement related training were provided through 207 sessions by 8 technical line departments, GIZ, and NGO partners. During the mission, some backyard and agricultural farms were visited which show the adoption of intercropping technology learned from the training activities conducted as well as based on their experience as farm labor force. It is estimated that more than 50% of the land recipients in Kampong Cham and Kratie SLCs have generated income from their first harvest, even though the land is not yet 100% cultivated.

15. Assessing the Minimum Threshold Land Clearing Required to Support Livelihood Activities. The LASED economic analysis was recalculated taking into account that households are more likely to focus on cash crops (particularly cassava) than on self-sufficiency food crops (mainly rice). The analysis shows that this approach accelerates their ability to escape poverty with incomes on a single hectare of land in the first year, typically reaching 3 to 5 million Riel in the first year on one hectare of land and 7 to 10 million Riel if agriculture is expanded to the additional land area in the second and third years – an income which puts a typical family well above the poverty line. However, to mitigate the price risks associated with short term cash crops, the analysis emphasizes the importance of introducing medium and long-term crops (such as cashew, rubber and pepper) in order to diversify on-farm income opportunities. Specifically for the LASED-SLC sites which are currently under production, the effectiveness of land distribution as a means to combat poverty appears highly effective but some level of initial land preparation (typically 0.5 to 1 hectare) is needed to permit sufficient income in the first year to avoid indebtedness and provide the basis for expanding cultivation in subsequent years. (Annex 7).

5

16. Flood. The mission is concerned of the continuing flooding in some of the sites in Kratie and Memoit. The flooding did not affect the residential areas of the land recipients; however, the heavy rains affected and damaged the farm lands mostly planted to cassava. Initial request to supply rice to about 484 households in Kratie (i.e., one bag of 50 kilos per household for the first round and two bags until end of the year). In addition, 60 households in Kampong Thom (Tipo) were severely affected and have requested two bags of rice support each. It was agreed that the project will send a report by October 31, 2011 on the impact of the current floods on the infrastructure and agriculture production at the LASED-SLC sites.

C. COMPONENT 3: SUSTAINABLE AND TRANSPARENT SLC PROGRAM DEVELOPMENT

17. SLC Knowledge and Experience Sharing. The mission is pleased to note that the knowledge and experience of LASED stakeholders in the three provinces have improved in terms of the legal, technical and operational aspects and procedures of SLC implementation. The LASED experiences have also been shared and adopted in other SLC programs of the government such as those for retired national armed forces, families of soldiers patrolling the border, etc. Some NGOs have likewise approached the JSDF-assisted NGOs to learn from their implementation experience.

18. Implications to LASED re Transfer of Functions from PRDC-ExCom to the Provincial Administration (PA). Under the first three-year implementation phase of the National Program for Sub-National Democratic Development (NP-SNDD), the project finance and administration functions of PRDC-ExCom are being transferred to the PA. Under the authority of the Provincial Governor, the Finance Division of the PA will manage an account denominated in US Dollars known as the “IP3 account” and can potentially manage additional project accounts. The Planning and Investment Division of the PA will manage sub-contracts between the PA and line departments or lower level authorities (District, Municipality, Commune or Sangkat). The NCDDS Finance and Administration Manual will remain in force to govern these arrangements, although a review of the manual is in progress. In most provinces, sufficient staffs have been transferred from ExCom to the PA to ensure that the Finance and Administration Manual procedures would continue to be implemented. The “IP3 Advisory Team” contracted by NCDDS, which is led by a Provincial Program Management Adviser and includes Provincial Finance Adviser in each province, can provide advisory services on projects funded through NCDDS or those that are considered to contribute to the aims of the NP-SNDD.

19. The Sub-decree establishing the PRDC-ExCom structure has not formally been rescinded. However, the mission met with the LASED Team and discussed the project implementation arrangement as per the NCDD Letter No. 315 issued on August 11, 2011 (Annex 8). It is also observed that changes at the sub national level do not have significant impact on the current operation of LASED as: (a) LASED FM staff at the provincial level are mostly the existing staff and being financed by the POC with support from the consultants, although the reporting and responsibilities on withdrawal from bank accounts and approval on payments are under the PA structure as described above; (b) the FM and Administration Manual of NCDDs has been so far adopted by LASED and which will be continued until further update is in place; (c) accounting software - LASED has used the same accounting software as NCDDS and ExCom since the start and this will also be continued; and (d) Chart of Accounts (CoAs) - using the existing CoA's structure and coding of NCDDS. It was agreed that NCDDS will provide the Bank updates on any change as a result of NCDD Letter No. 315.

20. Priority Operation Cost (POC). The mission reviewed and discussed the approved POC and noted that the staff recruitment process for POC was completed in August 2011. A total of 66 staff (10 and 8 staff from GSSLC and NCDD national level, respectively; and 16 staff each for the three LASED provinces at the sub- national level) are receiving POC, majority of whom are the existing staff who continue to work for the project after the cancellation of MBPI scheme. The mission confirmed that these staff would be eligible for retroactive financing starting May 12, 2011 (i.e., the date that the Bank provided NOL on the POC scheme), except the newly recruited staff who would be eligible for POC based on their contract effectiveness. The project also received a request from CAR (Letter No. 112/11 dated June 27, 2011) regarding the evaluation of the POC practice in LASED. The mission acknowledged the Government’s initiative and ownership in monitoring the POC implementation. However, given that the POC for LASED was only approved in May 2011, the project was 6 eventually agreed to be excluded from the evaluation. The project shall ensure that there is a mechanism in place to monitor attendance of staff under POC scheme and to manage their performance. Nevertheless, the supporting documents for the POC payments, including the retroactive financing, shall be appropriately maintained by each implementing agency for subsequent monitoring and audit. The mission has confirmed that the POC can be allowed to continue until the project closing date (June 2013), however, such should be requested by the RGC if it decides to continue availing of the POC.

21. Good Governance Framework (GGF). The mission received briefing about the implementation of non- fiduciary part of the GGF which was confirmed as being applied to the project adequately. NCDD and GSLLC have engaged their respective Good Governance Focal Persons who would be in charge of collecting and compiling project monitoring data, as well as visiting the project sites on a monthly basis. (Annex 9). The project reported that they occasionally receive informal complaints from some SLC beneficiaries who have received less favorable lands than other beneficiaries. These complaints were eventually withdrawn when it was pointed out that the land was allocated based on a lucky draw process. Nevertheless, it was agreed that a report on the types and number of complaints which are disaggregated per their nature, locations, current status, etc., will be compiled and submitted to the Bank by December 31, 2011.

D. COMPONENT 4: PROJECT ADMINISTRATION

22. Overall Project Management and Administration. The mission is pleased to note that the overall project management and administration continue to improve. There has also been improvement in the collaboration as well as communication among LASED Team at all levels, including increased ownership of the project at the sub- national level. However, the mission reiterated the importance of further improving and sustaining the collaboration as well as communication among the LASED stakeholders. In this regard, the following have been agreed: (a) LASED Team to proactively coordinate with the relevant oversight and line ministries/agencies to identify and agree on means to accelerate implementation progress, including processing of the proposed SLC sites, as well as procurement, financial management and safeguards concerns; and (b) LASED to reactivate monthly project management meetings with the project stakeholders (concerned agencies, NGO partners, Bank and GIZ) starting November 1, 2011 to address issues concerning the implementation of the project and the phasing out of the GIZ Technical Assistance Program in February 2013.

23. Monitoring and Evaluation (M&E). An advance M&E mission was carried out in May-June 2011 by WB/FAO-CP and found that the overall staff capacity on M&E was sufficient. However, the system was constrained by insufficient data collection and analysis, below optimal progress reporting and limited impact evaluation activities. The advance mission helped the project develop a more systemized data collection and developed excel based database to track key output data related to project beneficiaries. This is currently being put to use by the provinces and GSSLC with emphasis on ensuring consistency of information reported at the provincial and national levels. The mission strongly recommends that the data collected through the M&E mechanisms be actively used in developing and updating as relevant the Annual Work Plans since they will provide first-hand information about the changing situations in SLC sites.

24. As for impact evaluation, it is recommended that the project continues a small questionnaire annual survey of LASED beneficiaries and non-beneficiaries to improve knowledge on the impact of LASED on agricultural production in the sites and the economic situation of the land recipients living there relative to comparable non- beneficiaries and also complement other data gathered and impact evaluation activities conducted by GIZ (such as the PEDOS surveys). This could be contracted to a local research organization or university. This would facilitate reporting against the agreed LASED results framework. (Annex 10)

25. Procurement. There has been some improvement in the procurement since the last mission with the completion of some of the packages and progress in the contract processing in the first three sites. The mission appreciates the project's efforts to overcome the backlog. However, there is an urgent need to accelerate the remaining procurement, including those in the additional LASED-SLC sites, particularly with regard to agriculture

7 start up and housing support packages. It is important that this level of improvement is sustained and that conscious efforts are always made to ensure that all packages are carefully prepared considering both technical and procurement requirements, including large packages that would be procured by LASED-NCDD and NCDD through the International Procurement Agent. In addition, some flexibility had been approved during the mission as regards the procedures and documents for the procurement of goods by the Commune Councils, within the applicable threshold. (Annex 11)

26. Financial Management and Disbursement. These continue to work well with adequate staffing and internal control. The audit opinion on the project’s financial statements is “unqualified” (clean) and no significant internal control weaknesses were reported in the audit management letters. As of September 30, 2011, the cumulative disbursements including the Designated Account (DA) balances for IDA grant and credit amount to US$3.63 million (31.45%). In addition, there is about US$3.39 million (29.38%) which represents estimated expenditures for October-December 2011, plus commitment balance (composed of contracted but not yet paid and procurement packages that are expected to be signed by the end of 2011). Furthermore, given the indicative budget for the last 18 months of the project (US$3.09 million or 26.80%), it is estimated that US$1.08 million will be available for further utilization under the Sub-grants category. Participatory planning and prioritization should be done with all stakeholders to ensure that the remaining budget is best allocated to the high priority and high impact activities. This amount will also need to be incorporated in the next AWPB referred above. (Annex 12)

Table 2. Summary of Disbursements in US$ (as of September 30, 2011) Undisbursed Balance Estimated Expenditure and Commitment (from Client Connection) Balance up to the End of 2011 Estimated Total Disbursed Fund Balance of Packages Funding Closing Allocated Balance Estimated Balance Signed Expected Source Date Amount (from Client Expenditure for the Amount % Contract to be Connection) (Oct.- Dec. Remaining but Not Contract-ed 2011) 18 Months Yet Paid by End 2011

IDA Credit No. 30-Jun-2013 2,805,000 203,859 2,601,141 92.73% 963,558 1,637,583 44410

IDA Grant No. 30-Jun-2013 8,745,000 3,428,987 5,316,013 60.79% 559,651 896,734 963,558 2,886,518 H3860 Total IDA 11,550,000 3,632,846 7,917,154 68.55% 559,651 896,734 1,927,116 4,524,101 Credit & Grant

27. Annual Work Plan and Budget (AWPB) for 18 Months. Further improvement is required in the timely preparation and approval of consolidated AWPB. Delays had been experienced due to turnover of key staff and consultants which negatively impacted on the project implementation. It is important that timely preparation, approval, execution and monitoring of the AWPB are strictly adhered to. It was agreed that the next consolidated AWPB, jointly prepared by the NCDD and GSSLC, will cover the remaining 18 months of the project (January 2012 - June 2013) and shall be submitted for the Bank’s review and consideration by December 5, 2011.

28. Following the MTR review mission GSSLC and NCDDS should move quickly to finalize and adopt the updated and simplified PIM that was agreed in principle earlier in 2011, and send to the Bank for no objection not later than November 15, 2011.

E. OTHER CROSS-CUTTING CONCERNS

29. Environmental Safeguards. The LASED-SLC sites comply with the environmental procedures and guidelines. As indicated above, all the four approved sites as well as the three proposed additional sites in Kratie are verified by the mission as primarily (98%) sourced from degraded forests, with the rest from recovered illegally occupied lands. The mission notes that the early process of participatory land use planning process proved to be effective in ensuring the proposed LASED-SLC sites are sourced from degraded forests and in delineating remaining forest areas within the sites. 8

30. The environmental impacts from constructing community infrastructure were validated to be negligible and temporary. These have also been mitigated through including environmental and house-keeping measures (i.e. Environmental Management Plan) in both the design and contracts. A concern, however, in the established LASED-SLC sites is providing latrines (individual or communal) to improve sanitation and avoid contaminating shallow wells, which are used by the beneficiaries for drinking. In addition, the mission strongly suggests implementing the LASED-SLC management activities such as agro-forestry, enrichment planting, assisted-natural focusing in the remaining forests and green buffer zones. These are important to not only enhance the vegetation cover but also to arrest encroachment and agricultural expansion in the remaining forests and to lessen the pressure on the remaining forests from unsustainable harvesting of forest products. (Annex 13)

31. Involuntary Resettlement (OP 4.12). Overall, the project was found to have been implemented in line with OP 4.12. The selection of beneficiaries seems to have been conducted in a transparent manner and they were sufficiently informed of the rights and responsibilities associated with moving to sites. The mission did not find any evidence that the beneficiaries moved to sites under coercion or against their will. No SLC beneficiaries have reportedly left the land permanently. However, the mission recommends that the M&E system also monitors this.

32. As noted in the previous mission, some informal residents were residing in the current sites prior to the project cutoff date. They were allowed to continue staying in or near the SLC territory, but with their areas excluded from the registered SLC site. The informal residents interviewed during the mission indicated that they also benefit from the infrastructure built under the project and maintain relatively favorable relationships with beneficiaries. The mission was further informed that no involuntary land acquisition or loss of access has been necessary for the construction of access roads in Choam Kravien and Tipo sites, while improved efforts have been made to ensure that appropriate livelihood support is provided on a timely manner. (Annex 14)

33. Indigenous Peoples (OP 4.10). The mission observed that the guidelines regarding avoidance of land, predominantly occupied by indigenous peoples (IP) population, as part of project sites have been met. The project did not also find evidence that IP applicants were discriminated against in the selection processes or failed to receive project benefits. The selection criteria include multiple objective criteria against which a team assessed the eligibility of applicants, and therefore is technically difficult to systematically discriminate against IP population as social groups in the selection process.

34. The mission was informed that some SLC beneficiaries in Kratie belong to two IP groups: (a) Mel people (10); and (b) Phnong people (50). The mission talked with some of them who confirmed their support to the project. They were well informed of SLC principles prior to the application and selection of beneficiaries through consultation meetings conducted in which they participated together with local Khmer population. They maintained that they had little difficulties understanding Khmer. The relationship between IP beneficiaries and other Khmer beneficiaries in the same SLC site seem to be favorable. According to the official data in January 2010, a few villages in Sambok commune are predominated by ethnic minorities, implying that there are IP communities in project areas. OP 4.10 thus has to be triggered in this site. Nevertheless, based on the interview with the project staff, the mission considers that all but one condition laid out in the project Indigenous Peoples Policy Framework has been met. i.e., disaggregation of demographic and other data according to ethnic background. Nonetheless, it was agreed that the Government will provide the Bank by December 31, 2011 a short report on activities conducted in the past in relation to ethnic minorities. (Annex 14)

35. Gender. The project has conducted several gender mainstreaming training activities which were attended by about 3,100 beneficiaries, half of them women. Other training courses were provided and attendance of women was always encouraged. The mission also observed female participation during mission visits which is a good indication of gender involvement in the project. The delay in the provision of livelihood support including land clearance may mean that many women needed to spend additional time for securing enough food for their families, in addition to typical household chores. Nevertheless, the mission had an impression that the move to LASED-SLC sites had not affected women’s role in the household negatively, even though they may have undergone some difficulties initially. The mission suggests that continuous capacity development activities are conducted, including 9 livelihood training and those building on the skills the women have (handicrafts, etc.) to further empower female beneficiaries and also help stabilize the livelihood of beneficiary households. (Annex 14)

36. Communications Strategy. The mission is pleased to note the continuing conduct of the various communications outreach activities which have been very effective and have helped in the implementation and dissemination of project activities and results. The newly-engaged provincial-based Communications Officers will coordinate closely with GIZ, JSDF-assisted NGOs and the Bank in the development and dissemination of important information, education and communication (IEC) materials for the project through workshops, small group meetings, radio, mobile dissemination, leaflets, posters, quarter bulletins, comic books, and websites. They will also work on capturing success stories and lessons learned, organizing media coverage and bringing emerging issues to the project management. However, to further improve the IEC activities and strategies, the following are recommended to be given immediate attention: (a) provision of necessary communications equipment to the Communication Officers; (b) strengthening the capacity of the communications team; (c) further development of IEC materials such as quarterly bulletins, leaflets and posters, including tapping of relevant websites where LASED information, results and outcomes can be posted; and (d) working more closely with the operations team and JSDF- NGO partners to monitor, evaluate and handle emerging issues. The Bank’s Communications Officer will meet with the LASED Communications Team in November 2011 to discuss the preparation of the 2012 Communications Action Plan. (Annex 15)

V. JSDF-SUPPORTED NGO ACTIVITIES ON SOCIAL LAND CONCESSION

37. The LASED Project is considered an innovation that supports the Government’s efforts to distribute land to the landless and the land-poor. Given the complexities and risks of land distribution, some grant funding from the JSDF was sought to support and test various methodologies, including strengthening good governance, strengthening civil society and government partnership, and empowering communities to access lands. As part of these initiatives, the three JSDF-supported NGOs (Wathnakpheap, Habitat for Humanity International – Cambodia and Life with Dignity) conduct regular monthly meetings and NGO-Government quarterly meetings to strengthen coordination and effective sharing of lessons learned. (Annex 16)

A. WATHNAKPHEAP (WP)

38. Implementation Status. WP continues to provide public awareness and capacity building support on civic engagement and SLC processes and procedures to the LASED Project in Kratie and Kampong Cham Provinces. In the remaining months of the project, they will expand their services and activities in Kampong Thom Province using their remaining grant fund under the Bank-managed JSDF trust fund. Their involvement in the project had been highly appreciated by the government and land recipients as they have helped facilitate better understanding and participation by the various stakeholders at the sub-national levels, especially the target land recipients. As part of strengthening good governance, transparency, and accountability in the LASED Project, several public forums have been organized at the village/commune levels to educate and help the land recipients and the rest of the communities on the project’s complaints and dispute resolution mechanism. As indicated above, given the pilot nature of the SLC processes, WP together with the two other JSDF-assisted NGOs (LWD and HFHI-C), GSSLC and NCDD have organized regular coordination workshops to share experiences and lessons learned as regards their achievement, issues and challenges encountered in the SLC pilot implementation. This established coordination has helped in the improvement of the project’s implementation strategies and approaches which have been incorporated in the LASED Updated PIM.

39. Procurement. The procurement of goods in Kratie and Kampong Cham Provinces had been completed. These were all in accordance with the agreed guidelines and procedures. It is important that procurement in Kampong Thom Province is commenced immediately, especially given the forthcoming closing date of the grant. It was agreed that an Updated Procurement Plan (using the procurement tracking form), incorporating the procurement in Kampong Thom Province, will be submitted for the Bank's prior review and no objection by October 21, 2011.

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40. Financial Management. Total disbursements to date amount to US$361,079 (77%). All, except two of the required mitigation measures as a result of the FY 2010 qualified audit opinion, have been implemented. It was agreed that WP will implement these two remaining actions which include the recruitment of: (a) part-time internal auditor (using savings under the consultants category); and (b) consultant for capacity building of the FM staff (using WP funds), by not later than end of December 2011. Table 3 below shows the cumulative disbursements for the grants. (Annex 12)

Table 3. Summary of Disbursements (as of September 30, 2011) Disbursed Undisbursed Balance Total Allocated Balance (US$) (from Client Connection) Funding Source Closing Date Amount (from Client (US$) Connection) US$ % JSDF TF 91833 (WP) 13-Jun-2012 469,218 361,079 (77%) 108,139 23.05% JSDF TF 91836 (HFHI-C) 13-Jun-2012 415,267 185,817 (45%) 229,450 55.25% JSDF TF 91839 (LWD) 13-Jun-2012 1,483,603 441,463 (30%) 1,042,140 70.24% Total JSDF Grants 2,368,088 988,360 (42%) 1,379,728 58.26%

B. HABITAT FOR HUMANITY INTRENATIONAL - CAMBODIA (HFHI – C)

41. Implementation Status. HFHI-C continues to work closely with the local authorities in the three urban villages of Chamkar Russey, 13 Makara and Okhcheay in Prek Preah Sdach Commune in , . The SLC sites are in compliance with the agreed environmental procedures and guidelines. This is the first pilot project that will make centrally-located urban land available for housing the poor (with 6.73 hectares registered as private state land on December 17, 2009), undertake a systematic upgrading of an existing settlement and implement a sites-and-services project for a voluntary and participatory settlement by the poor. As such, the project has undergone several tedious processes, including the adoption of a land tenure security time frame following the provisions of both the Sub-decree 19 and Circular No. 3 (i.e., distribution of title after 5 years of residency as per the provisions of Sub-decree 19, but conveyance/transfer would be allowed after a minimum of 10 years of residency, as per Circular No. 3). Based on the survey, there are 334 existing households living in the project area that are qualified to apply as land recipients.

42. The mission was informed during the meeting with HFHI-C representatives in Phnom Penh and visit of the SLC site in Battambang that: (a) the land use plan has been approved by Provincial Governor, according to which 649 plots of about 70X80 square meters will be created in five blocks; (b) a census was redone in March 2011 in order to verify the current occupants of the SLC site, it found 334 households are currently occupying and using some parts of the land designated as the SLC site, in comparison to 289 households who were found when the census was originally taken in October 2007, which was set as the project cut-off date; and (c) the HFHI-C agreed with the municipality that the project cut-off date be reset to when the March 2011 survey was done, and that the current occupants found under the survey be considered as eligible for the SLC. The mission agreed with the approach, which will help address the natural and legitimate mobility of people in the local area over four years since the original cut off-date was set.

43. Under the March 2011 survey, the land occupant information sheets which were signed/thumb marked by household heads, surveyors, village chiefs and commune chiefs, have been developed which includes the photos of household members, the list of their properties and copies of the ID or family book if available. Those who occupy land in the SLC areas but who do not live there were included in the information sheet but no photos were attached. The mission suggested that photos be attached for those who do not live there too. The Battambang municipality requested that, in addition to current residents of the SLC areas, 4 families of disabled veterans be included in the project SLC.

44. Just like WP above, HFHI-C has undertaken several activities on public awareness and capacity building on SLC processes, policies and guidelines. HFHI-C has also coordinated regularly with project stakeholders to discuss project progress and issues. Several meetings with the community-residents were held, especially with the 11 affected families and most vulnerable households whose houses are located on the road corridor and/or the drainage area. The land re-blocking map has now been approved by the Provincial Governor, which would pave for the implementation of land demarcation activities. The approved map had considered the least possible disruption and that relocation of affected households will be done after land demarcation has been completed, including the drawing for the new parcels of the affected households.

45. There is a potential risk, however, that project activities cannot be completed given the tedious and careful processes that need to be in place within the remaining eight months of the project. Nevertheless, it is important that the project ensure that all safeguards are in place prior to lot allocation, as well as construction of road crossing and drainage system. It was agreed that the project prioritizes the critical activities and come up with an updated catch-up plan to ensure completion of priority activities for submission to the Bank on October 27, 2011, and the RAP finalize for submission to the Bank on November 30, 2011.

46. Procurement. Four procurement contracts of goods for sub-grant were completed since the last mission. An ex-post review had been carried out by the Bank and the findings were discussed with the HFHI-C management and staff. A formal letter will be sent on this regard. The big procurement packages under Component B are yet to be procured. Given the less than eight months remaining to the project, it is important that required prerequisite activities are completed to enable the procurement process to commence and be completed. It was agreed that an Updated Procurement Plan (using the procurement tracking form) will be submitted for the Bank's prior review and no objection by October 27, 2011.

47. Financial Management. The FM and disbursement arrangements have been working well, including the submissions of quarterly Interim Financial Reports (IFRs) and annual audited reports. The audit opinion on the organization’s financial statements as well as for the JSDF grant are “unqualified” (clean) and no significant internal control weaknesses were reported in the audit management letter. Total disbursements to date amount to US$185,817 (45%). It is critical that procurement of sub-grants and civil works are fast racked and completed before the grant closing date to enable the use of the grant funds. (Annex 12)

C. LIFE WITH DIGNITY (LWD)

48. Implementation Status. This is another NGO-led project that pilots SLC processing in five sites in close cooperation local authorities. Several activities on public awareness and capacity building on SLC processes, policies and guidelines were conducted continuously, including regular coordination with project stakeholders to discuss project progress and issues. Good progress has now been achieved in the four SLC sites in Sammeaki Meanchey District () with the approval on April 21, 2011 of 2,727.67 hectares. The approved SLC sites came from cancelled Economic Land Concession (ELC) areas and are in compliance with the agreed environmental procedures and guidelines. A total of 1,179 applicants were processed wherein 914 land recipients were selected. The SLC site in Phnom Srouch & O' Ral Districts, has also been approved on September 5, 2011, covering 1,120 hectares to support 400 target recipients. Given the remaining eight months of implementation, it is very critical to prioritize and fastrack set activities. The mission reviewed the project Resettlement Policy Framework (RPF) and found that it does not provide provisions to exclude the land from the SLC – RPF includes as the entitlements of “unauthorized land users” either to stay in the current premises or move to new SLC sites, unlike the PRF of LASED IDA project which also allows an option of excluding such land used by authorized users from the SLC. The mission reiterated that the RPF be revised in line with the LASED IDA RPF so it has sufficient policy provisions to deal with such informal land users. The mission agreed to support LWD in the revision of the RPF. The mission also suggested that a Resettlement Action Plan (RAP) should also be developed simultaneously with the revision of RPF. The mission advised LWD that no physical works should start prior to the clearance by the Bank of the RAP. Given the limited time available before the grant closing date, the mission strongly recommended that LWD put the revision of the RPF and the preparation of the RAP as one of the top priorities. It is critical that RAP finalize and submit to the Bank by November 30, 2011.

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Table 4. Status of LWD-Implemented SLC Site Processing (as of October, 2011) Estimated Actual Area SLC Site Status of Processing Potential Area Registered (has.) (has.) Kampong Chhnang Province 1. Sammeaki Meanchey District, Land registration completed and plot 720.74 854.30 Kraing Lvea Commune, Sambok allotment and demarcation in the process. 78 Kriel Area families selected under first round. A second round is being planned. (Note: The SLC land area was deducted from Economic Land Concession (ELC) of PHEAPHIMIX Co. Ltd.) 2. Sammeaki Meanchey District, Land registration completed and plot 952.17 975.60 Kraing Lvea Commune, allotment and demarcation in the process. Ksachsor Area 196 families selected. (Note: The SLC land area was deducted from ELC of PHEAPHIMIX Co. Ltd.) 3. Sammeaki Meanchey District Land registration completed and plot 427 468.78 Peam Commune allotment and demarcation in the process. 175 families selected. (Note: The SLC land area was deducted from ELC of PHEAPHIMIX Co. Ltd.) 4. Sammeaki Meanchey District, Land registration completed and plot 424.6 428.99 Chhean Leung Commune allotment and demarcation in the process. 157 families selected. (Note: The SLC land area was deducted from ELC of PHEAPHIMIX Co. Ltd.) Kampong Speu Province 5. Phnom Srouch District, Kraing Land has been approved by MAFF and RGC. 1,200 1,120 Dey Way Commune 972 families have applied for SLC land. It is in the selection process. Based on the project document, there is a potential 400 families will be selected. (Note: This SLC land was deducted from ELC of GRANDIS TIMBER Co. Ltd.) TOTAL Total Recipients in Kampong Chhnang: 3,724.51 3,847.67 606 Total Applicants in Kampong Speu: 972

49. Procurement. As the target SLC sites have just been registered and allocated, the procurement activities for the sub-grant component have not commenced yet. Given the forthcoming closing date of the grant, some of the sub-grant procurement packages may not be necessary anymore. In view of these changes, it was agreed that a Revised Procurement Plan (with the proposed changes) will be submitted for the Bank's prior review and no objection by October 21, 2011.

50. Financial Management. The FM and disbursement arrangements have been working well, including the submissions of quarterly IFRs and annual audited reports. The audit opinion on the organization’s financial statements as well as for the JSDF grant are “unqualified” (clean) and no significant internal control weaknesses were reported in the audit management letter. Total disbursements to date amount to US$441,463 (30%). It is critical that procurement of sub-grants and civil works are fast racked and completed before the grant closing date to enable the use of the grant funds. (Annex 12)

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VI. GERMAN INTERNATIONAL COOPERATION (GIZ)

51. The Government of Germany, through GIZ and based on the implementation agreements and the PAD, provides technical support for technical implementation of LASED with its own staff at national level and subcontracted technical assistance at field level. The technical assistance and the additional financial support of GIZ have been crucial in the commune based social land concession planning and land allocation and the development of the communities and their agricultural production activities. This has been highlighted in the draft report on Monitoring and Evaluation and Assessment of Livelihood Support Activities prepared by the Bank consultant during the mission (Japan Development Institute in collaboration with Global Development Solutions). GIZ assesses the coordination and cooperation with RGC and WB as good, although partners faced challenges to fully harmonize the project activities. GIZ has confirmed its technical assistance until the end of February 2013 to support LASED-SLC communities which received land before the end of 2010. Technical assistance requirements for additional new sites shall be organized by the RGC and the Bank. GIZ and IP/GOPA will further elaborate documents on lessons learned to help RGC and WB organize TA. GIZ also proposes to get other important stakeholders effectively involved such as MAFF, NLC/S and the private sector. (Annex 17)

VII. PROPOSED RESTRUCTURING

52. Given the various developments in the project, the Bank mission discussed with the LASED Team the need for the MEF to request for the re-structuring of the project to cover the change in the Component A indicator as regards the number of communes from 20 to 7, as well as inclusion of new indicators. It was agreed that a request on this will be submitted to the Bank by November 15, 2011.

VIII. SUMMARY OF AGREED KEY ACTIONS

53. The table below summarizes the agreed key actions and the corresponding responsibility center and due date.

Table 5. Summary of Agreed Key Actions

Paragraph Agreed Key Actions Responsibility Due Date No. Center

COMPONENT 1: 11 Continuation of information campaigns to remind the land recipients of CMAC, Provincial Continuing potential risks in areas surrounding/outside the LASED-SLC site. Safeguards Focal Person COMPONENT 2: 16 Submission of report regarding the impact of the current floods on the GSSLC and NCDDS October 31, 2011 infrastructure and agriculture production at the LASED-SLC sites. (requested for support from GIZ) COMPONENT 3: 19 Submission of report regarding any implication for LASED NCDDS Continuing implementation during the period 2012-2013.

21 Submission of a report on the on the types and number of complaints GSSLC, WP December 31, 2011 which are disaggregated per their nature, locations, current status, etc.

COMPONENT 4: 22 Undertake the following:

(a) Proactive coordination with the relevant oversight and line GSSLC Continuing ministries/agencies to identify and agree on means to accelerate implementation progress, including processing of the proposed SLC sites, as well as procurement, financial management and safeguards concerns.

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(b) Reactivation of monthly project management meetings with the project GSSLC, NCDD Starting November 1, stakeholders (concerned agencies, NGO partners, Bank and GIZ) to 2011 address issues concerning the implementation of the project and the phasing out of the GIZ Technical Assistance Program in February 2013.

9 Conduct of quarterly meeting to review progress in procurement and NCDD, GSSLC and Quarterly (starting identify any bottlenecks which could impede progress towards completion. World Bank November 2011)

27 Submission of the AWPB ( jointly prepared by the NCDD and GSSLC) NCDD and GSSLC December 5, 2011 covering the period January 2012 - June 2013

28 Finalize, adopt and submit to the Bank by GSSLC and NCDD on the GSSL and NCDD November 15, 2011 updated and simplified PIM that was agreed in principle earlier in 2011.

SAFEGUARDS: 34 Submission of a short report on activities conducted in the past in relation GSSLC, WP December 31, 2011 to ethnic minorities.

WATHNAKPHEAP: 39 Submission of an Updated Procurement Plan (using the procurement WP October 21, 2011 tracking form), incorporating the procurement in Kampong Thom (Submitted Nov.1, Province. 2011)

40 Implementation of the remaining actions in compliance with the FY 2010 WP November 1, 2011 qualified audit opinion as follows:

(a) Engagement of part-time internal auditor (using savings under the (NOL By Bank on consultant’s category). Oct 29, 2011)

(b) Engagement of Consultant for capacity building of the FM staff (using (Continuing) WP funds).

HABITAT FOR HUMANITY, INTERNATIONAL - CAMBODIA: 45 Prioritization of critical activities and come up with an updated catch-up HFHI-C October 27, 2011 plan to ensure completion of priority activities. (Submitted, Incorporating Bank’s comments) 45 Submission of final RAP to the Bank HFHI-C November 30, 2011 46 Submission of an Updated Procurement Plan (using the procurement HFHI-C October 21, 2011 tracking form). October 21, 2011. (Submitted Oct 27, 2011, Bank NOL due as no provision for NCB method in the Grant Agreement of HfHIC, therefore an amendment to GA is required if NCB will be used, under discussion). LIFE WITH DIGNITY: 48 Submission of RAP to the Bank LWD November 30, 2011

49 Submission of a Revised Procurement Plan (with the proposed changes) for LWD October 21, 2011 the Bank's no objection. (Submitted Oct 26, 2011, under review)

RESTRUCTURING: 52 LASED - Submission of a formal request for the re-structuring of the GSSLC November 15, 2011 project to cover the change in the Component A indicator (i.e., change in the number of communes from 20 to 7).

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IX. ANNEXES

Annex 1: Mission Announcement and Terms of Reference Annex 2: Results Framework and Monitoring Annex 3: Critical Risk Assessment at MTR Annex 4: Lessons Learned Annex 5: Status of Actions Agreed during the December 2010 Mission Annex 6: LASED Implementation Status Annex 7: Assessing the Minimum Threshold Land Clearing Required to Support Livelihood Activities Annex 8: NCDD Letter No. 315 (dated August 11, 2011) Annex 9: Good Governance Framework Annex 10: Monitoring and Evaluation Annex 11: Procurement Annex 12: Financial Management and Disbursement Annex 13: Environmental Safeguards Annex 14: Social Safeguards and Gender Annex 15: Communications Strategy Annex 16: JSDF Grants Implementation Status Annex 17: German International Cooperation Annex 18: Mission Schedule Annex 19: List of People Met

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