SUPPORTED BY Citizen-led Grievance Redress for Road Construction and Urban Infrastructure Upgrades Experiences from Two Projects in Rwanda CASE STUDY Abbreviations and Acronyms FRDP Feeder Roads Development Project IOSC Isange One Stop Center GBV gender-based violence km kilometer/s GEMS Geo-Enabling Initiative for Monitoring and Supervision PIU project implementation unit GRC grievance redress committee RTDA Rwanda Transport Development Agency GRM grievance redress mechanism RUDP Rwanda Urban Development Project Acknowledgments This report was part of an effort to strengthen the right to The authors appreciate the guidance and valuable input by remedy in World Bank operations and beyond by building the Helene Carlsson Rex, the Practice Manager, SAES2. The authors capacity of World Bank staff, clients, and project-affected people, would also like to thank Laura Johnson for her excellent editorial especially the vulnerable and marginalized, to implement support. effective grievance mechanisms so that they can improve service delivery, risk management, and development outcomes. The core Finally, the authors are grateful to the Human Rights, Inclusion team, led by Sanjay Agarwal and Saki Kumagai, comprised Harika and Empowerment Trust Fund (HRIETF) for supporting the Masud and Hélène Pfeil at the World Bank. activities under this initiative. The findings, interpretations, and conclusions expressed in this report are entirely those of The lead author of the report is Denis Rugege and George Bob the authors and should not be attributed in any manner to the Nkulanga, with invaluable contributions from Hélène Pfeil and World Bank, to its affiliated organizations, or to members of its Sanjay Agarwal. Valuable inputs and comments were provided by Board of Executive Directors or the countries they represent. Steffen Janus, Annette Omollo, and Najat Yamouri. Contents Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii 1 Overview of the Feeder Roads Development Project and the Rwanda Urban Development Project . . . . . . . . 1 2 Social Accountability Framework . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.1 Rwanda’s Decentralized Governance Structure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 2.2 Involvement of Project-Affected Parties in Grievance Redress Committee Elections and Operations . . . . . . . . . . . . . . . . . . . . . . . 5 3 Grievance Redress Procedure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.1 Grievance Submission . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.2 Grievance Registration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 3.3 Grievance Categorization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 3.4 Investigations, Follow-Up Actions, and Proposed Resolutions of Cell-Level Grievances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 3.5 Grievance Escalation to the Sector or District Level . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 3.6 Data Monitoring and Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 3.7 Gender-Based Violence, Sexual Exploitation and Abuse, and Sexual Harassment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 3.8 Labor-related Complaints . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 4 Grievance-Related Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 4.1 Volume of Grievances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 4.2 Grievance Categories in FRDP and RUDP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 5 Strengths of the Projects’ Grievance Redress Mechanisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 5.1 Building on Existing Governance Structures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 5.2 Independence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 5.3 Oversight by Dedicated Social Safeguards Officers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 5.4 Systematic Representation of Women . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 5.5 Transparency, Communications, and Community Involvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 5.6 Capacity Building for Grievance Redress Committees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 5.7 Institutionalizing Project-Level GRMs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 i 6 Areas in Need of Improvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 6.1 Accessibility for the Vulnerable and Marginalized . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 6.2 Timely Involvement of District Officials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 6.3 Timely Establishment of Grievance Redress Committees and Capacity Building . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 6.4. Compensation for Grievance Redress Committee Members . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 6.5 Data Collection, Analysis, and Reporting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 7 Conclusion and Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 Bibliography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 Box 3.1 Testimonies of Project-Affected Parties About Complaint Resolution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Figures 2.1 FRDP and RUDP Grievance Redress Mechanisms Flowchart . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.1 Isange One Stop Center’s GBV Intervention Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 3.2 Isange One Stop Center: Accessibility and Outreach Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 4.1 Volume of Registered Grievances in FRDP’s 10 Intervention Districts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 4.2 Volume of Registered Grievances in RUDP’s Urban Upgrade Works in the Six Secondary Cities of Intervention . . . . . . . . . . . . . . . . . . 12 4.3 Progression of Beneficiaries and Grievances Logged in FRDP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 4.4 Grievances Logged During FRDP’s First Phase in Intervention Districts by Grievance Category . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 4.5 Grievances Logged During RUDP’s First Phase in Six Secondary Cities by Grievance Category . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Tables 2.1 Rwanda’s Political and Administrative System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3.1 Categories of Grievances Registered by the FRDP and RUDP GRMs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 4.1 Received and Resolved Grievances Under FRDP and RUDP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 5.1 Levels of Participation Among Women in RUDP’s and FRDP’s Grievance Redress Committees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 5.2 GRC Training statistics of FRDP and RUDP . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 ii Introduction T his case study examines the grievance redress and members of grievance redress committees,1 as well as mechanisms (GRMs) put in place for two World Bank- on desk research and data provided by social and safeguards financed projects in the Republic of Rwanda: the Feeder officers of project implementation units and World Bank task Roads Development Project (FRDP) and the Rwanda Urban teams, section 1 provides an overview of both projects; section Development Project (RUDP). Aside from the considerable 2 describes the social accountability framework in which they number of grievances handled by these GRMs and the solidity were implemented; section 3 explores the way grievances of their processes, these two projects were selected due to were taken up, investigated, and resolved; section 4 considers the fact that they both leverage government systems and key grievance data; section 5 assesses the main strengths of hence have similar structures. Based on consultations and the GRMs; section 6 investigates areas for improvement; and interviews with key informants, such as project-affected parties section 7 outlines a few conclusions and recommendations for who submitted complaints to one of the project-level GRMs practitioners. 1. Due to COVID-19-related restrictions at the time of the research, most interviews were conducted virtually. iii 1 Overview of the Feeder Roads Development Project and the Rwanda Urban Development Project T he Feeder Roads Development Project (FRDP)1 seeks urban planning and management in the City of Kigali and in the to enhance all-season road connectivity to agricultural six secondary cities of Rwanda: Muhanga, Huye, Rusizi, Rubavu, market centers in selected districts in Rwanda: Musanze, and Nyagatare. Rwamagana in the Eastern Province, Gisagara in the Southern Province, and Karongi and Nyamasheke in the Western Province. Both the FRDP and the RUDP seek to enhance all-season roads The first phase of the project (2014–18) rehabilitated, upgraded, and construct asphalt roads. RUDP investments also involve and maintained 500 kilometers (km) of feeder roads. In 2018, urban upgrading activities, including establishing or improving the government of Rwanda obtained US$84 million of additional access streets, stormwater drains, pedestrian walkways, financing for 1,200 km more of feeder roads in another six 2 streetlights, and bus stops. districts, with implementation beginning in 2020. 3 The Rwanda Transport Development Agency (RTDA) implements With project activities that began in 2016, the Rwanda Urban the Feeder Roads Development Project (FRDP), and the Local Development Project (RUDP) provides access to basic 4 Administrative Entities Development Agency implements the infrastructure and enhances urban management in selected Urban Development Project (RUDP). FRDP activities related urban centers within participating districts. The second RUDP to feeder road construction and rehabilitation have primarily (P165017, US$160 million, 2020–25) seeks to improve access to affected people in rural settings, while RUDP activities have basic services, enhance resilience, and strengthen integrated primarily affected urban households. 1. P126498, IDA US$45 million and TF US$68 million, 2014–22. 2. US$68 million is a grant from a multi-donor trust fund and US$16 million is government counterpart financing to cover compensation of project-affected people. 3. The additional districts comprise Nyagatare and Gatsibo in the Eastern Province, Nyaruguru in the Southern Province, Nyabihu and Rutsiro in the Western Province and Gakenke in the Northern Province. 4. P150844, US$95 million, 2016–21. 1 2 Social Accountability Framework 2.1. Rwanda’s Decentralized Governance redress committees (GRCs), which allow project-affected people Structure to voice project-related grievances. Rwanda consists of four provinces plus the City of Kigali; The GRCs established for the two projects mirror the these are further divided into 30 districts. Districts are then administrative structure of the country, with the lowest-level divided into 416 sectors comprising 2,148 cells. These cells are GRCs meeting at the cell level to resolve issues at the level divided into 14,837 villages—the lowest level (see table 2.1). closest to the complainant, but with the possibility of escalation Rwanda’s governance system is based on a highly decentralized to the sector or district levels if necessary (see figure 2.1). administrative structure organized to increase citizen participation in national development. As stipulated in the 2008 A GRC comprises eight members, with the GRC president and Community Development Policy, this structure is designed to vice president directly elected by project-affected parties. empower local communities in effectively participating in policy Other members include a cell-level women’s representative making and implementation. (member of the National Women’s Council), the village leader, the project’s social safeguards officer, a representative of the In line with Rwanda’s Law No. 32/2015 of June 11, 2015, regarding contractor, a representative of the contractor’s supervisor, expropriation in the public interest,1 “expropriation … shall and a local government official (either the cell- or sector-level be carried out only in the public interest and with prior and executive secretary or the vice mayor for district-level social fair compensation” (article 3). Resettlement action plans were affairs). prepared for both the Feeder Roads Development Project (FRDP) and the Rwanda Urban Development Project (RUDP) before the GRCs are expected to meet at regular monthly working sessions start of civil works, in compliance with World Bank safeguards but can convene at any time deemed necessary based on the policies on involuntary resettlement.2 They spell out the nature of received grievances. respective compensation programs for project-affected people as well as the required establishment and training of grievance 1. Law No. 32/2015 of June 11, 2015, specifies that “any person affected by the decision on expropriation in the public interest shall have the right to request for review of the decision before the organ directly higher than the one having taken the decision” (article 18) and that any person “who is not satisfied with the assessed value of his/ her land and property incorporated thereon” can contest the assessed value of land and property” in writing “within seven (7) days after the approval of the valuation report by the expropriator” (article 33). Proponents of the project are required to prepare regulation-compliant assessment reports with information on appropriate measures for avoiding or mitigating environmental and social risks and impacts, grievance redress, and proof of needed funding. Ministerial order No 003/2008 regulates the procedures, content, and quality of environmental and social impact assessment reports to ensure the avoidance or mitigation of negative impacts from development projects. 2. For more information on World Bank Operational Policy 4.12, see https://www.worldbank.org/en/projects-operations/environmental-and-social-policies. 2 2. SOCIAL ACCOUNTABILITY FRAMEWORK TABLE 2.1. RWANDA’s POLITICAL AND ADMINISTRATIVE SYSTEM Administrative Entity/Decision- Composition of Administrative Entity/Decision-Making Level Making Body Mandate Body District District council District-level policy- The size of each district council is determined by the making and legislative number of sectors within its boundaries. Each sector body; formulates and sends a representative to the council. Four additional adopts policies and seats are reserved to ensure the representation of has decision-making marginalized groups: three for the National Youth Council and planning powers and one for the district coordinator of the National Central to determine district Council of Women. A district’s day-to-day business is government development. conducted by an executive committee headed by a mayor and two vice mayors. Sector Sector council Political organ Sector councils are elected by residents aged 18 years for policy-making and older. The number of council members is determined (Umurenge) decisions; functions by the number of cells within its boundaries. 4 include approval of provinces Sector council members include a cell representative sector plans and action programs elected by the cell council; members of the sector-level + National Youth Bureau; members of the sector-level and ensuring their City of Kigali National Women Bureau; a representative of people implementation. with disabilities; women’s representatives constituting at least 30 percent of members; a representative of the heads of all primary schools in the sector; a representative of the heads of all secondary schools in the sector; a representative of nongovernmental 30 organizations operating in the sector; a representative districts of cooperative societies in the sector; and a leader representing hospitals, health centers, or other health facilities operating in the sector. A 12-member sector executive committee drawn from the council is responsible for day-to-day administration and the implementation of the council’s decisions and plans. 416 Cell Cell council Executes functions Elected for five-year terms, cell councils comprise an related to elected cell councilor; a women’s representative (the sectors (Akagari) administration cell-level coordinator of the National Women’s Council); and community the cell-level coordinator of the National Youth Council; development, a representative of the heads of nursery schools in the including policy cell; a representative of primary school teachers in the orientation and cell; and a representative of the private sector in the technical advisory cell. The cell executive committee, which is composed 2,148 services; charged of the executive secretary and a secretary in charge with identifying, of coordinating social development, is responsible cells discussing, and for the day-to-day administration of the cell and the prioritizing issues, implementation of decisions taken by the cell council. as well as making decisions on behalf of the electorate. Village Village Council Identify, discuss, and The village council is the supreme organ made up of all 14,837 prioritize issues; make village residents who are at least 18 years old. villages (Umudugudu)— decisions on behalf of the lowest The village executive committee, selected by adult the electorate. administrative residents of the village for five-year terms, consists of five entity in members: the village chief, a member for development Rwanda and social affairs, a member in charge of security, a member in charge of youth-related issues and a member for gender-related issues. It is responsible for day-to-day village administration and for implementing decisions made by the village council on behalf of all residents. 3 2. SOCIAL ACCOUNTABILITY FRAMEWORK FIGURE 2.1. FRDP AND RUDP GRIEVANCE REDRESS MECHANISMS FLOWCHART Grievance registration GRC convened at cell level Level 0 • In-person to GRC; to GRC member; Level 1 (within maximum 4 days) to local administration o ce; Initiation 1. President (PAP) at Umuganda 2. Vice president (PAP) • By phone to a GRC member 3. Women representative Aggrieved • In writing to GRC member (NWC-cell) party 4. Village leader 5. Cell executive secretary GBV complaint 6. Project representative (direct) (social safeguards) 7. Contractor representative 8. Contract supervisor’s representative GBV complaint (referral) GBV Task Escalation Level 2 Force/Isange One-Stop Center (1–12 hours) GRC convened at sector level Grievance resolution (within maximum 1 week) 1. President (PAP) 2. Vice president (PAP) 3. Women representative (NWC-cell) GRC convened at sector level 4. Village leader National (within maximum 1 week) 5. Sector executive secretary 6. Project representative court system 1. President (PAP) (social safeguards) 2. Vice president (PAP) 7. Contractor representative 3. Women representative (NWC-cell) 8. Contract supervisor’s 4. Village leader representative 5. Vice mayor (social) of S-ES 6. Project representative (social safeguards) Escalation 7. Contractor representative Escalation 8. Contract supervisor’s Level 4 Level 3 representative FRDP = Feeder Roads Development Project; GRC = grievance redress committee; GRM = grievance redress mechanism; RUDP = Rwanda Urban Development Project. 4 2. SOCIAL ACCOUNTABILITY FRAMEWORK 2.2. Involvement of Project-Affected Parties in Grievance Redress Committee Elections and Operations During the project preparation stage, with the support of the project implementation unit social safeguards officers, the district administrations—as owners of the development projects—are charged with identifying and organizing consultations with project-affected parties in specific cells. These meetings fit into the agenda of regular community meetings, such as umuganda (mandatory nationwide community work that takes place on the last Saturday of every month) or general community meetings at the cell level that convene every Tuesday (Inteko Rusange in Kinyarwanda). The community meetings provide the framework for the election of GRC presidents and vice presidents by project-affected people. The elections are organized by beneficiary district administrations with the support of social safeguards officers at the cell-, sector- and district-level (see photo 2.1). Photo 2.1. Project-affected people lining up behind their preferred candidates during the election of an FRDP GRC. 5 3 Grievance Redress Procedure 3.1. Grievance Submission 3.2. Grievance Registration Under the Feeder Roads Development Project (FRDP) and the Grievances are written down on a grievance registration form Rwanda Urban Development Project (RUDP), complainants can by a GRC member during the committee’s monthly working access multiple channels to file a complaint, including: sessions and compiled into a logbook. Information captured includes name and national identification number of the 3 In person to a member of a grievance redress committee aggrieved person, date and location of grievance submission, (GRC) at a village, cell, or sector level administration office category of grievance, summary description of grievance, action during umuganda, at a regular GRC monthly working session, taken, date when action was taken, status of grievance, and or at any regular community meeting; signatures of the receiver of the complaint and the aggrieved party acknowledging its receipt. 3 By phone (voice or text) to a GRC member (who are known community members whose phone numbers are easily A project implementation unit (PIU) social safeguards officer accessible); and deployed and reporting to the district authority acts as 3 In writing to a GRC member or to a village head. district focal person, consolidates reports from several GRCs, and submits them to the district authority for further action and to share with the PIU. This focal person assists GRCs in Photo 3.1. Damaged security wall and home access in Huye Secondary City before (left) and after restoration (right). 6 3. GRIEVANCE REDRESS PROCEDURE Photo 3.2 Security wall restoration for a project-affected person in the secondary city of Rubavu (damage shown on left and restored wall on right). Credit: Local Administrative Entities Development Agency (2020) following-up on the committees’ decisions with concerned Box 3.1. Testimonies of Project-Affected parties to ensure grievances are resolved. Because GRCs have Parties About Complaint Resolution limited time and resources to follow-up on actions such as monetary settlements by district administrations or remediation Ms. Kabasinga, resident in Rusizi Secondary City: activities by contractors, they rely on the focal person for the “I was compensated for a housing structure that was necessary liaison with the responsible parties. removed to make way for a road upgrade. A second housing structure in my home had been damaged by 3.3. Grievance Categorization the road construction activities and was fully repaired to my satisfaction.” Some of the road construction and urban infrastructure upgrades funded by the FRDP and RUDP—such as street asphalt Ms. Francina, resident in Nyabihu FRDP intervention paving; construction and paving of pedestrian walkways district: and cycle tracks; installation of electrical and water utilities “The committee assisted me in understanding including streetlight poles, transformers, substations, and water procedures and helped me open a bank account. I piping; and the relocation of utility infrastructure to optimize received compensation and still use the bank account access—require heavy machinery, such as dump trucks, graders, to manage my money.” and compactors. These have the potential to cause vibrations; undermine the stability of foundations and thereby cause Mr. Safari, resident in Rubavu Secondary City: structural damage to properties; lead to temporary water supply “My property, removed to make way for the Majengo- disruptions; and disrupt access to private homes and businesses Byahi road, had been undervalued. I commissioned a as well as public, community, and cultural facilities. counter-valuation which came up with a higher value that became a basis for negotiations. An agreement The two projects therefore have common grievance categories, was reached, and I was paid a compensation that I am as well as categories that are unique to each project, which satisfied with.” table 3.1. summarizes. Note: Names of complainants were changed to protect their anonymity. 7 3. GRIEVANCE REDRESS PROCEDURE TABLE 3.1. CATEGORIES OF GRIEVANCES REGISTERED BY THE FRDP AND RUDP GRMs FRDP RUDP Delay in compensation Disruption of access to home or other facility Employment requestsa Asset counter-valuation Lack of bank account (required to Heavy road machinery damage pay due compensation) to property Lack of land title (required to pay Utility relocation due compensation) Landslide/damage from road Water supply disruption construction activity Photo 3.3. GRC assessing damage during a field visit. Stormwater damage from road construction activity satisfied with the proposed resolution and captures the updated Suspected false claim grievance status in the grievance logbook. If the complainant is Worker salary delay not satisfied with the proposed resolution, this is recorded in FRDP and RUDP the logbook and the complaint is escalated to the next level. Constructed, upgraded, or rehabilitated roads causing high-risk surroundings around homes and other assets, e.g., dangerous embankments due to road construction and increased proneness to landslides 3.5. Grievance Escalation to the Sector Family land disputes, e.g., conflicts over which family member should or District Level receive monetary compensation If a grievance is not resolved at the cell level, it is escalated to Land/asset overstepping or use beyond agreements, i.e., use of the sector level, where the maximum duration for resolution is additional land or destruction of assets beyond what was agreed on and compensated for due, for example, to a change in road layout one week, including the day the escalated complaint is received from the GRC. The GRC reconvenes with the participation of the a. The Rwandan government’s projects prioritize able, local residents for sector executive secretary, makes a field visit to the relevant employment opportunities. Some local residents may feel aggrieved if they are not site, and recommends a way to resolve the grievance. recruited even though they believe themselves to be eligible. If the complainant is not satisfied with the sector-level 3.4. Investigations, Follow-Up Actions, recommendation, the complaint then escalates to the district and Proposed Resolutions of Cell-Level level, and the GRC reconvenes with the participation of the vice Grievances mayor for social affairs and the complainant. GRCs conduct field The maximum duration for resolving a complaint at the cell level visits to investigate grievances logged and to verify them, often is four days,1 which includes the day the grievance is received with the involvement of the local community. For grievances by a GRC. Depending on their nature, complaints might be such as damage to property and loss of assets, GRC members resolved immediately or might require field visits. The field visits can be joined by residents of the site of interest, who are are conducted by GRC members to verify complaints involving given a chance to provide additional information and share property damage or loss of land or other assets (see photo 3.3) their testimonies regarding the subject of the grievance. If the and to then propose an appropriate resolution. After adequate complaint is not addressed within two weeks, the complainant action has been taken, the GRC confirms that the complainant is is advised to seek justice in court. 1. At the time of this writing, actual resolution times were not being recorded; information about the de facto resolution times of complaints was therefore unavailable. 8 3. GRIEVANCE REDRESS PROCEDURE 3.6. Data Monitoring and Evaluation “multi-disciplinary Investigative and Intervention Team (MDIIT) model [and adapt] evidence-based, international best practice Grievance logbook records are kept at cell-level administrative protocols for working with victims of gender-based violence offices. The social safeguards officers for both FRDP and RUDP and child abuse. Each IOSC staff has been trained in the MDIIT collate grievance data from project intervention districts on a model either through a formal education program or on-the– bi-weekly basis to use for project monitoring, evaluation, and job. The MDIIT model has aided the range of staff to work reporting. GRCs are not involved in organizing or analyzing together with the highest level of collaboration.” grievance-related data. The project social safeguards officers for RUDP and FRDP 3.7. Gender-Based Violence, Sexual ensure that bidding and contract documents clearly define Exploitation and Abuse, and Sexual the requirements linked to the prevention of GBV, sexual Harassment exploitation and abuse, and sexual harassment, including the need for the contractors and workers to commit to a code of Both GRCs and other community members are sensitized to conduct. and aware that cases of gender-based violence (GBV) require timely access to quality multisectoral services that guarantee The GRC’s women’s representative is trained by the IOSC under confidentiality and the informed consent of the survivor. GBV the auspices of the National Women’s Council to receive complaints are directed to the Isange One Stop Centers (IOSC). allegations of sexual exploitation and abuse, sexual harassment, IOSCs are specialized referral centers where GBV survivors can and GBV and to refer survivors to IOSCs as required by law. The access comprehensive services free of cost, including medical women’s representative is an elected community member and, care, psychosocial support, police and legal support, and as such, is trusted by project-affected parties to extend such evidence collection. IOSCs work closely with community police services and expertise. stations; sector-, cell-, and village-level leaders; and hospitals and health centers across the country. According to Bernath and Gahongayire (2013), IOSCs utilize the FIGURE 3.1. ISANGE ONE STOP CENTER’s GBV INTERVENTION MODEL Isange One Stop Center (IOSCs) Quality of Services to GBV Survivors Multidisciplinary Investigative and Intervention Team (MDIIT) model: • Reception operated by a social worker with access to legal support; medical services; psychological services and police desk Free 24/7 services: Capacity building: • Emergency contraception; HIV prophylaxis; STI prevention; • Training women’s cell-level representatives and other medication • Training GRC members Mainstreaming: • Received World Bank support for Rwanda Great Lakes Emergency Sexual and Gender Based Violence and Women’s Health Project. • IOSCs increased from 1 in 2009 to 44 in 2019; expected to increase to over 500 Isange One Stop Centers http://www.rib.gov.rw/index/php?id=371 9 3. GRIEVANCE REDRESS PROCEDURE FIGURE 3.2. ISANGE ONE STOP CENTER: ACCESSIBILITY AND OUTREACH INFORMATION Isange One Stop Centers http://www.rib.gov.rw/index/php?id=371 Emergency Toll-Free Numbers 24 Emergency call/sharing Reporting domestic and/or Reporting child abuse crime-related information gender-based violence CALL 166 CALL 3512 CALL 116 Reporting dissatisfaction Isange One Stop Center ? Media inquiries with RIB services CALL 2040 CALL 3029 CALL (+250) 788 311 164 GRCs receive training from the IOSC on how to handle and 3.8. Labor-related Complaints channel GBV cases. GRCs also participate in awareness and Grievances stemming from accidents, occupational health and sensitization campaigns around project intervention areas about safety concerns, and other issues that concern workers follow GBV and violence against children. the legal procedures as stipulated in Rwandan law and in the contractual agreements between contractors and projects. GBV, sexual exploitation and abuse, and sexual harassment The law requires contractors to establish grievance redress action plans were prepared and are being implemented mechanisms (GRMs) that include elected representatives of under the second phase of RUDP and under FRDP’s additional workers and that their implementation be supervised by labor financing, which has contracted independent service providers inspectors. in six districts to support action plan implementation. The World Bank has provided needed training to the PIU, contractors, The project workers’ GRM comprises a committee of elected service providers, and supervision consultants to strengthen workers’ representatives. This committee ensures the collaboration among service providers and IOSCs in project representation of all categories of workers, including women, intervention areas. The World Bank plans to conduct further people with disabilities, migrant workers if there are any, and training in this area for these new service providers in fiscal all other vulnerable groups. The workers’ GRC includes a labor year 2022. inspector as an ex-officio member who intervenes (to resolve or escalate to a higher-level legal framework for labor disputes) Under the model adopted by FRDP and RUDP, allegations of in instances when elected representatives cannot resolve GBV, sexual exploitation and abuse, and sexual harassment are the grievance. Labor inspectors are district-level officials of thereby clearly separated from other types of complaints. Such the Ministry of Public Service and Labor mandated to “ensure allegations are handled by the specialized country structures in compliance with all labor protection standards, as well as place and operational across the country. develop labor relations in an orderly and constructive way in order to enforce the labor laws, related regulations, and applicable International Standards for labor laws compliance” (Republic of Rwanda 2020). 10 4 Grievance-Related Data 4.1. Volume of Grievances TABLE 4.1. RECEIVED AND RESOLVED GRIEVANCES UNDER FRDP AND RUDP Overall rates of grievance resolution are high for both the Feeder Roads Development Project (FRDP) and the Rwanda Received Resolved (Number) Number % Urban Development Project (RUDP) (table 4.1). According to conducted interviews, unresolved grievances are usually linked FRDP Phase 1 (2016–19) in four 1,234 1,234 100 districts: Gisagara, Karongi, to family land disputes when compensation cannot be put into Nyamasheke and Rwamagana effect: compensation-related funds are kept in a district-level FRDP Phase 2 (beginning July 122 111 91 suspense account pending resolution of the disputes by the 2020) in an additional six districts: mandated institution. Over 90 percent of grievances received Gakanke, Gatsibo, Nyabihu, Nyagatare, Nyaruguru, and Rutsiro under the projects were resolved with monetary compensation RUDP (2019) in six intervention 172a 169 98 for land and/or assets lost or damaged because of involuntary secondary cities resettlement associated with project activities. a. A higher number of grievances, totaling 268, has been received, assessed, and resolved, but some of them were not properly recorded prior to the recruitment of Figures 4.1 and 4.2 illustrate the volume of received grievances the RUDP social safeguards officer in 2018. under FRDP and RUDP, respectively. Grievance volumes FRDP = Feeder Roads Development Project; RUDP = Rwanda Urban Development associated with feeder roads in the FRDP intervention Project. FIGURE 4.1. VOLUME OF REGISTERED GRIEVANCES IN FRDP’s 10 INTERVENTION DISTRICTS (2016–20) 200 180 175 Number of registered grievances 159 160 141 140 120 113 100 80 59 60 40 17 15 18 20 7 6 0 2016 2016 2016 2018 2020 2020 2020 2020 2020 2020 Gisagara Nyamasheke Rwamagana Karongi Gakenke Gatsibo Nyabihu Nyagatare Nyaruguru Rutsiro FRDP = Feeder Roads Development Project. 11 4. GRIEVANCE-RELATED DATA FIGURE 4.2. VOLUME OF REGISTERED GRIEVANCES IN RUDP’s URBAN UPGRADE WORKS IN THE SIX SECONDARY CITIES OF INTERVENTION (2016–19) 80 Number of registered grievances 68 70 60 50 47 40 30 25 20 16 9 10 7 0 Huye Muhanga Musanze Nyagatare Rubavu Rusizi RUDP = Rwanda Urban Development Project. districts are influenced by several factors, including FIGURE 4.3. PROGRESSION OF BENEFICIARIES AND resettlement needs due to road design and length of road GRIEVANCES LOGGED IN FRDP (2014–20) segment. As figure 4.2 shows, there were more grievances 450,000 600 247 GRC members trained registered during the RUDP’s first phase (2016–19) in the 400,000 535 412,000 412,000 intervention districts of Gisagara, Nyamasheke, Rwamagana, 500 Number of logged grievances 350,000 374,000 Number of bene aries and Karongi than during the second phase in the intervention 300,000 413 400 districts of Gakenke, Gatsibo, Nyabihu, Nyagatare, Nyaruguru, 295,000 250,000 and Rutsiro, which only began in 2020 but which still received Women representatives 300 200,000 joined GRCs fewer grievances than phase one as the project got underway. More robust budget allocations and larger-scale civil works for 150,000 581 GRC members trained 200 152,000 175 the secondary cities of Muhanga, Musanze, and Rubavu probably 100,000 Bene ciaries 121 100 account for the higher number of grievances registered there 50,000 Grievances logged 111 (see figure 4.2). These three secondary cities also have larger 0 0 urban populations and urban growth rates. 2015 2016 2017 2018 2019 2020 2021 Figure 4.3 shows the evolution in the number of project beneficiaries and logged grievances for FRDP. FRDP’s first compensation was required for land acquired for the public phase, which benefitted four districts in terms of feeder road interest if it represented less than 5 percent of the entire plot. construction, ended in 2020, as the second phase began Following dialogues between the World Bank and the Ministry with works in an additional six intervention districts. In of Infrastructure and the Ministry of Justice, the latter provided 2016, 99 percent of grievances were related to the lack of a clear legal opinion on private land, which ruled in favor of compensation for expropriated land, which represented less fair compensation for land per the 2015 expropriation law. This than 5 percent of the private parcel’s size. This was linked 2017 opinion helped address most of the grievances related to to a statutory condition on land titles, which stated that no compensation claims. 12 4. GRIEVANCE-RELATED DATA In addition, a significant number of project-affected parties redress committees (GRCs) and the joining of women’s did not possess land titles in 2016, and the project initially representatives may also have contributed to the decline in applied a strict compensation approach whereby those with land grievances. titles were paid on time while those in the majority without such titles were instructed to acquire them prior to receiving 4.2. Grievance Categories in FRDP and compensation. This approach resulted in many grievances in RUDP 2016. In 2017, the districts and project implementation unit therefore decided that in cases of project-affected people Figure 4.4 presents analytical charts of the categories of who do not possess a land title, the district and sector logged complaints during the first phase of FRDP. Data about administration would confirm that they were the actual specific grievance categories were available for only 1,020 out landowners, and payments for properties would be channeled of 1,234 logged grievances (table 4.1). At the time of this writing, through the sectors to fast-track payments. The change is information on grievance categories in the six additional evident in a rapid decrease in grievances, leveling off to just intervention districts under the project’s additional financing over 100 grievances after 2018. The proper training of grievance was not yet available. FIGURE 4.4. GRIEVANCES LOGGED DURING FRDP’s FIRST PHASE (2014–19) IN INTERVENTION DISTRICTS BY GRIEVANCE CATEGORY (PERCENT) Nyamasheke Rwamagana Karongi Gisagara Lack of bank account: 19% Delay in compensation: 35% Lack of bank account: 12% Lack of bank account: 22% Lack of land title: 7% Stormwater damage: 22% Lack of land title: 35% Stormwater damage: 69% Employment requests: 12% Land overstep: 43% Employment requests: 20% Land overstep: 9% Worker salary delay: 33% Stormwater damage: 10% Stormwater damage: 13% Landslide: 4% Landslide: 1% Causing risk: 9% Causing risk: 5% Land overstep: 8% False claims: 2% Family disputes: 2% Land overstep: 4% Family disputes: 4% 13 4. GRIEVANCE-RELATED DATA Figure 4.5 presents analytical charts of grievances logged during grievance category. No gender-based violence or other social the first phase of RUDP (2016–19) in six secondary cities by complaints were raised by project-affected people. FIGURE 4.5. GRIEVANCES LOGGED DURING RUDP’s FIRST PHASE (2016–19) IN SIX SECONDARY CITIES BY GRIEVANCE CATEGORY (PERCENT) Musanze Rusizi Nyagatare Water disruption: 7% Family disputes: 19% Water disruption: 100% Access disruption: 7% Counter-valuation: 31% Counter-valuation: 35% Causing risk: 50% Causing risk: 9% Property damage: 30% Land overstep: 12% Huye Muhanga Rubavu Access disruption: 22% Access disruption: 7% Counter-valuation: 20% Counter-valuation: 11% Property damage:: 74% Causing risk: 64% Utility relocation: 7% Water disruption: 11% Property damage 14 5 Strengths of the Projects’ Grievance Redress Mechanisms 5.1. Building on Existing Governance 5.3. Oversight by Dedicated Social Structures Safeguards Officers A major strength of the grievance redress mechanisms (GRMs) While the FRDP has benefitted from a dedicated project for the Feeder Roads Development Project (FRDP) and the implementation unit (PIU) social safeguards officer from its Rwanda Urban Development Project (RUDP) is the way they have beginning, the RUDP only recruited a full-time dedicated successfully built upon existing governance structures, allowing social safeguards officer in 2018—two years into project project-affected people to easily understand the process. The implementation. Prior to 2018, social safeguards were overseen use of existing community engagement frameworks accounts for by an officer sent to work temporarily from a subordinate or a substantial degree of familiarity with the proposed grievance similar government ministry responsible for several projects. redress system among those impacted by the projects. Such additional capacity dramatically improved the oversight and implementation of the RUDP’s GRM, especially regarding the inclusion of women’s representatives on committees (see 5.2. Independence below), proper recording of grievance data in logbooks, and The independence of grievance redress committee (GRC) improved monitoring and evaluation of grievance data for members from implementing agency line managers contributes statistical purposes. to the perceived legitimacy of the GRM—another notable strength. Interviews with project-affected people indicate their confidence in the fairness of the grievance redress 5.4. Systematic Representation of process and the consistency of outcomes. Interviews with GRC Women members and project-affected people as well as a review of Rwanda’s national constitution requires a minimum of 30 the implementation reports prepared by the social safeguards percent female representation in decision-making positions. officers of the RUDP and FRDP also point to the equitable The National Gender Policy (2010) also includes this provision. treatment of stakeholders and an evident respect for rights in Accordingly, the National Women’s Council was created as a GRM operations. statutory institution by Law No. 02/2011 of February 10, 2011, as a “forum for advocacy and social mobilization on issues affecting women, in order to build their capacity and ensure their participation in the development of the country in general, 15 5. STRENGTHS OF THE PROJECTS’ GRIEVANCE REDRESS MECHANISMS and the development of women in particular.” To align GRCs with 5.5. Transparency, Communications, and this national framework, the PIUs of FRDP 744and RUDP decided Community Involvement to systematically include a women’s representative as a GRC Other strengths of the GRMs for FRDP and RUDP are linked to executive member beginning in 2018, resulting in cell-, sector- transparency, communications, and community involvement. As and district-level councils all including at least one women’s specified in the respective projects’ stakeholder engagement representative under the mandate of the National Women’s plans and environmental and social risk management Council. instruments, GRM procedures were discussed during public consultations at the project preparation stage. Information The women’s representatives are elected by the members of the about the GRM was provided to project-affected people early communities to which they belong, under the auspices of the in the process through the district administration community National Women’s Council. Each village elects seven women, engagement frameworks. Project monitoring reports feature one of whom is subsequently elected to represent women gender-disaggregated stakeholder consultation statistics at the cell level. The representatives perform their duties as and narrative information on the GRM. The GRM’s structure, volunteers, attending to the interests of women and girls in the services, and standards were publicly disclosed, allowing all community at the cell level, and advocating for equity and equal project-affected communities to be aware of it. GRM-related opportunity. However, the National Women’s Council recently communications benefitted from the input of the projects’ social began providing the representatives with a monthly lump sum safeguards officers, who provided insights on GRM procedures facilitation allowance for transportation and communications. and supported the election and training of GRCs. Finally, the As members of project GRCs, women’s representatives are also election of the GRC presidents and vice presidents during eligible for and do receive a GRC facilitation allowance. community meetings ensured a high degree of awareness of the GRM among project-affected people. Table 5.1 shows that women accounted for 34 percent and 44 percent of GRC members in FRDP and RUDP respectively. TABLE 5.1. LEVELS OF PARTICIPATION AMONG WOMEN IN RUDP’s AND FRDP’s GRIEVANCE REDRESS COMMITTEES RUDP GRC Members FRDP GRC Members FRDP-AF GRC Members Secondary City Women Men Total District Women Men Total District Women Men Total Huye 8 8 16 Rwamagana (refresher) 26 50 76 Gakenke 23 30 53 Muhanga 9 6 15 Rwamagana 28 42 70 Gatsibo 23 49 72 Musanze 8 11 19 Nyamasheke 14 20 34 Nyabihu 10 22 32 Nyagatare 8 11 19 Karongi 12 25 37 Nyagatare 16 24 40 Rubavu 14 23 37 Gisagara 12 18 30 Nyaruguru 27 57 84 Rusizi 15 19 34 Rutsiro 30 70 100 Total 62 78 140 Total 92 155 247 Total 129 252 381 Percentage 44% 56% 100% Percentage 37% 63% 100% Percentage 34% 66% 100% AF = additional financing; FRDP = Feeder Roads Development Project; RUDP = Rwanda Urban Development Project. 16 5. STRENGTHS OF THE PROJECTS’ GRIEVANCE REDRESS MECHANISMS 5.6. Capacity Building for Grievance Redress Committees As evidenced by the statistics presented in table 5.2, both the FRDP’s and the RUDP’s GRC members benefitted from the training provided by PIU social specialists on topics including: 3 Rwanda’s expropriation law and how it differs from the World Bank’s involuntary resettlement policies (for example, the Rwandan law does not provide for compensation for the economic assets of squatters who informally occupy land without a title, while the World Bank mandates compensation for such informal settlers, with Bank policy Photo 5.1. RUDP GRC training session in the secondary city taking precedence and with compensation being determined of Huye by applying appropriate instruments, such as resettlement action plans); 3 Community health and safety measures; 3 Grievance recording in logbooks; 3 Gender-based violence, sexual exploitation and abuse, and 3 Assessment, management, and resolution of grievances; and sexual harassment; 3 Hierarchy of grievance reporting. 3 Roles and responsibilities of the GRC in receiving, assessing, and resolving complaints; TABLE 5.2. GRC TRAINING STATISTICS OF FRDP (2017 AND 2020) AND RUDP (2019) Phase 1 (2017) Phase 2 (2019) Phase 2 (2019) Phase 3 (2021) FRDP: District Women Men FRDP: District Women Men RUDP: Secondary City Women Men Women Men Rwamagana (refresher) 26 50 Gakenke 25 35 Huye 8 8 6 7 Rwamagana 28 42 Gatsibo 23 54 Muhanga 9 6 8 10 Nyamasheke 14 20 Nyabihu 28 52 Musanze 8 11 8 8 Karongi 12 25 Nyagatare 32 8 Nyagatare 8 11 10 6 Gisagara 12 18 Nyaruguru 31 59 Rubavu 12 20 7 11 Rutsiro 95 139 Rusizi 15 19 9 10 Total 92 155 Total 234 347 Total 60 75 48 52 Percentage 37% 63% Percentage 40% 60% Percentage 44% 56% 48% 52% 17 5. STRENGTHS OF THE PROJECTS’ GRIEVANCE REDRESS MECHANISMS 5.7. Institutionalizing Project-Level 3 Projects funded by the Islamic Development Bank for the GRMs Rubengera–Rambura road in Karongi District and the Kabuga– Tyazo-Kibogora road in Nyamasheke District; A procedures manual for the environmental and social management of transport projects, developed by the Rwanda 3 The Rubavu–Bralirwa–Burushya road project in Rubavu Transport Development Agency (RTDA)—the implementing District, funded by the African Development Bank; and agency for the FRDP—emphasizes the importance of the GRM 3 The Lake Kivu Water transport project, funded by TradeMark in ensuring that transport infrastructure is constructed and East Africa. operated in a sustainable manner and in compliance with national and international requirements and standards. The Such a development serves as testimony to the positive manual is currently in a final draft form and may soon be perception and effectiveness of GRMs operated under FRDP operationalized, at which time it would apply to all national and other World Bank-financed projects implemented by the transport-related infrastructure projects in Rwanda. RTDA. This step toward embedding the GRM into country systems may later be emulated by the Local Administrative The RTDA has already integrated the GRM outside of World Entities Development Agency and other sister institutions and Bank-supported operations, including in: may eventually be adopted as standard practice for national development projects. 18 6 Areas in Need of Improvement 6.1. Accessibility for the Vulnerable adequate budget planning and financial resource allocation, and Marginalized which would have been paramount to allow for faster processing of compensation payments to GRM users who filed complaints Although the environmental and social risk management linked to unsatisfactory compensation amounts. Such delays instruments of the Feeder Roads Development Project (FRDP) have resulted in conflicts between costs induced by the GRM and the Rwanda Urban Development Project (RUDP) provide for and other responsibilities, such as social protection and local consultations with vulnerable and marginalized individuals and economic development activities. groups, including the elderly, people who are illiterate, widows, child-headed households, and people without land titles and/ or bank accounts, at the time of this writing, the projects’ 6.3. Timely Establishment of Grievance respective grievance redress mechanisms (GRMs) did not include Redress Committees and Capacity any special provisions to ensure their easy accessibility by a Building variety of vulnerable and marginalized individuals and groups. Both the FRDP and the RUDP were delayed in establishing A stronger emphasis on making the GRM more accessible to and training grievance redress committees (GRCs), negatively people with disabilities, including those with vision and hearing impacting the timeliness of grievance redress for project- impairments, as well as those with low levels of literacy, as affected people. GRCs should be formed and trained as soon examples, would be useful. Options to explore going forward as resettlement action plans have been approved. Monitoring include providing special assistance to people with disabilities reports cite the lack of awareness among the relevant district by, for example, engaging employees fluent in sign language; officials and other GRM stakeholders of its procedures as a offering communication materials that are easily understood by challenge in the early years of project implementation. This people who are illiterate (e.g., using explanatory illustrations), finding was corroborated in an interview with a GRC member: and developing procedures that allow a person to submit a “District officials do not appreciate the project GRM and the grievance on behalf of another person. GRC as an essential instrument for the success of the project.” District officials are perceived as not valuing the role and 6.2. Timely Involvement of District function of GRCs. Consequently, the RUDP report of February 6, Officials 2019, on the implementation of the abbreviated resettlement RUDP reports indicate that resettlement action plans, action plans recommends that workshops be conducted for all particularly the provisions related to the compensation of stakeholders, with the aim of improving the understanding of project-affected people for involuntary resettlement, have not best practices for involuntary resettlement in grievance redress been communicated to districts quickly enough to allow for prior and during project execution. 19 6. AREAS IN NEED OF IMPROVEMENT 6.4. Compensation for Grievance 6.5. Data Collection, Analysis, and Redress Committee Members Reporting The lack of an allowance for a GRC member during RUDP’s first Project implementation unit (PIU) social specialists phase has been cited as an issue of concern. Several RUDP and produce activity reports, including resettlement action plan FRDP GRC members who were interviewed cited the lack of implementation reports, in which issues such as planning insimburamubyizi (the Kinyarwanda word for the compensation gaps are identified and targeted recommendations made. of a lost workday and for the facilitation of communications) as 1 For example, this study’s recommendation to integrate key a challenge to GRM implementation. district planning with project preparation was adopted from the RUDP’s implementation completion report on its resettlement In response, the second phase of RUDP made budget allocations action plan. However, no special provisions have been made from the project to provide a certain degree of compensation to for the monitoring and reporting of issues unrelated to the GRC members starting with project effectiveness in mid-2021. resettlement action plans, meaning that GRM data are currently The FRDP paid the allowances out of project funds during its only reported within the resettlement action plan monitoring first phase, but challenges related to office time and travel due and reporting framework. to the COVID-19 pandemic resulted in delays. During its second phase, the FRDP also made provisions to compensate GRC Grievance resolution timeframes could not be established here members. Both projects now indicate that allowances are being because the available information is in hardcopy logbooks, paid to their respective GRC members. 2 which are kept at district offices. A sample of the logbooks obtained for this case study mostly reveal barely legible As previously noted, GRMs are provided for by Law No. 32/2015 handwriting. Thanks to the initiative of the FRDP’s and RUDP’s of June 11, 2015, regarding expropriation in the public interest. social safeguards officers, the systematic use of logbooks by all A regulation is under development to guide operations of the GRCs to register grievances and actions taken towards grievance GRCs for project GRMs. Regardless of the funding sources— resolution markedly improved in 2020, but prior to that the whether they be the government of Rwanda, development record is somewhat piecemeal. In addition, because grievance finance and assistance institutions, or multilateral and bilateral resolution under both projects entails cash compensation, development banks—compensation for GRC members comes confidentiality must be ensured. District authorities therefore from project budgets as a matter of good practice. The lessons maintain the records of grievance resolutions and only share learned from the World Bank-supported projects presented them with PIUs upon request. Because of this, data on the in this study could influence the form and application of the resolution of grievances are not currently being analyzed. regulation. As previously mentioned, the Rwanda Transport Neither the FRDP nor the RUDP have provisions for obtaining Development Agency (RTDA) has already taken steps to feedback on the satisfaction level of complainants regarding mainstream the GRM into all its projects through a procedures grievance redress. manual for the environmental and social management of transport projects. 1. This observation was featured in the February 2019 abbreviated resettlement action plan implementation report for RUDP Phase 1. 2. FRDP pays GRC members a monthly facilitation fee of 6,000 Rwandan francs (US$6). RUDP pays GRC members a monthly facilitation fee of 5,000 Rwandan francs (US$5). If GRC members are invited to attend trainings in another sector or at the district level, they are reimbursed for lunch and transportation, with the allowance for the latter ranging from 10,000 to 15,000 Rwandan francs (about US$9.62–1,443) per day. 20 6. AREAS IN NEED OF IMPROVEMENT Investing in digital logging of grievances could therefore prove World Bank’s portfolio tracker Geo-Enabling Initiative for to be a good investment to improve the monitoring of GRM Monitoring and Supervision (GEMS).1 In this vein, the FRDP’s implementation. A feedback facility could be developed and PIU recently recruited a consultant to conduct a survey on the integrated into the GRM to gather information on satisfaction satisfaction level with the GRM among project-affected people; levels as a means for continuous evaluation and improvement the survey’s results are expected to be included in the fiscal of the service. A digital data collection, analysis, reporting, and 2022 reporting framework. As RTDA prepares to launch the newly feedback facility could be developed and integrated into the developed institution-level procedures manual for environmental GRM to better monitor grievance registration and resolution and social management of transport projects, an opportunity rates and to improve the quality of resolution based on the emerges for the adoption of the open source-based GEMS for feedback of complainants. An example of such a tool is the efficient monitoring and effective grievance redress. 1. GEMS offers a method for enabling project teams to use simple open-source tools to collect structured digital data directly from the field. These data automatically feed into a centralized monitoring and evaluation (M&E) system, allowing for the integration of grievance redress into the project’s system. The tool is adaptable and could integrate a complainant feedback facility to collect data on satisfaction levels of grievance resolution. Some World Bank-supported projects in Rwanda use GEMS in the field to facilitate remote supervision, especially regarding risk and safeguard monitoring and beneficiary engagement. 21 7 Conclusion and Recommendations When implemented with the support of existing legal and This study recognizes the laudable initial steps taken by the decentralized governance structures, project-level grievance implementing agencies of the Feeder Roads Development redress mechanisms (GRMs) can be highly effective and citizen- Project and the Rwanda Urban Development Project toward led. The close alignment between the GRM and local governance institutionalizing their GRMs beyond short-term projects and structures ensures easy access to local community engagement highlights the opportunity for the World Bank to leverage its frameworks for communication and awareness-raising as well as convening power to provide input into the regulatory guidelines for the adoption of multiple grievance uptake channels. that will operationalize GRMs in Law No. 32/2015 of June 11, 2015. This development reinforces the lesson that the support Gender inclusion, ideally through the leveraging of national of legal instruments can lead to the mainstreaming of GRM as policy and legal frameworks, can also enhance the effectiveness a good practice to ensure the greater sustainability of positive of a GRM. The example of Rwanda shows how trust can be built project impacts. in terms of addressing grievances related to gender-based- violence by relying on women’s representatives elected at the To enhance the accessibility of the GRM to the vulnerable community-level, with proper training, and with legal backing. and the marginalized, proposed approaches include engaging employees with appropriate sign-language skills to assist This case study highlights the importance of involving people with impaired hearing, engaging employees with drawing projects’ social safeguards specialists in the capacity building and other specialized communication skills to assist those who of grievance redress committees (GRCs) and relevant local cannot read, and allowing for the appropriate use of proxies to administration officials to ensure the proper functioning and assist people with other types of vulnerabilities. success of the GRM. 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Kigali: Republic of Rwanda. https://documents1.worldbank.org/ curated/en/353091598031382560/pdf/Labor-Management-Procedures-Second- Rwanda-Urban-Development-Project-P165017.pdf. 23 SUPPORTED BY © 2022 International Bank for Reconstruction and Development/The World Bank 1818 H Street NW, Washington, DC 20433 202-473-1000 | www.worldbank.org Some rights reserved. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent. The World Bank does not guarantee the accuracy of the data included in this work. Nothing herein shall constitute or be considered to be a limitation upon or waiver of the privileges and immunities of The World Bank, all of which are specifically reserved. Rights and Permissions The material in this work is subject to copyright. 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