Who approves a RAP, and what are they checking?

Usually two bodies: a national authority, and the lender financing the project. They approve against different criteria — the national process checks compliance with domestic acquisition law, the lender checks compliance with its own standard — and a plan can satisfy one while failing the other.

What the national authority checks

That the acquisition is for a permitted purpose, that the process was followed, that valuations were prepared by qualified valuers on the accepted basis, and that the award is properly authorised. In several jurisdictions a state valuation function must endorse the figures before an award can be made, which is frequently the longest single step in the whole programme.[4]

What the lender checks

Something different: whether the plan will actually restore the people it displaces. In practice, a reviewer works through a consistency check —

• Do the affected-population figures agree across the document?
• Does the entitlement matrix cover every category the census found, including tenants, sharecroppers and people with no title?[1]
• Is the valuation basis stated, and benchmarked against replacement cost?[2]
• Does the budget reconcile to the entitlements, with a funding source?
• Is the cut-off date fixed, disclosed and evidenced?
• Does the schedule pay before it displaces?
• Is livelihood restoration an outcome commitment with a baseline behind it?
• Is the grievance mechanism operating before offers go out?

Most findings come from that list, and almost all of them are internal contradictions the drafting team could have caught by reading their own document with the same question in mind.

Where the Equator Principles come in

For commercially financed projects, the banks involved commonly apply the IFC Performance Standards as their reference framework. The review is then conducted by or for the lenders, and approval becomes a condition precedent in the finance documents — which is what gives it teeth.[5]

Disclosure is part of approval

A plan is not properly approved until it has been disclosed — publicly, in the local language, before implementation — and any comments received have been addressed.[3]

If you are affected by a project and cannot obtain the plan, that is not a confidentiality matter. It is a compliance one, and worth raising through the grievance mechanism and, if necessary, with the lender directly.