Planning before the footprint is known: the Resettlement Policy Framework
Reviewed for publication
Abstract
Where a project's physical footprint is not known at appraisal — a programme of subprojects, a corridor whose alignment is unfixed, a facility whose site is still under selection — a resettlement action plan cannot be prepared, because the people it would cover cannot yet be identified. Lenders address this with a Resettlement Policy Framework: an instrument that fixes eligibility, entitlements, valuation method and process in advance, binding whatever plans are later prepared. This paper examines what an RPF must settle to be useful, why the instrument is structurally vulnerable to becoming a device for deferring decisions rather than pre-committing them, and what distinguishes legitimate deferral from avoidance.
1. The problem of the unknown footprint
A resettlement action plan is built on a census: an enumeration of the people affected and what each stands to lose. Where the footprint is unknown, that census cannot be conducted, and a plan cannot be written. This is not a deficiency in project preparation but a common feature of certain project types — a rural electrification programme whose subprojects are selected annually, a road whose final alignment depends on detailed design, a water scheme whose intake location is still under study.
Requiring a plan regardless would produce a fictional document, and lenders instead accept a framework: an instrument that does not identify affected people but binds the treatment they will receive once identified. [1][4] The subsequent plans, prepared when each footprint is fixed, must conform to it.
The framework therefore does prospectively what a plan does retrospectively. It settles the rules before anyone knows who they will apply to — which, correctly used, is a stronger position than settling them once the affected population is known and the cost of each rule can be calculated.
2. What must actually be settled
A framework earns its place by deciding things, and the decisions that matter are the ones that will be contested later. Eligibility is first: which categories of person are entitled to what, including those without formal title, tenants, labourers, users of common resources, and those present before a cut-off yet to be set. A framework that restates the standard's language on eligibility without applying it to the tenure realities of the country in question has decided nothing. [2]
Valuation method is second and is where frameworks most often equivocate. A framework that commits to replacement cost, states how replacement cost will be derived for each asset class, and specifies that depreciation and salvage will not be deducted has constrained the later plans. [3] One that says compensation will be at rates determined in accordance with applicable law has deferred the substantive question, since applicable law in many jurisdictions produces figures below replacement cost.
Third is process: how the cut-off will be set and notified, how grievances will be handled, what the disclosure obligations are, and who is responsible for each. These are the provisions that make the framework auditable, because they generate artefacts that either exist or do not.
3. Legitimate deferral and its abuse
The instrument's structural vulnerability is that deferral is its purpose, which makes over-deferral difficult to detect. A framework that defers the identification of affected people is doing what it is for. One that defers the entitlement matrix, the valuation approach or the treatment of informal occupants to the subsequent plan has deferred the parts that were supposed to be decided in advance, and provides no constraint at all.
The abuse is rarely explicit. It appears as language committing to determine entitlements at the time of plan preparation, in consultation with affected communities and in accordance with national law. Every clause is unobjectionable and their combination leaves every substantive question open, to be settled later by whoever is preparing the plan under budget pressure.
A useful diagnostic is to ask what the framework would prevent. If a subsequent plan could adopt a narrow eligibility definition, deduct depreciation, and exclude informal users without contradicting anything in the framework, then the framework is not binding the outcome and its approval has not secured what approval was taken to secure.
4. The gap between framework and plan
Frameworks are approved at appraisal and plans are prepared later, sometimes years later, by different people. The gap is where conformity is lost — not usually by open departure, but by drift: a plan prepared without close reference to the framework, adopting the preparer's customary approach, and reviewed by someone who does not hold the framework in mind.
This argues for an explicit conformity step: each plan accompanied by a demonstration, provision by provision, that it implements the framework, and a review that tests that demonstration rather than only the plan's internal quality. Where projects do this, the conformity table itself becomes one of the more useful documents in the file.
There is also a temporal problem. A framework prepared before a change in national law, in market prices, or in the lender's own standards may bind later plans to a superseded position. Frameworks with long lives need a stated review trigger, absent which they either become a ceiling that is quietly ignored or a constraint that produces outcomes nobody now defends.
5. Conclusion
The World Bank's framework uses the same pre-commitment logic for projects with an undefined footprint. [6][5] The Resettlement Policy Framework is an instrument for pre-commitment, and pre-commitment is valuable precisely because it is made before the costs are known. A framework drafted with that understanding constrains a project usefully for a decade. One drafted as a placeholder to satisfy an appraisal requirement produces the appearance of a safeguard while leaving every decision to be taken later, under exactly the pressures the framework existed to resist.
The difference is visible on the page, and testable by a single question: what does this document stop anyone from doing?
References
- [1]Performance Standard 5: Land Acquisition and Involuntary Resettlement. International Finance Corporation, 2012.
- [2]Guidance Note 5: Land Acquisition and Involuntary Resettlement. International Finance Corporation, 2012.
- [3]Good Practice Handbook: Land Acquisition and Involuntary Resettlement. International Finance Corporation, 2023.
- [4]ESF Guidance Note 5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement. World Bank, 2018.
- [5]Environmental and Social Standards (ESS). World Bank, 2018.
- [6]The World Bank Environmental and Social Framework. World Bank, 2017.
Related papers
- When economic displacement travels alone: the standalone Livelihood Restoration Plan
- The Process Framework: displacement by restriction rather than acquisition
- The entitlement matrix: the document that decides everything else
- No-objection and clearance sequencing: the gates a resettlement programme passes through