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difficulties in understanding the audit and compensation process,AP appointed the Operational Team (as previously discussed), andthen, in support of grievance management, two CLOs from eachcommunity.In spite of these efforts, it is the finding of this review that overall,the Motlhotlo consultation process falls short of IFC performancestandards for consultation, in particular with regards to therequirement for free, prior and informed consultation, and for aconsultation process that is inclusive and appropriate to affectedresidents. These weaknesses are outlined below.Consultation to be Based on Prior Disclosure of Relevant andAdequate Information, thus Enabling Informed Participation andConsentAgreement to relocateConcerns around free, prior and informed consultation go as farback as the community agreement to relocate in 1992. Althoughthe decision to relocate was a negotiated process, involving theMapela Tribal Authority (MTA) and the community appointed RSCs,and culminating in a community resolution to relocate, concernshave emerged as to whether this was done with a full understandingof the implications of this decision. The Municipality commentedthat the communities could never have understood the scale ofthe resettlement in terms of the impacts on their lives, when firstpresented with the idea. A hope for a better quality of life andfinancial reward may have overshadowed any possibility of criticalthinking about what it meant to resettle.In this regard, it is unclear whether the Kgoshigadi was either willingor had sufficient knowledge to be able to facilitate discussionsand raise awareness among community residents on the potentialnegative impacts of resettlement. ERM are also uncertain regardingthe extent to which AP raised awareness about the negativeimpacts of resettlement, based on their recent experience with GaPila. Typically, an EIA should provide an education function in thisregard. However, the timing of the EIA (starting in September 2002)meant that the findings of the impact assessment and associatedidentification of the impacts of resettlement were not fed back to thecommunity residents in time to inform their decision to move (firsttaken in October 2002). The extent to which informed consent wasfully given to the relocation is thus uncertain.Weaknesses in the audit and compensation processIn spite of the successes of some parts of the audit andcompensation process, concerns remain regarding the extentto which people fully understood the audit and associatedcompensation process. This is certainly reflected in the frequentlyheard claim among community respondents that ‘they didn’t knowwhat they were signing’ (in reference to the signing off on auditfindings). In fact, the perception that AP exploited the illiterateand those with a lack of educational capacity to understand thecompensation process, is at the root of many of the allegations madeby certain of the community residents and resistance groups towardAP. Notwithstanding these allegations, it is recognised that extensiveefforts were made by AP, and within a challenging context of highlevels of illiteracyBoth the Project Management Team and the construction contractoridentified illiteracy of community residents and competency of theOperational and Community Relations Teams as major obstaclesin the translation of the results of the household audits into houseplans. This resulted in unmanaged expectations around how theplans translated into built physical structures. These expectationsresulted in disappointment, frustration and even resistance.These misunderstandings and unmet expectations could perhapshave been avoided with better community education priorto starting the audit, and by the use of community relations/communications specialists in roles that were being filled by nonsocialspecialists, (i.e., architects, engineers, quantity surveyors, localresidents etc). Feedback received from the construction contractorwas that the Operational Team and the Community Relations Teamstruggled to translate the technical information relevant to theaudit and compensation process into a form understandable for thecommunity residents.Given the widespread illiteracy and low levels of education in thesecommunities, ERM are of the opinion that a more systematic preeducationprogramme for the Operational Team, the CommunityRelations Team, and the community should have been considered,facilitated by the required social specialists.Effectiveness of the S21sThe consultative and participatory approach adopted by APwas undermined by the fact that the main vehicle used forcommunication (i.e., the S21) was not appropriate or effective inensuring adequate disclosure of information to the majority ofcommunity residents they were elected to represent. The reasonsfor this failure would appear to be due to the S21s’ reported poorperformance as a consultative body, linked in part, to an apparentlack of capacity amongst its members.In spite of the S21’s intended role as a feedback mechanism, it hasbeen widely criticised for its failure to serve as an accountable,consultative and transparent communication structure.Conversations held with community respondents, the communitylegal advisors and the construction contractors indicate that theix

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