SOMALILAND_NATIONAL_LAND_POLICY_SCOPING
SOMALILAND_NATIONAL_LAND_POLICY_SCOPING
2
Summary
1.
A
National
Land
Policy
(NLP)
needs,
as
a
starting
point,
a
classification
of
land
types.
The
simplest
option
is
to
frame
overall
policy
for
just
three
classes
of
land:
communal,
private
and
public.
Additional
sub-‐classes
will
be
needed,
but
only
for
matters
of
detail.
2.
Somaliland
has
experienced
a
very
rapid
increase
in
the
number
and
extent
of
private
land
holdings
(privatization)
since
1991.
An
NLP
might
be
expected
to
state
government’s
view
on
how
sustainable
this
is
and
whether,
and
where,
there
should
be
any
limits.
3.
Privatization
is
accompanied
by
uncertainties
as
to
the
respective
legal
force
and
jurisdiction
of
customary
and
statutory
law,
in
particular
Xeer,
which
governs
usufruct
rights
to
communal
grazing.
This
has
particular
reference
to
enclosures
(see
10,
below)
4.
At
least
four
Ministries
(Internal
Affairs,
Public
Works,
Agriculture
and
Environment)
are
directly
involved
in
land
administration,
with
powers
and
responsibilities
under
separate
Laws.
These
pieces
of
legislation
do
not
always
interlock
neatly
–
as
analysed
in
Report
3.
5.
Other
Ministries
are
also
represented
on
the
National
Land
Planning
Committee
but
this
potentially
influential
institution
meets
rarely
and
does
not
seem
to
lead
to
action.
6.
Decentralisation
of
local
government
has
produced
an
uncoordinated
urban
land
administration
system,
to
a
large
extent
operating
independently
of
central
government.
7.
There
is
no
national
land
registry
and
the
extent
and
impact
of
rapid
urban
sprawl
is
not
captured
in
any
national
data
set.
This
lack
of
transparency
hinders
understanding
of
the
problem
and
the
development
of
suitable
policies
to
deal
with
it.
8.
Laws
governing
the
administration
of
urban
land
assume
the
existence
of
a
masterplan
for
all
urban
settlements.
In
many
cases
these
do
not
exist
or
are
out
of
date.
Capacity
to
produce
them
is
limited
and
is
located
in
the
central
Ministry
of
Public
Works,
not
within
the
local
government
system
which
must
use
them.
9.
Experience
with
titling
individual
farms
has
been,
on
the
one
hand,
positive
in
terms
of
public
appreciation
and,
on
the
other,
something
of
a
missed
opportunity,
with
too
much
executive
responsibility
left
in
the
hands
of
an
NGO
with
good
ideas
but
limited
capacity.
10.
Enclosures
of
communal
rangeland
are
a
hot
issue;
the
law
is
contradictory
and
needs
clarification,
in
conjunction
with
a
review
of
its
relation
to
customary
law
(see
3,
above).
11.
There
are
few
opportunities
for
professional
development
of
the
land
professions
–
surveyors,
brokers,
notaries
–
all
of
whom
play
key
roles
in
land
administration
12.
Property
taxes
are
a
major
element
in
municipal
finance
and
are
the
subject
of
the
most
innovative
current
development
in
land
administration,
the
UN-‐JPLG2
GIS
programme.
13.
It
is
important
to
recognize
that,
notwithstanding
the
issues
outlined
above,
there
are
functional
systems
in
place
and
a
new
NLP
need
not
necessarily
aim
at
total,
radical
reform.
2
UN
multi-‐agency
Joint
Programme
on
Local
Governance
and
Decentralized
Service
Delivery
–
see
section
9.
3
1 Introduction
1.1 Objective
and
Purpose
of
the
Study
This
is
one
of
six
reports
prepared
by
the
Rift
Valley
Institute
(RVI),
with
support
from
the
Somaliland
Development
Fund
(SDF),
that
are
intended
to
provide
the
Government
of
Somaliland
with
up
to
date
information
on
all
aspects
of
land
governance
in
Somaliland
that
will
inform
a
national
land
policy
development
process.
The
other
reports
cover:
1.
Historical
and
Cultural
Analysis
2.
Comparative
Case
Studies
3.
Legal
and
Policy
Framework
4.
Land
Conflict
Dynamics
5.
Land
Resources,
Use
and
Economy
6.
Land
Tenure
and
Administration
These
reports
examine
past
and
on-‐going
land
policy
and
regulatory
frameworks
and
the
political,
social,
physical,
economic,
cultural
and
institutional
factors
impacting
on
governance
in
Somaliland.
Together
they
are
intended
to
inform
a
Land
Policy
Conference
that
is
expected
to
be
held
in
March
2016.
The
results
of
these
deliberations
will
be
incorporated
into
a
final
summary
report
outlining
a
road
map
towards
a
successful
land
policy.
This
will
include
an
indicative
draft,
or
skeleton,
national
land
policy
(NLP),
for
the
Government
of
Somaliland’s
further
consideration.
It
is
expected
that
these
will
only
be
the
first
steps
along
a
long
road.
1.3 Methodology
The
study
is
based
on
results
from
extensive
field
research,
described
in
detail
in
Report
4
in
the
series
on
Conflict
Dynamics,
involving
110
focus
group
discussions
and
162
key
informant
interviews
with
stakeholders
in
all
regions
of
Somaliland.
This
was
complemented
by
interviews
with
key
informants
in
the
Somaliland
Government
and
development
partners,
and
a
literature
review.
This
report
makes
extensive
use
of
quotes
from
Somaliland
Law
in
English
translation.
The
language
of
Law
is
Somali
and
these
translations
are
not
official
or
definitive.
They
are
used
in
good
faith
with
the
caveat
that,
through
errors
in
translation,
they
may
not
be
entirely
accurate
representations
of
the
law
in
every
aspect.
4
National
Land
Policy
(NLP)
is
not
a
sufficient
remedy
for
this
challenge
but
it
should
be
a
necessary
first
step.
2 Land
Classification
The
position
on
what
classes
of
land
are
recognized
is
confusing
and
it
may
be
that
no
single,
agreed
formal
land
classification
exists.
One
opinion3
is
that
Law
No.
15
of
25th
January
1969
is
still
in
force,
recognizing
“two
main
categories,
namely
aqua
land
and
terrestrial
land.
Terrestrial
land
is
further
divided
into
rural
and
urban
land
while
rural
land
is
further
divided
into
agricultural
land,
pastoral/rangelands,
forests
and
wetlands.”
More
recent
attempts4
at
a
national
land
policy
have
proposed
the
following:
Draft
Land
Tenure
Policy,
20085
1) Grazing
land:
a
field
covered
with
grass
or
herbage
and
suitable
for
grazing
by
livestock.
2) Pastureland:
is
an
area
with
lush
herbaceous
vegetation
cover
used
for
the
grazing
of
ungulate
livestock
as
part
of
a
farm
or
ranch.
3) Agricultural
land:
refers
to
areas
of
land
in
which
agriculture
is
recognized
as
the
priority
use.
Farming
is
encouraged
and
non-‐agricultural
uses
are
controlled.
4) Rangeland:
a
large,
mostly
unimproved
section
of
land
that
is
predominantly
used
for
livestock
grazing.
This
is
land
on
which
the
natural
vegetation
is
dominated
by
native
grasses,
grass-‐like
plants,
forbs,
and
shrubs.
Rangeland
also
consists
of
areas
seeded
to
native
or
adapted
introduced
species
that
are
managed
like
native
vegetation.
5) Conservation
land:
an
area
that
is
fenced-‐off
or
closed-‐off
from
common
use
for
the
protection
and
conservation
of
particular
endemic
and
endangered
natural
resources
(e.g.
plants,
animals,
land,
energy,
minerals)
or
of
historical/archaeological
artefacts
(e.g.
paintings,
monuments,
etc)
for
the
future.
(see
7.1)
6) Mining
land:
a
natural
deposit
of
ores,
coal,
precious
stones
where
such
minerals
are
extracted
or
obtained
either
by
excavation
or
by
washing
the
soil
7) Urban
land:
is
an
area
with
a
relatively
higher
population
density
of
humans
in
comparison
to
the
areas
surrounding
it
known
as
rural
areas.
As
such,
urban
areas
also
constitute
increased
density
of
human-‐created
structures
than
rural
areas.
8) National
Parks:
land
that
is
set
aside
for
the
preservation
of
unique
landscapes
for
the
pleasure
of
the
people.
The
land
may
vary
in
sizes
and
natural
characteristics
as
well
as
the
usage
for
which
it
is
particularly
preserved.
9) Graveyards:
an
area
that
is
specifically
designated
as
burying
ground
where
dead
bodies
or
remains
are
buried.
Shall
be
respected
and
protected
by
the
state;
a) Graveyards
of
all
religions
shall
be
equally
respected
and
protected;
b) Specific
land
shall
be
allocated
for
graveyards
in
all
urban
settlements;
c) The
Minister
of
Religious
Affairs
and
local
municipalities
shall
be
responsible
for
the
protection
of
graveyards
and
the
use
of
land
allocated
for
graveyards;
d) The
Minster
of
Religious
Affairs
shall
issue
regulations
on
protection
of
graveyards
and
use
of
land
designated
for
graveyards.
10) Public
works
land:
an
area
where
public
buildings,
roads,
bridges,
dams,
housing
developments
are
constructed
or
engineered
by
the
state
on
behalf
of
the
community.
11) Leisure
and
recreational
land:
areas
of
open
space
provided
for
recreational
use
and
resembling
open
woodlands
where
trees
are
chosen
for
their
beauty
and
shade.
3
Agwanda
&
Hersi,
Evaluation
of
Somaliland
Secure
Land
Tenure
Arrangements
Project,
for
UNDP,
2012
4
see
Report
3
in
this
series,
Legal
&
Policy
Framework
Penha
&
VetAid,
for
Ministry
of
Agriculture
and
(former)
Ministry
of
Pasture
Development
and
Environment
5
5
12) Religious,
historical
and
archaeological
sites:
a) Shall
be
under
the
direct
preservation
and
protection
of
the
Government;
b) The
Minister
of
Tourism
and
Heritage
shall
be
mandated
to
declare
any
new
sight
of
historical,
archaeological
or
cultural
value
as
a
protected
area.
13) Hazardous
land:
an
area
that
is
designated
as
unsafe
by
appropriate
authorities
for
the
settlement
or
subsistence
of
humans
as
a
result
of
either
human-‐made
causes
such
as
the
disposal
of
toxic
substances
that
contaminate
or
pollute
the
environment
or
natural
threats
such
as
earthquakes,
volcanoes
and
landslides
that
threaten
human
safety.
A
more
conventional
approach
was
included
in
the
Land
&
Urban
Management
Institute’s
(LUMI)
proposed
draft:
Land
Policy
Draft,
LUMI,
2011
a. Urban
land
b. Agricultural
Land
c. Pastoral
land
d. Public
Infrastructure
land
highway,
ROW
(Rights
Of
Way)
for
Communications
e. Land
of
minerals
&
natural
resources
f. Industrial
land
g. Coastal
land
h. Airfields
land
i. Sensitive
land
j. Bad
land
k. Special
Development
purposed
land
(Note
that
this
proposed
classification
also
appeared
in
the
earlier
version
from
the
National
Land
and
Urban
Planning
Committee,
2001)
The
2008
version
is
surely
too
elaborate,
and
unnecessary.
Even
the
simpler
proposal
from
LUMI
may
be
cutting
the
issue
too
finely.
The
risk
is
that,
once
we
start
sub-‐dividing,
we
can
always
think
of
a
piece
of
land
or
situation
that
is
different
from
others.
This
is
natural,
as
every
parcel
of
land
is
unique
and
some
degree
of
sub-‐division
will
be
appropriate
in,
for
example,
detailed
town
or
land
use
planning.
For
overall
policy
purposes
it
may
be
sufficient
to
recognize
only
three
broad
classes
of
land:
communal,
private
and
public6.
All
the
longer
lists
above
could
fit
into
these
three,
as
sub-‐classes,
only
as
and
when
needed
and,
perhaps,
mainly
at
the
regulation
level.
Certainly
the
NLP
will
have
to
distinguish
agricultural
from
pastoral,
housing
from
industrial,
forest
reserve
from
littoral
and
so
on.
But
it
is
useful
to
start
with
the
broadest
focus,
only
narrowing
it
down
when
strictly
necessary.
3 Land
Tenure
Land
tenure
is
the
English
term
used
to
describe
the
legal
arrangements
(or
status)
under
which
a
person
(legal
or
natural
–
i.e.
corporate
or
private
individual)
owns
land.
It
comes
from
the
French
“to
hold”,
with
the
“tenant”
or
holder
being
someone
who
holds
the
consent
to
occupy
land,
of
the
Crown
(or
King/Queen)
who,
in
ancient
feudal
law,
was
believed
to
be
endowed
with
all
land
by
6
This
is
the
practice
followed
in
the
Kenyan
NLP
(and
law,
including
the
Kenya
Constitution)
6
God.
Many
forms
of
land
ownership
have
evolved
in
different
societies
and
the
word
is
now
used
in
a
very
general
sense,
which
does
not
refer
directly
to
English
common
law.
7
Law
17
has
nothing
specific
to
say
about
communal
tenure,
reasonably
enough
as
it
is
about
urban
land,
where
private
ownership
is
the
rule.
Nevertheless,
Article
1
can
be
read
as
asserting
the
primacy
of
statute
over
customary
law.
It
is
not
clear
that
‘the
nation’,
with
its
continued
adherence
to
Xeer,
has
fully
assented
to
this.
The
NLP
must
confront
this
problem,
with
policies
on
the
respective
jurisdictions
and
force
of
the
two
legal
systems.
8
Article
No.
2
Authority
of
Issuing
Titles
1.
Management
and
issuance
of
plots
in
urban
centers
in
Somaliland
is
for
the
local
authority
(The
Executive
Branch
of
the
local
authority).
2.
The
Management
of
Public
land,
such
government
offices
and
houses,
diplomatic
buildings,
factories
and
ex-‐Shacab
Area
is
for
the
Central
Government.
3.
There
will
an
office
representing
the
National
Land
Planning
Committee,
headquartered
in
the
Ministry
of
Public
Works
and
Housing
at
National,
Regional
and
District
levels.
3.6 Leasehold
There
are
no
figures
on
this
but
we
believe
that
most
people
who
live
in
Hargeysa
rent,
rather
than
own,
their
homes.
One
of
the
research
team
thinks
it
could
be
as
high
as
80%,
on
the
basis
of
discussions
with
the
different
community
sectors,
but
there
is
no
hard
evidence
or
empirical
data
to
support
the
estimate.
The
proportion
would
probably
be
lower
for
smaller
towns.
Whatever
the
correct
figure,
it
may
be
that
such
tenants
number
in
the
hundreds
of
thousands.
No
law
protects
them,
they
rarely
have
any
more
than
a
verbal
agreement
with
their
landlords
and
can
be
thrown
out
at
any
time.
Though
many
landlords
are
probably
decent
people,
only
this
decency
and
self-‐
interest
protect
the
‘rights’
(there
are
none,
really)
of
tenants.
Tenancy
is
rather
on
the
fringes
of
what
is
usually
covered
by
land
policy
but
it
is
a
legitimate
and
common
form
of
land
tenure
and
deserves
to
be
noted
and
addressed.
Shari’a?
These
are
some
responses
to
questions,
in
the
field
survey,
about
the
extent
of
landlessness:
Box
1:
Field
survey
responses
on
the
extent
of
landlessness
“Only
a
third
of
the
population
in
Awdal
own
land
while
the
other
two
are
landless.
There
are
some
people
who
lived
here
for
30
years
and
don’t
own
a
small
piece
of
land”.
(Borama,
Awdal)
“There
are
also
refugees
from
Ethiopia
who
come
and
reside
here,
you
see
many
families
sharing
a
small
piece
of
land”.
(Wajaale,
MJ)
“Your
wealth
determines
whether
you
get
a
piece
of
land
or
you
don’t.
If
you
don’t
have
money,
who
is
going
to
give
you
land!
(Lughaya,
Awdal)
“There
are
a
lot
of
landless
people
in
the
community.
The
reason
is
that
they
didn’t
participate
in
the
earlier
land
grabbings.
They
have
just
realized
that
no
land
was
left
behind”.
(Lasa
Daacawo,
Sahil)
“There
will
always
be
a
landless
people
until
the
government
implements
demarcation
of
land,
and
limit
the
land
someone
can
own”.
(El
Afwayn,
Sanaag)
12
See
section
on
demography
in
Report
5.
9
made.
Yet
it
surprises
many
people
to
learn
how
little
space
the
towns
and
villages
take
up.
SWALIM
has
estimated13
the
total
area
covered
by
urban
settlement
as
4,645
ha,
with
a
further
2,881
ha
in
rural
settlements.
These
figures
are
0.03%
and
0.02%
of
the
total
surface
area
of
Somaliland.
Even
allowing
for
the
undoubted
increase
in
settlements
since
these
estimates
were
made,
they
account
for
a
negligible
share
of
‘land’
as
a
whole
–
less
than
one
tenth
of
one
percent.
The
Regions
and
Districts
Law
No.
23
of
2002,
established
a
decentralized
structure
of
local
government,
the
higher
tiers
of
which
administer
the
ULM
Law
No.
17
of
2001/8.
Central
Government,
through
the
Ministry
of
the
Internal
Affairs
(MoIA)
and
its
Regional
Governors,
exercises
oversight
of
local
government
and
defines
regional
and
district
boundaries
but
otherwise
MoIA
has
few
specific
powers
over
urban
land
administration.
Instead,
authority
over
urban
land
matters,
at
Central
Government
level,
has
been
located
in
a
committee.
The
National
Land
Planning
Committee
could,
and
perhaps
should,
be
the
most
powerful
institution
on
land
matters
in
Somaliland.
It
appears
and
re-‐appears
throughout
the
literature,
sometimes
as
a
“Commission”14,
elsewhere
as
a
“taskforce”
(such
as
the
Inter-‐Ministerial
Committee
with
oversight
of
the
present
study).
But
it
meets
rarely
and
the
results
of
its
deliberations
are
never
communicated
to
stakeholders.
To
outsiders
it
appears
paralyzed
by
inaction.
Urban
Land
Management
Law
No.
17
of
2001/8,
Article
4
National
Land
Planning
Committee
The
master
plan
for
urban
areas
shall
be
approved
by
a
national
committee,
comprising
of
Minister
of
Public
Works
-‐
Chairman
Minister
of
Health
-‐
Member
Minister
of
Agriculture
-‐
Member
Minister
of
Water
and
Minerals
-‐
Member
Minister
of
Interior
Affairs
-‐
Member
Minister
of
Rural
Development
-‐
Member
Minister
of
Communication
and
Postal
Services
-‐
Member
Director
General,
Ministry
of
Public
Works
-‐
Member
After
the
approval
of
the
Committee,
the
plan
will
be
effective
with
the
issuance
of
Presidential
Decree.
4.2 Municipalities
Law
23
establishes
a
graduated
(A-‐D)
structure
of
local
government
entities.
Grade
A
and
B
districts
are
able
to
elect
District
Councils,
headed
by
a
Mayor.
Most
Grade
C
districts
have
also
been
granted
these
powers,
since
the
Law
first
became
effective.
They
are
generally
known
as
Municipalities,
rather
than
Districts,
though
the
terms
(in
English)
are
inter-‐changeable.
They
are
responsible
for
both
the
immediate
areas
of
district
capital
towns
(as
the
name
suggests)
and,
it
seems
(though
this
is
not
at
all
clear),
for
all
lower
tier
settlements
within
the
district,
including
Grade
D
districts
and
smaller
villages.
Table
2:
District
Councils,
numbers,
by
Grade,
as
established
by
initial
legislation,
Law
23,
2002
Region
Capital
town
–
Grade
A
B
C
D
Number
(no
of
21
17
13
9
councillors)
Maroodi-‐Jeex
Hargeysa*
1
Gabiley
-‐
2
3
6
13
Land
cover
of
selected
study
areas
in
Somaliland
and
Southern
Somalia;
FAO-‐SWALIM
project
report
L-‐03,
2007
See,
e.g.,
Agwanda
&
Hersi,
ibid,
for
discussion
of
the
design
of
Phase
III
of
the
MoA-‐UNDP
project,
2011.
14
10
Togdheer
Burco
2
-‐
3
6
Sanaag
Ceerigaabo
2
3
4
10
Awdal
Boorama
1
2
1
5
Sool
Laascaanood
-‐
3
2
6
Saaxil
Berbera
-‐
1
3
5
7
5
11
16
39
*
as
the
national
capital
Hargeysa
City
Council
has
25
Councillors.
Grade
D
districts
are
only
supposed
to
become
effective
when
their
boundaries
have
been
verified.
Municipalities
have
no
authority
(in
land
matters)
over
agricultural,
pasture
or
other
classes
of
land
in
the
district,
though
we
will
see
below
that
they
use
their
powers
to
encroach
extensively
into
farm
and
pasture
land.
Provision
is
made
for
towns
that
have
grown
sufficiently
to
graduate
up
the
scale.
For
example,
Wajaale
(a
rapidly
growing
border
town
and
centre
for
trade
with
Ethiopia),
which
did
not
feature
in
the
original
grades,
now
has
a
Mayor
and
Council.
Hargeysa
has
been
divided
into
four
districts,
which
function
for
land
administration
together
with
the
overall
City
Council;
the
districts
carry
out
preliminary
checks
and
due
diligence,
with
certification
remaining
a
city
function.
Regions
and
Districts
Law
No.
23
of
2002,
Article
67:
1.
Creation,
expansion,
and
increase
of
the
department
of
grades
B,
C,
&
D
will
be
in
accordance
with
evaluations
by
the
Ministry
of
Internal
Affairs
on
the
economic
growth
and
increase
of
income
of
each
district.
In
all,
there
are
now
23
A+B+C
authorities.
They
are
(or
have
become,
de
facto)
the
main
authority
in
land
matters,
in
terms
of
numbers
of
new
titles
issued.
4.3 Powers
under
the
Regions
and
Districts
Law
No.
23
of
2002
The
law
provides
for
every
district
council
to
have
a
sub-‐committee
dealing
with
land
matters,
constituted
slightly
differently,
depending
on
grade.
For
A
and
B
districts
there
is
the
General
Works
Sub-‐committee,
one
of
four
such;
C
and
D
districts
have
only
two
sub-‐committees;
one
of
them,
the
Economic
and
Development
and
General
Works
sub-‐committee,
has
the
same
function.
The
committees
consider
and
make
recommendations
all
applications
for
new
title
but
members
are
explicitly
forbidden
to
sign
documents
pertaining
to
individual
cases,
presumably
for
conflict
of
interest
reasons.
Power
of
signature,
under
Article
33,
is
reserved
for
the
Permanent
Committee,
consisting
of
the
Mayor
(District
Commissioner),
Deputy
District
Commissioner,
Executive
Secretary
and
the
Chairs
of
the
various
sub-‐committees.
Day-‐to-‐day
land
administration
functions
are
in
the
hands
of
the
Executive
Secretary.
11
that,
to
the
best
of
his
knowledge
the
plot
is
not
subject
to
dispute
or
any
other
bar
(for
example,
that
it
has
been
reserved
by
the
Municipality
for
some
other
development).
It
was
observed
that
copies
in
the
registry
were
often
incomplete
and
that
descriptions
of
location
are
very
general.
It
seems
that
some,
perhaps
most,
lower
grade
districts
lack
the
resources
to
maintain
their
own
registry
and
certification
machinery.
Their
sub-‐committees
make
recommendations
to
the
main,
regional,
municipality,
which
then
issues
title,
even
though
it
is
questionable
whether
Law
23
gives
them
this
jurisdiction
over
lower
grade
districts.
There
is
no
central,
national
land
registry15,
though
the
legal
basis
for
establishing
one
seems
to
exist
in
Law
17,
which
gives
a
central
role
to
the
Ministry
of
Public
Works
(MoPWH).
As
the
Chair
of
the
National
Land
Planning
Committee,
the
Ministry
could
theoretically
use
copies
of
title
(which
it
supposed
to
receive
as
a
matter
of
routine
procedure
–
Art
27.3)
to
compile
a
national
registry.
However,
as
far
as
the
study
could
establish,
this
just
does
not
happen.
Municipalities
do
not
send
copies
to
the
Ministry
and
nor
is
the
national
committee
effective
in
any
way.
It
meets
irregularly,
if
at
all.
4.5 The
Master
Plan
and
urban
sprawl
of
undeveloped
plots
Report
3
in
this
series,
on
the
Legal
and
Policy
Framework,
argues
that
land
law
in
Somaliland
is
generally
piecemeal,
with
gaps
and
contradictions.
Perhaps
the
biggest
practical
‘gap’
is
the
so-‐called
“masterplan”
(Article
5
of
the
UML
No.
17
of
2001/8).
Much
of
what
municipalities
are
empowered
to
do
depends
on
this
plan,
yet
few
district
towns
actually
have
an
up-‐to-‐date
one
and
the
capacity
of
MoPW
(see
below)
to
deliver
them
is
limited.
This
has
not
stopped
municipalities
going
ahead
and
expanding
their
towns.
The
impact
is
visually
obvious,
on
the
outskirts
of
every
major
town
and
even
in
smaller
settlements.
One
can
see,
everywhere,
the
corner
markers
or
foundations
of
compound
walls,
to
one
course
of
masonry
above
ground
level,
of
relatively
new,
but
not
yet
developed,
landholdings.
They
extend
some
distance,
in
Berbera
as
far
as
the
cement
factory
(8
km),
for
example.
Also
in
Berbera,
a
dillaal
told
the
field
survey
that
the
whole
beachfront
or
coastline,
extending
20
km
east
of
the
city,
has
been
allocated
and
marked
out
in
this
way,
one
plot
deep
and
without
planned
access
to
the
shore.
“You
won’t
find
a
place
to
bury
someone
there”,
he
said.
The
same
phenomenon
is
observable
in
Hargeysa,
south
of
the
airport
for
some
distance
and
indeed
along
every
main
road
out
of
the
city;
in
Boorama,
some
8
km
towards
Gabiley.
And
so
on,
throughout
the
country,
though
the
phenomenon
is
less
pronounced
in
the
Eastern
regions,
where
the
economy
is
slower.
Selected
excerpts
from
Urban
Management
Law
17,
2001/2008
Article
3
Urban
Master
Plan
3.
Planning
of
urban
land
cannot
go
beyond
five
kilometres
from
the
furthest
buildings
in
the
town.
Article
No.
5
Urban
Town
Mapping
1.
The
master
plan
of
a
town
or
part
of
it
shall
be
requested
by
the
local
authority
whenever
there
is
need
to
extend
the
town
or
create
new
settlements,
by
indicating
the
area
to
be
planned.
Article
No.
7
Farms
adjunct
to
the
town
15
as
a
consequence,
policy
makers
at
the
national
level
have
no
precise
information
about
what
is
happening
on
the
ground;
though
they
hear
stories,
belong
to
networks
and
have
families
affected,
like
everyone
else.
12
1.
Irrigation
farms
that
conform
to
the
Agricultural
Law
No.
08/99,
and
now
included
in
the
master
of
the
towns
can
be
used
for
plots,
and
they
are
owned
by
those
who
hold
the
titles
legally.
2.
Rain-‐fed
farms
that
conform
to
Agricultural
Law
No.
08/99
….,
as
Art
7.1
3.
Thirty
percent
of
the
farm
areas
extended
to
by
towns
shall
be
reserved
for
public
purpose
and
that
shall
be
indicated
in
the
town
plan.
Article
No.
9
Base
for
allocating
land
1.
Any
land
(plots)
that
are
to
be
allocated
should
be
based
on
and
conform
to
the
general
town
plan
approved
by
the
National
Land
Planning
Committee.
2.
Any
plot
with
permanent
use
can
be
allocated
with
the
decision
of
the
Executive
Committee
of
the
local
authority
following
recommendation
from
the
Planning
Office
of
the
Municipality.
3.
The
Mayors
of
towns
can
issue
uniform
regulations
regarding
the
verification
of
the
ownership
of
plots,
such
ownership
claims
should
be
supported
by
the
owners
–
with
legal
titles
–
of
the
three
plots
or
buildings
around.
Article
No.
12
Ownership
of
land
1.
Anybody
who
receives
title
for
land
with
permanent
use
must
build
a
permanent
building
in
one
year,
starting
from
the
date
of
issuance.
If
the
owner
does
not
build
the
land
within
that
time,
he/she
shall
be
obliged
to
pay
the
unified
tax
tariffs
of
the
local
authority
(Law
No.
12).
2.
Land
with
temporary
use
can
be
allocated
for
those
who
need,
and
they
must
build
in
three
months,
and
the
types
of
buildings
that
can
be
build
in
such
land
are
those
indicated
in
Article
No.
10,
Section
4
3.
If
the
recipient
of
land
does
not
build
the
land,
and
does
not
pay
due
taxes
for
two
consecutive
years,
he/she
shall
lose
the
right
to
own
that
land,
and
the
land
shall
become
public
property.
Article
No.
23
Reclaiming
of
land
for
public
purpose
1.
After
consulting
with
the
Executive
Committee
and
getting
permission
from
the
National
Land
Planning
Committee,
the
mayor
of
the
town
has
the
authority
to
issue
decree
for
the
reclaim
of
a
built
or
vacant
plot
for
public
purpose.
3.
The
owner
of
the
land
shall
receive
fair
compensation
for
the
affected
building
in
that
plot.
4.
The
owner
shall
also
receive
a
plot
that
is
equal
to,
in
terms
of
size
and
location,
the
previous
plot.
Article
No.
27
Registration
of
Plots
1.
The
local
authority
of
the
town
keeps
registers
for
recording
the
different
types
of
plots
and
the
titles
for
their
building.
3.
The
Land
Planning
Office
at
the
Ministry
of
Public
Works
shall
keep
copies
of
titles
for
permanent
plots
This
urban
sprawl
does
not
accord
with
Law
17
in
a
number
of
ways.
First,
the
plots
concerned
are
often
laid
out
without
a
masterplan.
Second,
the
provision
for
30%
of
new
urban
land
to
be
reserved
for
public
works
(Art
7.3,
previous
page)
seems
to
be
ignored
in
most
cases.
Sometimes,
it
is
alleged,
even
access
roadways
are
not
properly
provided
for.
We
heard
of
one
unhappy
plot
buyer
who
found
that
they
had
neighbours
on
all
four
sides
and
no
way
to
get
in.
Third,
though
this
is
as
much
an
aesthetic
or
functional
consideration
as
a
legal
one,
plots
are
not
planned
in
the
wider
sense
of
good
practice
in
town
planning.
Identical-‐sized
plots
are
laid
out
on
grids,
irrespective
of
terrain
or
function,
with
the
short-‐sighted
aim
of
selling
them
to
people
hoping
to
build
a
house,
some
day
(see
section
11
below
on
land
markets).
There
is
nowhere
for
future
mosques,
schools,
shops,
market
places,
playing
fields
and
so
on.
This
may
be
the
result
of
the
limited
skills
of
the
joomitir
(surveyors)
who
do
the
lay-‐out
or
of
a
short-‐sighted
imperative
to
meet
demand,
at
any
cost
or
maybe
both.
Fourth
is
the
broad
interpretation
of
the
term
“farms
adjunct
to
the
town”
in
Article
7.
The
process
by
which
“farm
land”
is
converted
to
urban
plots
is
as
follows.
A
block
of
land
is
registered
as
a
farm
13
in
accordance
with
the
Agricultural
Land
Ownership
Law
(Law
No.8/99
–
see
below).
It
may
indeed
have
been
farmed,
in
the
sense
of
growing
crops,
but
may
equally
have
been
under
communal
tenure
as
rangeland.
It
may
be
registered
by
the
person(s)
originally
using
it
or
by
a
land
speculator
with
the
resources
to
buy
out
(compensate)
anyone
with
an
interest
or
possible
claim
under
customary
law.
After
a
time
as
a
nominal
(or
actual)
farm
the
owner
applies
to
the
municipality
to
register
a
number
of
plots
under
the
terms
of
Article
7
and,
in
due
course,
sells
them.
For
this
to
happen,
officials
in
the
Ministry
of
Agriculture
(regional
and
headquarters)
and
in
the
District
Executive
Committee,
as
well
as
elected
councilors
in
the
relevant
sub-‐committee,
must
all
agree.
This
is
not
necessarily
collusion,
in
the
negative
sense,
as
the
farm
may
indeed
have
been
under
crops
and
be
‘adjunct’
to
the
town,
i.e.
with
an
actual
common
boundary.
However,
town
boundaries
are
not
mapped
and,
because
of
rainfall
and
soil
limitations,
much,
or
most,
of
the
land
surrounding
towns
is
not
suitable
for
agriculture.
Blocks
of
new
plots
seem
commonly
much
larger
than
the
8
hectare
maximum
allowed
for
individual
farms
(see
section
6,
below)16.
It
appears
therefore,
that
much
of
the
urban
sprawl
observed
has,
in
fact,
involved
collusion
by
parties
mentioned.
How
else
would
these
plots
have
spread
as
far
as
they
have?
Finally,
many
‘new’
plots
are
not
so
new
and
remain
undeveloped
after
two
years
or
more.
This
is
visible
from
the
state
of
the
masonry
and
surrounding
vegetation.
This
is
as
true
of
much
older
plots
within
towns
as
it
is
in
new
areas
on
the
outskirts.
It
is
probable
that
many
owners
are
not
compliant
with
Article
12
and,
strictly,
stand
to
lose
their
investment.
This
is
highly
unlikely
to
happen,
however,
as
it
would
be
an
unusually
bold
Mayor
who
attempted
to
claw
back
such
land
into
public
ownership.
While
this
is
understandable
politically,
it
does
raise
the
question:
is
a
law
that
invites
contempt
a
good
one?
To
conclude:
“The
municipalities
are
out
of
control”
(Director
of
Housing,
MoPWH,
interview
with
RVI).
This
would
appear
to
be
the
case;
however,
much
of
what
is
not
right
is
due
to
limited
technical
capacity
in
the
municipalities
and
unrealistic
demands
in
the
law
itself.
16
Apparently,
speculators
are
able
to
circumvent
the
8
ha
rule
by
registering
as
Co-‐ops
or
companies
(see
Law
8,
art
7.2,
in
section
6,
below);
DG,
MoA,
pers
comm.
17
See,
also,
Report
4
on
Land
Conflict
Dynamics
14
dissatisfaction
and
cynicism
about
the
way
that
parts
of
the
Shacab
have
been
privatized,
at
times
without
regard
to
the
rights
of
those
who
settled
it
after
the
civil
war
(box
on
following
page).
One
senior
MoPW
official
interviewed
regretted
that
Somaliland
has
not
been
able
to
retain
a
public
interest
in
these
prime
locations
by
entering
into
joint
ventures
with
developers,
instead
of
selling
them
outright.
The
example
of
Tanzania’s
National
Housing
Corporation18
was
quoted
but
it
seems
that
there
is
no
legal
basis
in
Somaliland
for
any
such
form
of
joint
venture.
With
appropriate
legislative
initiative,
the
opportunity
was
there,
at
a
certain
point,
to
retain
a
long-‐term
public
interest
in
former
Shacab
sites.
Cash
flow
benefits
to
government
would
have
been
less
dramatic
than
outright
sale,
but
longer
lasting.
It
may
still
be
possible
with
sites
not
yet
sold.
Some
form
of
claw-‐back
may
theoretically
still
be
possible
with
sites
already
sold,
under
Article
23
(see
above),
“for
public
purpose”.
But
note
that
Art
23.4
makes
this
practically
very
difficult.
Compensation
is
supposed
to
be
not
just
of
equivalent
value
but
identical
size
and
location.
This
is
yet
another
weakness
in
the
detail
of
Law
17
-‐
if
the
state
or
municipality
already
had,
and
was
able
to
offer
in
compensation,
another
plot
of
the
same
size
in
the
same
place,
where
is
the
public
purpose?
Also
note
that
this
article
is
about
the
Municipality;
the
Ministry,
as
custodian
of
public
land,
is
not
mentioned.
People
are
not
happy
with
the
disposal
of
ex-‐Shacab
sites
(see
Box
2,
following
page).
An
NLP
that
ignores
these
concerns,
or
pretends
that
there
is
no
issue,
would
be
incomplete.
The
process
of
urban
expansion
is
supposed
to
generate
new
public
space
equivalent
to
30%
of
farmland
converted,
under
Art
7.3.
Though
there
is
widespread
public
awareness
of
this
provision,
it
just
does
not
happen,
in
most
cases.
The
law
offers
no
clear
guidance
on
whether
this
area
should
be
surrendered,
free,
or
whether
compensation
is
due,
again
under
Art
23.
Presumably
the
“farmer”
selling
the
land
would
expect
payment.
Given
limited
capacity
to
produce
town
masterplans
in
the
more
sophisticated
sense,
the
joomitir
just
lay
out
their
grids
of
plots,
the
sale
of
which
maximizes
short-‐term
tax
revenue
for
the
municipality
and
does
not
expose
them
to
difficult
questions
of
compensation.
It
is
also
alleged
that
municipal
officials
benefit
directly.
Box
2:
Focus
group
discussion
with
public
land
squatters,
Hargeysa
“The
government
owns
the
land
in
this
neighbourhood.
However,
civilians
took
it
over.
There
are
houses
owned
by
the
civilians
and
others
the
government
owns
but
sold
them
to
civilians.
The
majority
of
the
people
who
settled
in
this
area
in
the
first
place
were
poor
people
who
either
moved
into
government
houses
or
occupied
vacant
land
in
the
neighbourhood.
However
the
government
sold
most
of
the
land
in
the
neighbourhood
to
rich
people
or
gave
it
to
them.
For
example,
the
former
president
gave
Adna
Adam
1
km
(sic)
of
land
in
this
area.
400
families
used
to
live
in
it
and
even
though
some
of
them
have
been
resettled,
the
majority
of
them
weren’t
and
18
NHC
was
set
up
to
own
all
the
commercial
and
residential
property
nationalized
post-‐1967.
It
is
still
politically
difficult
in
Tanzania
to
return
these
to
the
original
owners,
mostly
‘Asian’
(of
Indian
sub-‐continent
origin)
business
people
and
their
families.
Instead,
they
are
being
allowed
to
enter
into
joint
ventures
with
NHC.
Many
never
left
and,
after
a
generation
or
two
as
rent-‐paying
tenants
of
the
state
in
their
increasingly
run-‐down
buildings,
they
are
now
encouraged
to
rehabilitate
or
completely
redevelop
NHC
property,
as
part
owners.
This
is
a
fairly
unique
form
of
tenure,
without
an
exact
parallel
in
Somaliland.
15
they
fear
that
they’ll
be
simply
kicked
out
of
the
land
they
lived
on
for
more
than
20
years.
Thus
now
the
people
who
live
in
Shacab
area
are
of
different
levels
of
wealth.
Some
of
the
people
lived
in
this
neighbourhood
from
the
seventies.
These
were
government
employees.
However
the
majority
of
the
people
settled
in
the
neighbourhood
after
the
war.
The
poor
people
are
being
pushed
from
the
neighbourhood
and
rich
people
are
taking
over.
These
poor
people
who
don’t
have
anywhere
else
to
go
are
suffering
due
to
businessmen
who
want
to
buy
their
land.
The
businessmen
offer
them
some
money
and
persuade
them
to
give
up
their
land.
Sometimes
these
businessmen
buy
pieces
of
land
over
which
there
are
conflicts.
There
is
a
fast
growing
land
trade
in
our
neighbourhood
and
at
least
a
house
is
sold
per
day.
There
isn’t
a
single
plot
of
land
in
this
neighbourhood
that
hasn’t
been
claimed
by
someone.
It
is
all
fenced.
Sometimes
the
occupants
of
these
houses
are
given
money
as
compensation
and
other
times
they
are
forced
out
of
their
houses.
Sometimes
the
occupants
sell
part
of
the
land
and
settle
down
in
the
other.
However,
they
move
out
of
the
neighbourhood
most
times.
Thus
the
number
of
poor
people
who
live
in
this
neighbourhood
is
decreasing
day
by
day
and
the
rich
are
replacing
them.
Sometimes
a
conflict
happens
between
the
occupants,
the
government
and
those
who
bought
the
land
from
the
government.
The
occupants
believe
that
they
own
the
land
since
they
lived
in
it
for
more
than
two
decades
so
when
the
government
who
is
the
real
owner
sells
it
to
buyers,
they
refuse
to
move
out
and
a
conflict
starts.
Sometimes
several
families
share
a
piece
of
land.
The
first
person
who
settled
in
it
decides
to
sell
it
but
the
others
refuse
to
move
out
claiming
that
since
this
is
public
land,
no
one
has
more
rights
over
it
than
others.
The
elders
of
the
parties
involved
in
the
conflict,
resolve
it.
The
local
government
doesn’t
have
the
power
to
control
this
neighbourhood.
It
comes
under
the
jurisdiction
of
the
Public
Works
Ministry
and
the
only
time
the
ministry
intervenes
in
our
affairs
is
when
there
is
a
transaction
or
a
big
conflict
happens
that
leads
to
the
police
being
involved.
Apparently
the
Ministry
has
publicly
warned
that
the
liability
for
the
30%
remains
and
that
plot
buyers
should
be
aware
(caveat
emptor)
that
they
may
be
called
upon
to
make
it
good.
An
incident
of
poorly
managed
privatization
of
‘farmland’
involved
the
disposal
of
land
in
Boorama
that
had
been
informally
used
as
recreation
space
(football
grounds).
This
led
to
well-‐known
and
widely
discussed
incidents
of
violence
between
gangs
of
youth
who
could
previously
sublimate
their
rivalries
in
soccer.
If
the
land
had
been
properly
planned
before
sale,
football
grounds
might
have
been
laid
out
and
allocated.
Box
3:
Focus
group
discussions,
some
views
on
the
issue
of
30%
public
land
reservation
“In
the
urban
area
the
only
communal
land
is
that
deducted
from
the
planning
of
agricultural
areas
that
are
turned
into
residential
areas.
In
these
lands,
by
law,
the
local
government
deducts
some
land
for
public
use.
Unfortunately
this
type
of
land
falls
into
hands
of
very
few
local
government
officials
who
use
it
for
their
own
good”.
(FGD,
pastoralists,
Burco)
“The
government
doesn’t
own
one
meter
of
land.
There
is
no
public
land
even
to
bury
one
person.
All
that
land
the
local
government
deducts
for
public
use
falls
in
the
hands
of
very
few
local
administration
officials.
It
is
a
sad
reality
to
know
that
the
local
government
makes
money
out
of
these
lands
either
by
selling
the
public
lands
or
prolonging
land
conflict
cases
so
that
the
disputing
parties
pay
money
to
them.”
(FGD,
elders,
Mohamoud
Heibe,
Hargeysa)
“the
..
local
municipality
here
in
Wajaale
..
finished
all
the
land
..
and
they
have
no
land
to
sell
now
..
they
only
care
about
the
people
who
are
buying
land.
Sometimes
they
take
500
dollars
16
from
each
side
..
Here
in
Wajaale
they
exchange
money
for
land
and
they
have
no
impact
on
community
peacefulness
and
affordability”.
(FGD,
farmers,
Togwajaale)
“There
is
no
public
land
at
all.
The
30%
of
public
land
indicated
by
the
law
is
sold
by
the
local
government
officials
and
nothing
is
left
for
public
purpose.”
(FGD,
elders,
JIgjigayar,
Hargeysa)
5.2 Masterplans
There
is
clearly
a
capacity
bottleneck
in
the
Ministry,
which
continues
to
produce
urban
masterplans,
most
recently
in
Lascaanood
and
Wajaale.
But
the
speed
at
which
these
can
be
produced
is
far
out-‐
paced
by
developments
on
the
ground.
The
problem
comprises:
• at
least
23
districts
in
need
of
a
town
plan
(leave
aside
district
boundary
survey19)
• capacity
to
generate
a
limited
number
(only
one
or
two?)
of
plans
a
year
• the
need
to
rotate
available
resources
fairly
around
the
country
Even
districts
that
have
a
plan
find
that
it
is
quickly
out
of
date
and
that
it
will
be
years
until
it
is
their
turn
again.
The
RVI
study
team
took
care
to
ask
municipalities
if
they
had
the
resources
to
draw
up
plans
on
their
own,
without
waiting
for
the
Ministry.
The
answer
was
invariably
‘no’
and,
moreover,
there
were
doubts
as
to
the
legality
of
this.
It
is
unlikely
that
the
private
sector
can
fill
this
gap
in
the
immediate
future,
because
there
simply
are
not
enough
trained
surveyors.
However,
in
other
countries,
local
authorities
are
free
to
contract
out
such
work,
as
they
do
with
construction.
The
NLP
could
consider
opening
up
competition
to
provide
such
services,
using
the
best
technology
available.
17
from
central
government,
presumably
through
the
appropriate
line
ministry,
which
is
Internal
affairs,
not
Public
Works.
The
municipality
is
also
expected
to
provide
premises
and
support
staff.
This
has
not
worked
well
in
Boorama,
where
the
LDT
Chair
indicated
considerable
friction
over
resources
between
tribunal
and
municipality.
But
as
this
tribunal
is
new,
with
only
one
case
resolved
and
seven
in
process
(in
October
2015),
it
may
be
that
these
are
only
teething
troubles.
Once
again,
the
masterplan
is
a
problem.
The
Berbera
LDT
Chair
reports
that,
without
one,
he
is
often
unsure
whether
a
given
case
falls
within
his
jurisdiction.
He
recommends
that
this
is
insoluble
while
planning
capacity
is
so
limited
and
that
the
relevant
articles
should
be
repealed.
He
also
recommends
that
the
tribunal
should
be,
physically
and
in
resource
terms,
taken
out
of
the
municipality,
to
emphasise
its
impartiality.
As
Report
4
shows,
corrupt
or
incompetent
practice
by
local
government
staff
is
a
common
cause
of
disputes.
The
three
existing
LDT
Chairs
are
all
lawyers.
Berbera
is
especially
well
served
in
that
both
Municipality
members
and
the
MoAg
member
are
also
lawyers.
It
is
not
clear
if
MoPW,
where
one
would
expect
to
find
engineers,
has
an
infinite
supply
of
lawyers.
The
Berbera
Chair
regrets
the
gap
between
an
Administrative
Tribunal
and
the
courts
and
judges
of
the
mainstream
legal
system.
This
is
both
as
a
matter
of
principle,
because
the
expediency
of
the
tribunals
does
nothing
to
correct
the
weaknesses
of
the
mainstream,
and
a
practical
consideration,
as
LDTs
have
no
powers
of
enforcement.
Where
one
party
(or
both)
refuses
to
accept
the
tribunal’s
decision,
the
case
must
go
up
to
the
supreme
court
(not
the
regional
court).
Most
cases
in
Berbera
have
been
where
one
party
refuses
to
accept
the
judgment
or
recommended
settlement
of
either
elders
or
shari’a
courts;
not
because
these
have
failed
to
reach
a
decision
and
have
passed
on
the
case.
HGA
–
cross
check
R.4
There
is
no
general
agreement
as
to
the
jurisdiction
of
LDTs.
Some
people
consulted
believe
that
its
function
is
to
act
as
a
higher
authority
(than
the
elders)
on
all
land
disputes
within
the
whole
Region
of
a
Grade
A
municipality,
including
those
involving
agricultural
land.
Others
believe
that
Law
17
confines
jurisdiction
to
the
area
included
in
the
town
masterplan.
This
needs
clarification
and
the
correct
position
needs
to
be
publicly
explained.
The
level
of
general
understanding
about
the
LDTs
is
very
low.
as
part
of
the
UN
multi-‐agency
Joint
Programme
on
Local
Governance
and
Decentralized
Service
Delivery
(JPLG)
20
18
This
impasse
has
been
unresolved
since
2012
and,
as
a
result,
LUMI
has
yet
to
realize
its
potential.
This
is
regrettable
and
the
draft
NLP
would
be
incomplete
without
a
statement
on
the
question.
In
spite
of
this
impasse,
UN-‐Habitat
has
progressed
its
work
on
property
tax
(see
section
10,
below).
19
3.
If
the
farm
investment
and
the
related
expenses
came
from
oversees/foreign
sources,
they
can
have
the
right
to
send
some
of
the
profits
oversees/foreign
country.
4.
To
have
the
right
to
sell,
rent,
and
transfer
ownership
of
the
farm
land
apart
from
those
lands
mentioned
in
Article
9.
Article
Thirteen,
Inheritance
1.
When
a
person
with
registered
title
dies,
the
title
will
be
transferred
to
the
heirs
as
shari’a
defines.
2.
In
such
cases
the
inheritors
of
the
land
title
will
be
entered
in
the
land
register
as
this
law
states.
Article
Fifteen,
Land
Registration
If
the
land
issued
was
previously
improved
by
the
local
government,
or
another
independent
government
agency,
the
expenses
should
be
compensated
by
the
person
given
the
land
title.
Article
Sixteen,
Land
Registration
–
same
name???
1.
The
Ministry
of
Agriculture
should
have
a
map
(master
plan)
and
a
farmland
register
on
which
the
names
of
the
people
with
titles
appear
and
under
which
conditions/criteria
the
land
was
issued.
2.
Agents/representatives
of
the
Ministry
of
Agriculture
in
the
districts
may
register
farmlands
in
the
districts.
5.
Ministry
of
Agriculture
representative
in
the
district
will
finally
submit
a
copy
the
farm
ownership
certificate
to
the
Ministry
of
Agriculture.
Article
Seventeen,
Demarcation
of
Farmland
from
Residential
Land
1.
Irrigated
farms
shall
not
be
issues/apportioned
from
the
pasture
and
of
the
Republic
of
Somaliland,
2.
Irrigated
farms
can
be
issued
from
pastureland
if
they
are
not
enclosed
or
not
interrupting
water
routes
for
animals
or
not
blocking
access
to
wells
that
animals
travel
to.
20
6.2 Somaliland
Secure
Land
Tenure
Arrangements
Project
(SSLTAP)
The
SSLTAP
was
the
most
ambitious
effort
to
issue
title
to
farms
that
has
been
attempted
to
date.
It
evolved
from
the
initiative
of
Somaliland
Cadastral
Surveys
(SCS),
an
NGO
which
started
surveying
individual
farm
holdings
in
1997.
Though
it
piloted
activities
in
Burco
and
Ceerigaaboo,
most
of
the
work
was
in
the
west
of
the
country,
particularly
in
Gebiley,
Dilla,
Arabsiyo
and
Boorama.
At
one
point
there
it
was
estimated
that
80,000
farms
could
benefit.
The
project
was
supported
by
UNDP
through
three
phases
from
2001-‐2012.
In
one
important
respect
it
was
a
success:
farmers
loved
it.
It
mirrored
the
Ethiopian
experience
that
people
appreciate
official
recognition
of
their
rights
and
are
proud
of
their
certificates.
SCS,
and
the
MoA
project
that
took
over,
generated
a
lot
of
positive
good
will
and
publicity
on
this
basis.
The
Municipality
in
Gebiley
are
equally
proud
of
their
SCS
master
plan,
still
prominently
displayed
in
their
offices,
though
it
is
now
some
years
out
of
date.
In
most
other
respects
SSLTAP
seems
to
have
been
a
technical
failure.
The
concrete
beacons
used
to
mark
boundary
corners
were
all
too
frequently
stolen
or
moved,
perhaps
an
indication
that
individual
ownership
is
opposed
locally.
The
substitute
adopted,
planting
Aloe
Vera21
along
boundaries,
is
expensive
because
of
the
need
to
raise
and
distribute
planting
material.
More
importantly,
SCS
failed
to
organize
and
pass
on
its
data
set
to
the
Ministry,
so
that
the
certificates
it
issued
–
which
generated
the
early
publicity
–
are
of
doubtful
validity.
Many
of
them
had
to
be
re-‐
surveyed.
A
review
of
the
SSLTAP
project22
documents
the
gradual
breakdown
of
relations
between
SCS,
MoA
and
UNDP
by
2012.
UNDP
did
not
renew
support
to
MoA,
though
some
of
the
ministry
staff
continue
to
administer
new
title,
following
the
methodology
developed
by
SSLTAP,
in
the
Marodijeh
Upper
Catchment
Soil
and
Water
Conservation
project,
funded
by
SDF.
SCS
itself
has
ceased
to
function,
due
to
the
old
age
of
its
founder,
John
Drysdale;
staff
members
have
dispersed
and
the
capacity
created
has
been
dissipated.
This
is
a
tragic
story
and
a
loss
to
Somaliland.
21
3.
Lands
designated
as
fodder
crops
production
entity.
4.
Land
cleared
by
fire
or
cleared
manually.
5.
Land
used
for
water
reservoir,
water
wells,
barkes
and
seasonal
river
beds
used
for
pastoral
and
irrigation
purposes.
6.
Reserved
pastoral
grazing
lands.
7.
Land
closed
for
research
in
bio-‐diversity”
These
wide
powers
are
specifically
extended
to
allow
the
Ministry
“to
control
and
regulate
the
land,
grazing,
forestry
and
wildlife
and
make
optimum
use
of
water
resources
…”
and,
under
Article
10,
Creation
of
Special
Fodder
Preservation
Farms
“may
permit
the
creation
special
fodder
farms
and
special
reserved
areas
in
the
following:
• Land
designated
for
agricultural
purposes.
• Any
land
that
has
suffered
erosion
and
is
being
rehabilitated
and
conserved”.
Note
that
Article
10
does
not
seem
to
cover
permitting,
or
otherwise
regulating,
enclosures
for
fodder
preservation
on
open
rangeland,
but
Article
9.1
might
well
be
given
the
opposite
interpretation.
Given
how
deeply
controversial
and
common
this
practice
is,
it
is
essential
that
the
NLP
establishes
clarity
on
the
question
and
makes
a
commitment
to
amend
the
law
accordingly.
23
Harmonization
of
the
legal
systems
resolving
land
disputes
in
Somaliland
and
Puntland;
Law
in
Action
Worldwide
(LAW),
for
JPLG,
2015.
Note
that
this
report
does
in
fact
include
a
substantial
and
sympathetic
account
of
Xeer,
though
it
would
appear
to
be
overlooked
in
the
passage
quoted.
22
herding,
harvesting
forage
etc.
It
is
not
clear
how
many,
if
any,
of
these
have
been
formally
registered.
Box
4:
Pastoralists
in
Rabaso,
Ethiopia,
consider
abolishing
enclosures
in
Somaliland
During
the
dry
season
in
Somaliland,
pastoralists
go
with
their
camels
to
other
areas
in
search
of
water
and
pasture.
This
year
(2015)
pastoralists
from
Maroodi
Jeex
and
Awdal
regions
in
the
west
reached
Rabaso
and
Daroor
in
the
Somali
Region
of
Ethiopia.
They
usually
gather
in
the
evening
around
the
fire
and
entertain
themselves
with
stories
and
issues
of
interest
to
livestock
herders.
The
elders
are
the
most
vocal.
One
of
those
nights
an
elder
started
analysing
the
main
cause
of
the
drought
in
their
homeland
on
the
other
side
of
the
border
and
the
old
man
explained
why
the
land
is
greener
on
the
Ethiopian
side
of
the
border.
The
listeners
were
all
interested
to
listen
to
the
old
man’s
wisdom
because
it
was
an
issue
which
always
concerns
them.
Their
conclusion
was
that
it
is
the
will
of
Allah.
The
old
man
did
not
dispute
that
it
is
the
will
of
Allah
but
explained
that
Allah
always
has
reason
behind
such
judgments.
The
elder
continued
and
asked
the
listeners
whether
they
see
any
enclosures
in
this
area
where
their
camels
were
grazing
and
the
answer
was
negative.
Therefore
he
explained
that
the
reason
why
their
homeland
in
Somaliland
is
always
dry
and
the
rainfall
is
erratic
is
because
of
the
enclosures
which
deprive
the
poor
pastoralists
a
land
where
their
animals
can
graze.
He
further
explained
that
the
land
which
is
a
gift
by
Allah
for
all
is
monopolised
by
few
hence
the
punishment
of
Allah
in
depriving
us
of
water
and
pasture.
He
also
explained
that
some
of
us
here
enclosed
their
land
back
home
and
travelled
hundreds
of
miles
to
bring
their
animals
to
Ethiopia
for
pasture.
The
analysis
and
the
wisdom
of
the
elder
was
convincing
that
everybody
kept
silent
for
some
time
and
started
to
reflect
on
what
the
old
man
said.
In
the
end,
the
elder
suggested
that
as
soon
as
they
return
to
their
homeland
they
should
get
rid
of
the
enclosures.
Everybody
present
accepted
the
proposal
and
they
all
swore
to
Allah
that
they
will
abolish
enclosures
in
the
area
where
they
live.
Such
oaths
are
taken
seriously.
This
incident
is
also
related
to
the
culture
that
when
the
rains
are
delayed
during
the
rainy
season,
people
pray
for
rain
and
the
prayer
is
called
“Roob
doon”.
At
the
same
time
in
the
mosques,
religious
leaders
preach
that
it
is
the
curse
of
Allah
as
a
result
of
the
sins
people
is
committing
and
therefore
they
should
gather
and
pray
together
for
rain.
It
is
important
(for
non-‐Somalis)
to
grasp
the
fact
that
land
grabbing
by
an
outsider
in
any
given
degaan
is
not
possible;
it
would
be
rejected
by
the
clan,
violently
if
necessary.
It
is
true
that
rumours
about
the
archetypal
foreign
land
grabber,
said
to
be
Saudis,
have
played
a
part
in
the
communal
rejection
by
the
Eidagale
clan
of
the
Government’s
plans
(with
SDF)
for
the
Qool
Caday
livestock
holding
ground
but
that
tends
to
prove
the
point.
The
point
is
that
enclosure
usually
involves
the
elders,
somehow,
and
that,
therefore,
the
NLP
should
seek
to
establish
ways
to
strengthen
Xeer,
not
to
substitute
for
it
with
any
additional
powers
for
the
already
stretched
Ministries24.
And
certainly
not,
as
the
LAW
report
seems
to
suggest,
to
introduce
regulations
that
attempt
to
physically
define
patches
of
rangeland,
treating
it
like
a
house-‐
plot,
with
fixed
corners.
Pastoralism,
or
transhumance,
works
in
a
quite
different
way,
with
fluid
24
For
a
discussion
of
the
potential
of
remote
sensing
(using
satellite
imagery)
for
monitoring
the
incidence
and
extent
of
enclosures,
see
Report
5
in
this
series,
on
Land
Resources.
23
boundaries
determined
by
rain
and
where
the
grass
is
growing
in
any
particular
season,
as
well
as
the
current
state
of
relations
between
the
clans
that
have
a
reasonable
established
claim
to
use
the
grazing.
9 Taxation
Property
taxes
are
an
important
element
in
municipal
finance.
New
plots
attract
a
4%
tax
on
purchase
price,
shared
equally
between
local
and
central
government.
An
annual
property
tax
is
also
levied,
with
rates
decided
by
the
municipality.
The
Ministry
of
National
Planning
has
helpfully
provided
the
study
team
with
the
income
and
expenditure
statements
for
Burco
and
Berbera
municipalities.
Though
this
is
not
a
representative
sample,
the
two
sets
of
accounts
make
an
interesting
contrast.
For
Berbera,
property
taxes
are
only
some
5.3%
of
income
because
it
has
a
unique
revenue
source
in
the
port.
Import
duties
(which
it,
not
central
government,
controls)
make
up
87%
of
municipal
income.
In
Burco,
which
may
be
more
typical,
house
and
land
tax
account
for
17.6%
of
income,
the
second
biggest
item
after
disposal
of
assets
(22.3%).
It
is
not
clear
if
the
latter
includes
the
sale
of
public
land,
a
finite
resource.
The
UN
multi-‐agency
JPLG,
through
UN
Habitat25,
has
developed
geographic
information
systems
(GIS)
and
related
accounting
packages
for
Hargeysa,
Burco,
Boorama,
Sheehk,
Berbera,
Odweyne
districts.
A
three-‐phase
process
starts
with
awareness
sensitization
on
the
purpose
and
importance
of
good
property
information
to
the
management
of
the
municipality.
Religious
and
political
leaders,
community
elders
and
the
general
public
are
engaged.
In
Burco,
for
example,
the
University
has
been
a
key
partner.
25
See,
e.g
,
http://unhabitat.org/un-‐habitat-‐in-‐the-‐somali-‐region-‐newsletter-‐issue-‐19/
+
other
JPLG
reports
24
This
is
followed
by
recruitment
and
training
of
enumerators,
municipal
assistants,
data
clerks
and
a
team
leader
for
the
location.
The
survey
itself
uses
a
questionnaire
to
capture
the
resident’s
details,
a
tape
measure
for
the
property
dimensions
and
a
hand-‐held
global
positioning
system
(GPS)
device
to
take
coordinate
readings
for
the
property.
Data
clerks
then
enter
this
information
on
the
database.
This
links
with
a
Billing
Information
Management
System,
which
issues
tax
demands.
Municipality
staff
is
trained
on
the
uses
and
maintenance
of
the
GIS
database.
The
results
are
striking.
In
Borama,
before
the
installation
of
the
GIS
database
system,
the
revenue
department
in
the
Municipality
collected
tax
from
7,600
registered
properties;
after
the
property
survey
a
total
of
15,494
properties
were
captured.
In
Berbera,
registered
properties
increased
from
3,000
to
7,107.
Once
staff
have
the
skills,
updates
can
be
made
annually,
adding,
for
example,
another
500
properties
to
the
Berbera
tax
roll
in
the
last
year.
This
programme
is
the
most
important
and
innovative
current
initiative
in
land
governance
in
Somaliland.
In
addition
to
significant
gains
in
efficiency
and
transparency
in
municipal
finance,
it
offers
a
solution
to
the
problem
of
the
masterplan.
The
present
GIS
property
data
mapping
is
not
yet
equivalent
to
a
cadastre
but
it
is
conceptually
easy
to
see
how
it
could
be
up-‐graded,
given
additional
resources.
It
is
not
clear
whether
MoPW
will
easily
accept
this
potential
as
it
could
challenge
its
control
over
the
masterplan.
GPS
based
mapping
for
masterplans,
carried
out
by
local
staff
and
institutions,
would
constitute
a
further
step
in
devolution
of
land
governance,
probably
needing
amendment
to
both
Laws
17
and
23.
10
Land
Professions
The
study
interviewed
surveyors
(joomitir),
brokers
(dillaal)
and
notaries
(nootaayo)
in
nearly
every
location.
All
three
professions
play
key
roles
in
land
administration.
Joomitir
are
municipal
employees,
men
(all
men)
of
a
certain
age,
usually
trained
at
an
institute
in
Mogadishu
in
the
Siyaad
Barre
era.
Interviewees
reported
little
interest
by
a
younger
generation
in
joining
the
profession
because
no
specific
training
opportunities
exist.
The
University
of
Hargeisa
piloted
an
institute
(course)
with
the
SSLTAP
project
but
this
folded
without
external
support.
UN
Habitat
is
said
to
be
preparing
a
certificate-‐level
course
for
2016
[follow
up
at
validation
workshop*].
No
continuing
education
opportunities,
trade
association,
conferences
or
other
kind
of
formal
networking
arrangements
are
available
to
joomitirro.
None
seem
to
operate,
as
their
fellows
do
in
other
markets,
as
independent
advisors
to
property
buyers
and
sellers,
charging
fees
at
a
market
rate.
As
local
government
employees
their
work
is,
perhaps,
under-‐paid
and
carried
out
with
a
minimum
of
due
care
and
attention.
It
is
puzzling,
in
a
roaring
market
(see
below),
that
no
one
seems
to
have
seen
an
opportunity
to
set
up
as
genuinely
independent
surveyors,
offering
a
quality
service.
Dillaal
are
private
business
people,
operating
on
different
scales;
there
are
some
big
operators,
one
interviewed
is
a
practicing
lawyer
who
is
also
a
registered
notary.
It
is
usual,
but
not
invariably
so,
for
both
sides
in
a
transaction
to
employ
their
own
dillaal,
to
negotiate
on
their
behalf.
Fees
are
negotiable,
not
a
fixed
commission
(percentage),
though
5%
is
sometimes
mentioned
as
a
benchmark.
Brokers
are
licensed
by
their
municipality,
though
it
is
not
clear
what,
if
any,
degree
of
control
this
gives
the
mayors.
It
may
be
no
more
than
a
normal
business
license.
At
least
one
of
those
interviewed
did
not
bother
to
get
his
license.
They
are
widely
thought
to
be
crooks
but
that
is
a
view
of
estate
agents
or
realtors
or
whatever
the
profession
is
called,
across
the
world.
Like
the
surveyors
(but
unlike
lawyers
and
accountants),
there
is
no
professional
body
to
represent
them
or
through
which
to
promote
a
code
of
professional
conduct/standards.
25
Property
transactions
are
only
part
of
a
public
notary’s
business
and
are
subject
to
a
low
fixed
fee.
Like
surveyors,
therefore,
the
incentive
to
compete
on
standard/quality
of
due
diligence
is
limited.
The
number
of
notaries
is
also
limited
(though
this
may
be
changing,
with
the
recent
output
of
law
graduates)
and
people
seem,
from
interviews,
to
choose
the
nearest
or
most
convenient
one,
not
to
go
on
grounds
of
reputation
or
clan.
This
suggests
that
the
role
is
neutral,
as
it
is
supposed
to
be.
Box
5:
A
Land
File
in
Hargeysa:
a
record
of
recent
administrative
actions
for
one
residential
plot
1.
The
plot
is
a
sub-‐division,
undeveloped,
and
the
first
document
of
record
is
the
owner
writing
in
2013,
as
a
private
citizen,
to
the
municipality
requesting
registration.
The
letter
is
typed
and
has
obviously
been
prepared
by
a
notary,
to
a
set
format.
2.
District
officials
add
a
form,
annotated,
dated
and
stamped,
attesting
that
the
plot:
a)
has
been
physically
checked;
b)
its
tax
compliance
is
in
order;
c)
conforms
with
the
master
plan.
3.
GRs
(government
general
receipts)
filed
for:
a)
verification
fee
SL
100,000/=
(US$16);
b)
housing
tax
SL50,000/=
(US$8
approx.).
4.
Copy
of
relevant
section
of
master
plan
showing
location
on
grid.
5.
Document
2
is
repeated,
formalizing
attestations,
by
District
Head
of
Housing;
and
countersigned
by
equivalent
official
in
the
City
Mayor’s
office.
This
declares
that
any
error
is
the
responsibility
of
the
district,
not
the
city.
Formal
ownership,
Title,
of
this
plot
is
now
complete.
6.
Two
years
later
the
plot
is
for
sale,
buyer
and
seller
agree
and
a
notary
prepares
a
bill
of
sale,
with
stamp
tax/duty
and
witnessed
(thumb
print)
by
nine
people:
two
brokers,
one
for
each
side,
who
attest
that
they
have
checked
with
neighbors
and
elders
and
there
is
no
encumbrance
in
the
way
of
inheritance
or
other
dispute;
other
witnesses,
again
for
both
sides,
include
relatives
and
district
councilors,
as
guarantors
of
the
good
faith
of
both
parties.
7.
GRs
for
recent
housing
tax
to
date.
8.
Mayor’s
office
files
a
Transfer
of
Ownership
form
with
following:
a)
identification
details
of
plot,
seller
and
buyer;
b)
sale
price
and
calculation
of
transfer
tax
due;
c)
official
(district)
confirmation
that
the
price
reflects
fair
market
value
(often
allegedly
under-‐reported);
d)
checked,
signed,
stamped
by
District
Executive
Secretary;
e)
stamped
by
City
Mayor’s
office
(PW
department);
f)
confirmation
of
development
permit.
This
is
the
document
transferring
Title.
9.
More
GRs,
for
transfer
tax,
construction
tax
etc.
All
of
this
is
quite
proper,
the
interval
between
document
dates
is
not
long,
suggesting
prompt
processing,
and
the
detail
seems
assiduous
and
clear,
unlike
some
examples
the
study
saw.
Except
that,
almost
immediately
after
the
sale,
the
buyer
began
building
and
the
seller
initiated
a
dispute,
based
on
the
dimensions
of
the
plot.
The
seller
claimed
that
a
two-‐metre
strip
of
the
sub-‐division
was
not
in
fact
included
in
the
sale.
This
goes
back
to
an
error
in
document
2,
where
the
district
joomitir
had,
perhaps,
just
assumed
that
the
plot,
a
standard
size,
had
been
sub-‐
divided
into
two
exactly
equal
halves.
The
buyer
had
not
ensured
that
this
was
independently
checked.
Rather
than
enter
into
a
lengthy,
perhaps
endless,
dispute
with
the
district
about
liability,
the
buyer
settled,
at
much
expense.
This
also
involved
repeating
step
6
for
the
disputed
strip,
with
notary,
witnesses,
stamp
duty
etc.
This
sort
of
relatively
minor
(though
not
to
the
buyer,
who
suspects
that
he
was
set
up)
inefficiency
in
conveyance
is
apparently
all
too
common
and
quite
often
ends
in
violence.
It
is
evidence
of
market
failure
in
service
provision,
by
the
land
professions.
26
11
A
note
on
the
land
market
Interviews
with
dillaal
(and
many
other
interviewees)
describe
a
constantly
rising
market;
one
that
has
not
experienced
a
correction
since
Somaliland
re-‐established
itself;
one
in
which
year-‐on-‐year
prices
have
doubled
in
each
of
the
past
three
years
in
the
hottest
areas,
particularly
in
Hargeysa;
and
one
which
is
driven
by
an
externality,
diaspora
cash
investment.
Everyone
knows
what
a
good
investment
real
estate
has
been
over
the
past
20
years.
Box
6:
Land
prices
in
Burco,
excerpt
from
interview
with
a
dillaal
“Usually
..
plot
sizes
..
are
24m
x
24m,
similar
to
four
traditional
plots.
In
town,
most
plots
are
the
traditional
12mx12m.
People
like
to
buy
in
areas
close
to
the
town
center.
Prices
are
hiking
..
a
piece
of
land
sold
for
$20,000
in
2011
is
now
sold
to
$55,000
in
2015.
It
is
the
same
land.
Another
plot
in
town
sold
for
$55,000
in
2011,
and
for
$95,000
in
2015.”
[these
prices
presumably
refer
to
larger
sized
plots,
suitable
for
commercial
use]
“A
plot
of
[residential]
land
near
the
town
center
will
cost
$13,000
to
$15,000
USD;
in
Tuwalli
village
..
$20,000
USD;
in
Jarmal
village
plots
are
between
$8,000-‐$10,000.
What
makes
a
plot
expensive
are
the
roads
[access]
it
has.
Sometimes
two
adjacent
plots
of
the
same
size,
one
is
$12,000
and
the
other
is
$16,000.
Now,
people
like
the
south
side
of
town,
areas
along
the
tarmac
road,
city
plaza
hotel
area,
Qasab,
Tuurta
and
Nafaqo
areas.
The
places
where
prices
are
not
growing
are
..
along
the
road
to
Berbera
..
These
areas
are
good
farming
land
and
those
who
buy
want
to
make
it
into
farms”.
As
in
every
property
market,
worldwide,
the
principle
of
‘location,
location,
location’
rules,
both
within
a
given
town
and
across
the
country.
These
price
rises
in
Burco
are
not
the
100%
year-‐on-‐
year
increase
often
quoted
in
Hargeysa
but
clearly
the
same
general
trend
applies.
Dillaal
in
Boorama
and
Burco
reported
that
prices
have
been
held
down
by
people
and
businesses
selling
up
to
move
to
the
capital.
In
quiet
(economically)
and
comparatively
remote
Ceerigaavo,
quoted
prices
are
correspondingly
lower.
This
looks
very
like
a
bubble
and,
by
definition,
bubbles
always
burst;
though
who
knows
when
and
how
explosive
the
result
might
be.
The
experiences,
after
2008,
of
American
and
European
property
markets
are
the
obvious
examples.
What
the
consequences,
or
proximate
cause,
of
a
sharp
fall
in
house
and
house-‐plot
prices
in
Somaliland
would
be
is
beyond
the
scope
of
this
study
but
they
would,
as
a
matter
of
general
principle,
be
de-‐stabilizing
in
an
economy
so
dependent
on
remittances.
Interviewees
also
suggested
that
some
resentment,
and
the
possible
root
of
a
social
problem,
may
be
building
between
those
that
have
access
to
capital,
through
the
diaspora,
and
those
who
do
not.
Prices
cannot
double
indefinitely,
it
is
mathematically
out
of
the
question;
but
it
is
quite
possible
that
they
simply
flatten
out.
Given
a
degree
of
emotional
commitment
to
property
ownership
in
Somaliland
on
the
part
of
the
diaspora,
there
is
little
reason
to
expect
a
sudden,
rapid
sell-‐off,
triggering
a
price
collapse.
Also,
this
market,
unlike
those
that
led
to
the
2008
financial
crisis
in
the
West,
is
not
debt-‐financed.
Whatever
happens,
managing
change
would
be
easier
with
a
robust
land
administration
system.
27
12 Glossary
of
acronyms,
words
and
phrases
abbaan
agent
or
broker;
also
dillaal
berkad
water
reservoir
used
to
catch
and
store
rain
water
run-‐off
caaqil
representative
of
a
diya-‐paying
group;
position
formalized
by
the
British
(pl.
caaqillo)
deegaan
environment,
land,
area,
territory
dhulka
shacabka
Sha’ab
land
–
see
below
dillaal
broker
joomitir
surveyor
(from
Italian,
geometer)
LUMI
Land
and
Urban
Management
Institute
MoAg
Ministry
of
Agriculture
MoERD
Ministry
of
Environment
and
Rural
Development
MoIA
Ministry
of
Internal
Affairs
MoPWH
Ministry
of
Public
Works
and
Housing
nootaayo
notaries
NWADP
North
Western
Agricultural
Development
Project
NLP
National
Land
Policy
NRDP
Northern
Rangelands
Development
Project
RVI
Rift
Valley
Institute
Shacab
(or
ex-‐Sha’ab)
the
quarter
or
locality,
in
all
seven
regional
headquarter
towns,
originally
reserved
under
the
Protectorate
for
government
offices,
courts,
military
and
police
barracks
and
parade
grounds,
senior
and
junior
staff
housing,
hospital,
clinics
etc.
SCS
Somaliland
Cadastral
Surveys
SDF
Somaliland
Development
Fund
SSLTAP
Somaliland
Secure
Land
Tenure
Arrangements
Project
xeer-‐beegti
legal
councils
responsible
for
administering
xeer
UNDP
United
Nations
Development
Program
28