After 17 years of struggle, UN recognises peasants’ rights:
UN General Assembly approves Declaration for the Rights of Peasants and Other People Working in Rural Areas
The Declaration is hugely significant as a first step to recognise and protect the rights of peasants and people working in rural areas, including their land rights:
- Peasant women’s rights “to equal access to, use of and management of land and natural resources, and to equal or priority treatment in land and agrarian reform and in land resettlement schemes”;
- Peasants’ “rights to active and free participation, directly and/or through their representative organizations, in the preparation and implementation of policies, programmes and projects that may affect their lives, land and livelihoods”;
- Peasants “have the right to land, individually and/or collectively, […] including the right to have access to, sustainably use and manage land and the water bodies, coastal seas, fisheries, pastures and forests therein, to achieve an adequate standard of living, to have a place to live in security, peace and dignity and to develop their cultures.”
The Declaration also encourages that “States shall take appropriate measures to carry out agrarian reforms in order to facilitate broad and equitable access to land and other natural resources (…), and to limit excessive concentration and control of land” and that “landless peasants, young people, small-scale fishers and other rural workers should be given priority in the allocation of public lands, fisheries and forests”.
ILC members participated in advocacy and negotiations to ensure the right to land, including the land rights of women, feature prominently in the Declaration. ILC welcomes the adoption of the Declaration. In particular, ILC supports the inclusion of agrarian reform as a solution to protect and promote peasants’ rights. This is a foundation of ILC’s 2018 Bandung Declaration in which ILC members called for urgent action on agrarian reform and protecting land and environmental defenders.
ILC’s Director Mike Taylor welcomes the Declaration as yet another benchmark for land rights in addition to the Voluntary Guidelines on the Responsible Governance of Tenure, as well as binding human rights convention that are essential to the realisation of land rights: “We celebrate the adoption of the Declaration as a step towards recognising the right to land as a human right. We are committed to support members to use the Declaration as a tool to further their work to promote people-centred land governance.”
The Declaration is available in all UN languages here: https://undocs.org/en/A/C.3/73/L.30
5 things you need to know about the new Strategy: https://www.landcoalition.org/en/regions/global/our-strategy-2016-21
- The change we seek as a Coalition is clearly envisioned in ILC’s 10 commitments to people-centred land governance.
- Building on our strength and niche as a network, ILC focuses on creating opportunities for its members to Connect, Mobilise and Influence.
- Our primary impact is through enabling systematic change at the country-level through our National Engagement Strategies.
- We facilitate engagement with influential changemakers beyond the Coalition, including government and the private sector.
- We have elevated our focus on addressing inequality, in particular gender inequality by ensuring women’s land rights and gender justice are elevated and cut across all areas of work.
How did we get here?
Preparation for the 2016-21 strategy began in June 2014, with 178 member and partner organisations responding to a survey on expectations and goals for the next six years. further inputs were then provided through four regional and one global consultative workshop between October and November 2014. In March 2015, the Council validated the draft in light of their inputs.
The ILC Strategy 2016-21 will be accompanied by a Roadmap describing in greater detail how it will be implemented, which will be developed after the Assembly and endorsed by the Council in December 2015.
The Dashboard is a comprehensive monitoring tool, developed by ILC members with the goal of promoting people-centered land governance. Conceived in 2016 and developed in consultation with members throughout 2017, the Dashboard is based on the fundamental recognition that civil society organizations are well – if not the best –positioned to measure changes to land governance on the ground.
The success of the Post-2015 sustainable development goals (SDGs) will depend on the adoption of indicators that allow measuring progress towards targets and provide helpful information to policymakers.
In preparation for the March 3-6 discussions, the UN Statistical Commission compiled recommendations from the UN system. We applaud the inclusion of land rights indicators to track progress toward targets 1.4 and 5.a. We support the growing consensus on this subject, and we reaffirm the fundamental importance of secure and equitable land rights for the achievement of the SDGs.
As member states move towards the next inter-governmental negotiations, ILC proposed two indicators fundamental to achieving ‘the future we want’ and confirmed that these indicators are meaningful, universal, and feasible, and that they capture fundamental realities affecting key stakeholders at the heart of the SDGs.
Priority land rights indicator
Combining suggestions from UN Women, IFAD1, UNEP2, and the Sustainable Development Solutions Network (SDSN), we propose the following land indicator to monitor land rights in the next 15 years. This indicator is fundamental and should be prioritized, as it provides the most basic information on this subject. It is based on what has been proposed by SDSN and consistent with recommendations from the Global Land Indicators Initiative. While recommending it to be placed under the Target 1.4, this indicator can also track progress toward targets under Goals 2, 5, 10, 11, and 15.3
Percentage of women, men, indigenous peoples, and local communities (IPLCs) with secure rights to land, property, and natural resources, measured by
- percentage with legally documented or recognized evidence of tenure4, and
- percentage who perceive their rights are recognized and protected
This land rights indicator can be defined as follows:
1a (number of women with legally documented or recognized evidence of tenure / number of women) x 100, and similarly for men, and IPLCs.
1b (number of women who perceive their rights are recognized and protected / number of women) x 100, and similarly for men (with overview where appropriate also at IPLCs’ level).
A complementary area indicator on common land
Considering the transformative aspirations of the Post-2015 Agenda, we also support a second complementary indicator under Target 2.3 and 15c that tracks progress on a critical aspect of tenure: common lands.5
It is fundamental to mention explicitly women, men, indigenous peoples and local communities
Strengthening land rights for women, indigenous peoples and local communities goes hand in hand with the realization of development objectives related to poverty alleviation, food security, advancing women’s empowerment, and environmental stewardship.
Firstly, land-related indicators that explicitly distinguish between “the percentage of women” and “the percentage of men” have a built-in safety guard to ensure that this ambitious development agenda does not leave women behind, unintentionally exacerbating the gender asset gap and undermining governments’ ability to meet the globally agreed upon goals. Alternative wording such as “proportion of the population” or “percentage of households” leaves the door open to prioritizing men over women.
The explicit inclusion of “indigenous peoples and local communities” ensures that this agenda recognizes and protects their land rights, in line with globally agreed upon recommendations such as those from the Voluntary Guidelines on the Responsible Governance of Tenure, Convention on Biological Diversity (CBD) and Rio+20. Likewise, an area indicator on common lands capture an important piece of information that is critical for those who have rights over collective tenure, and can make the picture of worldwide trends in land tenure more comprehensive.
The land rights indicators are meaningful
There is no perfect indicator, but as recognized and proposed by SDSN, documentation and perceptions provide fundamental and complementary information on tenure security. In addition, they both highlight outcomes and on- the-ground realities.6 The legal recognition of tenure is important,7 but not always sufficient to fully guarantee that rights to land are experienced in practice. Field experience around the world suggests that for these rights to be secure, they must be backed by effective, inclusive and gender-responsive systems of land administration and justice.
By tracking the extent to which these rights are documented (sub-indicator 1a), we allow governments to demonstrate that they are taking steps to formally grant the rights. The expression “legally documented or recognized evidence of tenure” is broad enough to consider different forms and systems of tenure, which in some countries may necessarily be expressed at the individual level, while in others may also include community-based and collective customary forms.
By tracking individuals’ perceptions of their own tenure security (sub-indicator 1b), we summarize in one measure the economic, social, and political risks affecting individuals, their households, and their communities as they perceive them. Individuals may face different kinds of threats to their land rights. Examples of these threats include the possibility of losing land due to adverse economic circumstances, to conflict in their communities, to large scale land acquisitions, or as it is often the case for women, to intra-family dynamics such as losing a husband.
Indicator 1 therefore measures the tenure security of all women and men, as well as the collective tenure of the communities – by looking for administrative data indicating which IPLCs have registered rights over common lands under relevant national frameworks. Comparing these results provides critically important information, as one can determine whether members of these communities are less secure – due to factors affecting the entire community or only some of its members — and, importantly, whether women in these communities are as secure as the men. By tracking progress in recognition of common lands under the tenure of indigenous peoples and local communities (indicator 2), we recognize and protect an important dimension of tenure arrangements that are expressed and held in common, including forests, rangelands, wetlands, and dry-lands.
The land rights indicators are universal
By using the number of women (or men) as the denominator in indicator 1 a and 1b, we ensure that the indicator is based on the entire population. It is important to note that alternative formulations – such as focusing on those who are heads of households, landowners, or legally married for example – will unintentionally limit the indicators’ coverage and obscure gender disparities. Where appropriate, this indicator should also get complementary information on the number of IPLCs that have their tenure legally recognized and documented.
Similarly, by using a numerator that goes beyond ownership, these indicators can help guarantee and protect the rights of women and men who access land through a number of group or individually held tenure arrangements whose nature and prevalence can vary across the globe. Owning land may not be feasible in certain settings and may not be affordable for many. The indicator we propose can capture, for example, the tenure security of those whose claims are based on long-term contractual use rights, rental agreements, orcommunity-managed resources.
Likewise, an indicator on common lands under the tenure of IPLCs is universally applicable, as collective tenure is widespread across countries, and applies to a wide range of land users, including pastoralists, indigenous peoples, fisher folk, hunter-gatherers, and others accessing common-pool resources.
The land rights indicators are feasible
As conveyed by the Transformative Agenda for Official Statistics, national statistical systems will need to take short, medium and long-term actions in order to strengthen their capacity and close important data gaps. The transformative agenda calls for improved administrative data, for expanded household surveys, and for the collection of data at the lowest possible level. On tenure, this means collecting data at the individual level and, where appropriate, data on rights held collectively by indigenous peoples and local communities.
We fully support the goal of strengthening countries’ administrative capacity to gather, generate and make available land tenure data. In order to enable the production of sub-indicator 1a for women and men, countries would need to have data on their entire territory and that data would have to contain unique individuals’ identifiers.8 For IPLCs, it also requires that collective rights are recognized and documented in administrative records. While this is already taking place in many countries, in others these are long term efforts that, unfortunately, do not align with the more immediate demand for data required to track the post-2015 agenda and must therefore be supplemented with other sources of data.
In the medium term, nationally representative household surveys can be used to calculate sub-indicator 1a for women and men. A number of countries have piloted similar efforts through the Living Standards Measurement Study-Integrated Surveys on Agriculture (LSMS-ISA). In these surveys, households provide information on all their members and all their plots of land. For each plot of land, they are asked if they have documents, what type of documents and, often, whose names are included in the documents. The list of documents to consider varies by country.
These household surveys will need to be adjusted to (1) ensure that the survey asks about all the plots the household uses, not only plots that the household owns; (2) allow each country to determine the set of documents with legal validity; (3) ensure the survey identifies all those who are listed in the documents (that it accounts for all the persons, not only the first person named, and that it gathers data that identifies the person not just his or her gender, see endnote 7; and, (4) ensures that the survey asks about rights to access and use common lands and natural resources. As mentioned above, administrative data should be used to complement this information by tracking the number of indigenous peoples and local communities whose collective tenure is legally recognized and documented.
Sub-indicator 1b is about women and men’s perceptions of their own tenure security and therefore needs to be collected through nationally representative individual surveys. In recent years, researchers from a number of institutions that include but are not limited to IFPRI, NORC at the University of Chicago, UN Habitat and Landesa have tested the type of questions that could be used to elicit women and men’s perceptions of tenure security. Considerable progress has been made on how to gather this data, but only a small number of projects and organizations collect it regularly. Where appropriate, these data should be also aggregated at IPLCs’ level, to have an overview of the percentage of members who perceive their tenure over common land secure.
For indicator 2 on common land, relevant spatial information can be retrieved through administrative data that track domains and spatial units under relevant legal frameworks; and can be supported by GIS information, which is a widespread and mobile technology. Data can also be complemented with information from community-based monitoring systems and validated by experts’ and peer groups.9 Such an indicator is achievable in a cost-effective way in all countries, is measurable over time, and allows for incremental measurements. It can use internationally agreed definitions and standards, such as those developed through the Voluntary Guideline on the Governance of Tenure.
A feasible tool to start tracking rights to land in the Post-2015 agenda: Global Polls
While building countries’ capacity to collect data for sub-indicators 1a and 1b and indicator 2 will take some time, global polls can be a cost-effective and timely tool to create a robust baseline, to guide policy makers, to at least track progress using individual, sex-disaggregated data on land tenure security (sub-indicator 1a and 1b). In addition, by testing questions in different contexts, they can help refine survey modules before their adoption by national statistical agencies.
In fact, this is precisely the approach that has been successfully pioneered by the World Bank and by FAO to address essential global data needs on financial inclusion (Global Findex) and access to food (Voices of the Hungry), respectively, in a timely and cost-effective manner.
In a period of less than two years and with funding from the Bill and Melinda Gates Foundation, Global Findex gathered, analyzed and released data on how individuals save, borrow, make payments and manage risk, based on interviews with more than 150,000 nationally representative and randomly selected adults in 148 economies, covering over 97% of the world’s adult population.
More recently, FAO’s Voices of the Hungry relies on global polls to create and maintain the first nationally representative database on individuals’ access to food. The database covers more than 150 countries, will be updated annually and will inform national and international policy making, in addition to help monitor the Scaling Up Nutrition movement, the SDGs, and other international commitments.
Indicator 1 should always be disaggregated by gender, and can also distinguish between tenure arrangements, urban and rural populations, those living on communal land, and vulnerable populations. Indicator 2 should explicitly track common lands whose tenure is legally recognized, secured, documented, and protected, but also whose regulations guarantee equitable access and use to women and men.
We should not be deterred by the current limitations on available data
We propose indicators for which data collection is feasible and cost effective, and for which even greater progress can be made in an incremental manner. Our belief is that we should strive to measure what is critical, even if it requires additional efforts in data collection. The development of the post-2015 framework provides an opportunity to push the data and evidence base forward, rather than having the available data control the framing of priorities.
There are good precedents for this. Only a few years ago, the data on poverty was limited, inconsistent, not representative and noteasily available. Yet this did not stop visionary leaders from establishing high level objectives thatserved as a visible call toaction with more focus, accountability, and improved processes forgathering evidence and measuring progress. Today we have good data on poverty and know the world has made considerable progress.
Data are not an end in itself. They allow policy makers to take more informed and effective decisions to promote change. We encourage governments to take this historic opportunity to measure and improve the livelihoods of the poorest and most marginalized women and men in the world.
Information and contact
This technical briefing has been prepared by Action Aid International, Forest Peoples Program, Habitat for Humanity International, Huairou Commission, the International Work Group for Indigenous Affairs (IWGIA), the International Union for Conservation of Nature (IUCN), Landesa, Oxfam International, the Rights and Resources Initiative (RRI) and the Secretariat of the International Land Coalition.
For questions or suggestions, please contact:
Katia Araujo at firstname.lastname@example.org; Melany Grout at email@example.com;
Luca Miggiano at firstname.lastname@example.org; or Jenny Springer at email@example.com.
This briefing is also endorsed by
- AAP, Aide et Action pour la Paix, DRC
- ADHD, Autopromotion rurale pour un Développement Humain Durable, Togo
- ALRD, Association for Land Reform and Development, Bangladesh
- APDH, Association pour la Paix et les Droits de l’Homme, Burundi
- CEPES, Centro Peruano di Estudios Sociales, Peru
- Cicodev, Senegal
- CSRC, Community Self-Reliance Center, Nepal
- CTV, Centro Terra Viva, Mozambique
- FIANTSO, Madagascar
- Fundapaz, Fundación Para el Desarrollo en Justicia y Paz, Argentina
- FUNDE, Fundación nacional para el Desarrollo, Ecuador
- MACOFA, Mau Community Forest Association , Kenya
- RDF, Rural Development Fund, Kyrgyz Republic
- SDF, Social Development Foundation, India
- SER, Servicios Educativos Rurales, Peru
- SONIA for a Just New World, Italy
- ULA, Uganda Land Alliance
- Xavier Science Foundation, Philippines
- See UN Statistical Commission’s “List of Proposed Preliminary Indicators”.
- According to the UN Statistical Commission’s “Background Information to the List of Proposed Preliminary Indicators,” UN agencies suggested 6 options for tracking progress on land and property under target a. To keep the list of indicators manageable, the UN Statistics agency chose the indicator that had been listed first. The indicator proposed by UNEP reads “Percentage of women, men, indigenous peoples and local communities with legally recognized evidence of land tenure, and percentage of them who perceive their land rights are secure.”
- The indicators can help track progress towards targets 4, 2.3, 5.a, 10.2, 11.1, and 15.a.
- We have framed the indicators around “tenure security” but they could also be framed around “secure land ”
- Tenure arrangements that are expressed and held in common, including forests, rangelands, wetlands, and dry-lands under the collective tenure of indigenous peoples and local communities, including pastoralists, fisher folk, hunter-gatherers, and others accessing common- pool
- We acknowledge that the wording of the indicators we propose is not entirely consistent with the draft language of the targets, which currently range from “ownership and control over land” (goal 1) to “secure and equal access to land” (goal 2) and “access to ownership and control” (goal 5). These differences can be easily reconciled, improving the effectiveness of the agenda, with a few small tweaks. Here is an example.
Land and the SDGs: Key takeaways from the 2017 HLPF and what we need to do next, July 28, 2017
Without People-Centred Land Governance, governments will not be able to achieve the Sustainable Development Goals (SDGs). In fact, if we fail to secure and protect land rights, for those who live on and from the land, it will be impossible to achieve or, in most cases, even make significant progress on at least as many as 13 of the SDGs goals, 59 targets and 65 indicators.
No SDGs without major progress on land
This was the clear and strong message that was brought by the land community into the major global forum on the SDGs, the High Level Political Forum (HLPF), which is the central platform for follow-up and review of the SDGs that take place every year in July in New York.
Several ILC Members engaged in the 2017 HLPF from 10th to 19th of July, to strongly advocate on women land rights, and more specifically, to lobby various actors on the need to move the major SDGs land indicators toward their full implementations. Critical recommendations for the HLPF were developed by an Expert Group Meeting on Women Land Rights convened by GLII, UN Habitat, Oxfam, Landesa, Huairou Commission and UN Women that also involved other ILC members and the Global Secretariat (document found below).
The HLPF brought together nearly 2500 delegates, and 77 ministers, cabinet secretaries and deputy ministers and delivered a Ministerial Declaration referencing the importance of land rights and tenure governance. The 2017 HLPF focused on the thematic review of SDGs 1, 2, 3, 5, 9 and 14 and more than 40 Voluntary National Reviews. Additional background information on the HLPF and a detailed report on what happened at the 2017 HLPF can be found here.
Why is it critical for the land community to engage in the SDGs? What are the key takeaways from the 2017 HLPF?
- The SDGs can provide a massive contribution to move us toward People-Centred Land Governance. The SDGs do not substitute the need to implement the VGGTs and other land-specific instruments, but can be used to: 1) Mobilize high level political will and commitment across all relevant governments’ ministries, agencies and actors; 2) Ensure all governments measure progress on land rights through solid and comparable indicators and are hold accountable through adequate review mechanisms. However, to make this happen we need to scale up our efforts to influence relevant SDGs processes and key institutions at national and global levels.
- The HLPF represents an important forum to track progress on the SDGs and ensure that land remains central in global agendas. However, most opportunities to harness the SDGs for progressing on land governance are at country level. The development of national implementation mechanisms, the increasing alignment of development partners on SDGs targets, the implementation of land indicators and Voluntary National Reviews (VNRs) processes, represent important advocacy opportunities for land policies reforms at country level.
- There is a risk that land will disappear from the global agenda if we do not take collective action within the next months and years. The global agenda is critical to ensure that land policy reforms at country level move forward. The HLPF is an important space to reach key decision makers beyond those normally dealing with land issues. In order to keep land high in non-thematic forums like the HLPF, it is critical to frame our messages for a political audience. Furthermore, it is critical that the land indicators will be fully implemented. In fact, without indicators land will never be included in UN progress reports and major SDGs-related policy debates.
So, what we need to do next?
- In November, there will be a crucial meeting on the SDGs’ land indicators. In fact, the Inter-Agency Expert Group on the SDGs which is composed of 27 Countries will meet to decide whether the land indicators will move toward their full implementation. We will need your help to make this happen! We will get in touch with relevant NES and Members in the next weeks to see how relevant countries can be influenced. In the long term, we will need all countries to invest in adequate resources and have the political will to collect data for the land indicators. In fact, those indicators will be a critical tool for our advocacy work at national, regional and global levels.
- The land community should increase its efforts in targeting SDGs processes at national and global levels. In 2018, the HLPF will review four goals that are very relevant for the land community: the goals 5 (water); 11 (human settlement); 12 (Sustainable consumption and production) and 15 (life on land). We need to ensure that the 2018 HLPF will deliver strong and actionable recommendations to move the world forward on land rights. Furthermore, in 2018, several countries are expected to deliver their VNRs [https://sustainabledevelopment.un.org/vnrs/] in 2018 that normally should be an outcome of all stakeholders’ consultations at country level.
If you would like more information or want to work more on the SDGs at a global level, please send an email to firstname.lastname@example.org. In the next weeks, the ILC Global Secretariat plan to develop a paper to support Members willing to engage on the SDGs.
During consultations, the Dashboard was built with the monitoring needs of members in mind: What changes in land governance are the most important to measure? How could a tool like Dashboard help to consolidate land-monitoring efforts on these priority issues?
The tool is built on 33 core indicators, which are organized according to the 10 thematic Commitment of ILC. In general, progress against these commitments is measured by three types of indicators: legal, implementation, and impact. Legal indicators measure the presence (or lack) of a legal framework to address the issue at hand, implementation indicators evaluate the degree to which relevant policies and laws have been implemented and impact indicators document on-the-ground impacts.
Using standard methodologies for data collection, one of the great of the Dashboard lies in its ability to overcome fragmentation in existing land monitoring initiatives. While its flexible approach allows members to choose the indicators they use, its core indicators contribute to ongoing local, regional and global data collection efforts. Several Dashboard indicators align with SDG targets, principles of the VGGTs, as well as indicators developed by UNDRIP, GLII and others.
By allowing members to generate data on the issues that matter most to them, the Dashboard encourages data ecosystems that complement and offer people-centered alternatives to official numbers. It will give a platform to data sources, perspectives and populations often underrepresented in national statistics. While it broadens the debate on land monitoring and land governance, people-centered data also amplifies space for civil society in national policy spaces.
The full Dashboard tool is currently being piloted in Senegal, Colombia and Nepal, with preliminary results already being recorded. Other regional initiatives, such as the Latin American Red de Iniciativas de Monitoreo, have already adopted select Dashboard indicators as well. Next year, the Dashboard intends to expand coverage to all countries where the ILC has an established National Engagement Strategy (NES).
Check out the latest indicators (August 2018)
Indicators, August 2018
Legal and institutional framework in place at national level for securing tenure rights, for
different types of tenure and by sex
Women and men with legally recognized documentation or secure rights to land,
disaggregated by type of tenure
Women and men who perceive their rights to land are protected against dispossession or
eviction, disaggregated by type of tenure
Legal and institutional framework in place at national level recognizes a continuum of
individual and communal land rights, including secondary rights of tenants, sharecroppers,
Implementation of diverse tenure rights and regimes, including secondary rights of tenants,
sharecroppers, and pastoralists
Community members who perceive their rights to land are protected against dispossession
or eviction, disaggregated by sex
Legal and institutional framework in place at national level recognizes indigenous peoples’
right to land, territories, and resources
Implementation of tenure rights on indigenous lands
Indigenous peoples who perceive their rights to land are protected against dispossession or
eviction, disaggregated by sex
Percent of land held or used by indigenous peoples that is recognized
Legal and institutional framework in place at national level to support family farmers
National budget and support programs dedicated to family farming
Equitable land distribution, by size
Legal and institutional framework surrounding land, in place at national level, is genderresponsive
Share of women among owners or rights-bearers of agricultural land, by type of tenure
Women who perceive their rights to land are protected against dispossession or eviction,
disaggregated by type of tenure
Legal and institutional framework in place at national level promotes the local and
sustainable management of ecosystems
Rural districts where land use change and land development are governed by sustainable
use plans that take account of the rights and interest of the local land users and owners
Local control of forest resources (TBC)
Legal and institutional framework in place at national level calls for timely, reliable and
accessible data on land and land-related issues
National information on public land deals made publicly available
Corruption present in the land sector (TBC)
Legal and institutional framework in place at national level to protect land rights defenders
Protective measures ensure the safety of land and environmental defenders
Land and environment defenders threatened, harassed, arrested, jailed, killed, or missing,
disaggregated by sex
Legal and institutional framework in place at national level promotes the equitable
representation of women and men in local decision making
Rural land use management and changes based on public and community input
Target groups including women, youth, and holders of customary rights have access to and
are supported to engage in multi-stakeholder platforms
Legal and institutional framework in place at national level to prevent land grabbing in
private and public investments and includes the existence of procedural safeguards
Challenges to land rights violation attempts
Free Prior and Informed Consent (FPIC) and other safeguards are implemented in largescale
Land grabbing cases where corrective action was taken against violators
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