DRAFT 7/10/00

Comments by Ratanakiri IO/NGOs on the ADB RTA 5771

Interim Report on "Opportunities for Project Interventions" in the Cambodia Sesan Watershed

Based on brainstorming discussion 25/9/00, including senior management  representatives and advisors of CARERE/UNDP, WWF, ADHOC, CIDSE, Health Unlimited, ICC, NTFP Project

Summary of main Points

Strengths and Opportunities                                                                [TOP]

• The ADB may be able to exert the leverage needed to address transboundary issues such as mitigating the impact of Yalli Falls.  This should be a priority, and pre-requisite for other project interventions.
• The ADB may be able to exert leverage for forestry policy reforms and enforcement mechanisms to curtail the rapid deforestation and anarchic activities of logging concessions.  This should be a priority activity and a pre-requisite for  other project interventions.
• The project proposes working through existing governance structures (such as the Seila network).  This will avoid considerable confusion on the part of local communities, providing that good coordination and cooperation is maintained.
•  The consultation  2-3 October 2000 and future planned consultations with NGO/IOs, are an opportunity for ADB to ensure sound strategies in the project formulation and to rectify the lack of consultation during the study phase.  ADBs commitment to sound environmental management and poverty reduction strategies will be indicated by the extent to which these recommendations have been considered and incorporated into the project.  

Weaknesses of the study

• The timeline for the overall project needs to be twice as long, with gradual step-by-step implementation to facilitate long-term development.
• The study lacked consultation with NGO/IOs both during the field work and drafting the interim report,  even though a number of them work in relevant districts.  Only one NGO received information and an opportunity to comment late in the process of drafting  the interim report.
• 50%  of the  PRAs conducted were in lowland villages,  however, the majority of Ratanakiri's population are ethnic highland peoples, who also are the most vulnerable groups in  the province.  Little mention is made of cultural issues and the challenges facing the indigenous peoples due to the influx of lowlanders and the rapid transition to a market economy.  The PRAs appears biased towards the lowlanders' situation  and is weak on good analysis of highland issues.  An example is the conclusion in the interim report: "There are no land issues in Kun Mum district".  In fact, there are chronic land issues affecting highland villages along highway 78 (including Kun Mum).  About half of the population of Kon Mum district are Highlanders. The survey did not take the time to consult even briefly with NGO or Provincial Government personnel to obtain this significant information.  There are many examples of a similar lack of consultation throughout the report.  This lack of consultation with NGOs is a breach of ADB policy. 
• Analysis of agriculture issues is also extremely weak and the recommendations unrealistic.  This submission recommends that the survey and analysis of land and upland agriculture issues be redone with participation of all significant stakeholders and practitioners.  The highlanders are the ones most marginalized from policy processes and the population most likely to be impacted (positively or negatively) by the project interventions.  Therefore, lack of good analysis of their situation, and specific issues threatening their self-determination is considered to be a serious oversight.      

4.2  Environment and Watershed Management                                    [TOP]

Impact of Hydropower Dams on Poverty

• Operation of the Yali Falls hydropower scheme in Vietnam is currently the most significant factor exacerbating poverty in communities living along the Sesan River (Baird I.G. 2000).  Indigenous communities with well established villages and paddy fields along the Sesan River have abandoned their village sites and paddy fields to start swidden cultivation a day's walk from their village site. The impact of the flooding from Yali Falls is multi-faceted, affecting not only food security and agriculture, but also the long term development and capacity building initiatives. Traditional income generation activities were abandoned along with the village site.  Long term development efforts such as community NFE classes and community health activities are disrupted as the villagers focus on remedying the food security crises.

Strengths and Opportunities

• The interim report recognizes that RTA 5771 interventions in the Sesan project area will not be sustainable unless immediate mitigating measures are taken by the managers of the Yali Falls hydropower dam in Vietnam (section 5.1).  Section 4.2.2 recommends achieving this through cooperation with existing initiatives to monitor the downstream impacts of the dam and to make policy recommendations. 

Endorsement

• If the project is able to successfully support these joint initiatives of the Province, local communities and IO/NGOs, and to combine this with effective advocacy at the national and transboundary levels,  this may be the most significant contribution that RTA 5771 can make to ameliorating poverty in the Sesan Basin.  If this recommendation is not followed through, other project interventions in the Sesan basin may have only temporary and cosmetic impact. There is little or no point to the project if the Yalli Falls issue is not satisfactorily resolved.         

Forest Concessions                                                        [TOP]

Strengths

• The project intends to support DAFF and DoË to more effectively monitor and enforce concession logging operations (4.2.1).  Local communities will be supported with maps of concession areas so they can monitor and protect their culturally important forest areas.  The project intends to influence forest policy reforms so that logging concessions which have committed significant contractual infringements will be cancelled (4.2.2).
• The project is advised to support pilot community-managed forest guard and  monitoring systems (4.2.2).

Weaknesses

• There is no guarantee that DAFF and or DoE will be able to effectively monitor and enforce concessions, especially since (as the report acknowledges) DAFF gives illegal support to concessionaires in their contractual infringements (4.2.1). There is also no guarantee that they will assist the communities in monitoring efforts.

Recommendations

• The project should build on the work of IO/NGOs in Ratanakiri in cooperation with DoE to build local community networks and capacity to monitor the logging concessions.  Concession maps supplied to the local communities should have the objective of supporting community monitoring efforts.  Delineation of culturally important areas (for protection) on the concession maps, must take place with full participation of the communities affected.  Supporting local community stakeholders in this way has greatly increased the effectiveness (and will) of DAFF and DoE to monitor and enforce.
• The project must effectively advocate at national level for a forest Law that legitimates local community role in initiating, protecting and managing forest resources.  First drafts of the New Forest Law undermine community management.  

Community Based Natural Resources Management                [TOP]

Strengths

• The report advises the project to build on the work of existing Community Forest Management Associations in Ratanakiri Province in order to secure ethnic minorities participation in forest management , monitoring and benefits (4.2.3).

Weaknesses

• Trained human resources do not yet exist who could implement the project.  All interventions must begin with training and proceed only as staff is trained. 
• There is no clear strategy or proposal given for promoting community natural resources management

Recommendations

• Community based NRM should be the focal strategy of project environmental interventions.  The project must work in close cooperation with existing Local community NRM associations and the Provincial Government Departments and NGO/IOs who have been piloting this work.  The project should consider implementing through those agencies and organizations who already have the experience on the ground.  The proposed NRM activities are specialised type of work which are necessarily time consuming and require much groundwork. 
• Training should be a central component to all interventions, and the implementation timeline must take into account the length of time needed to train human resources.

4.2.7 Tourism                                                                                [TOP]

Strengths

• Co-management institutions with strong representation from (and benefits flowing to) the affected indigenous communities are recommended.  The report recognizes the need to proceed with caution and intends to develop a strategy based on the experience of the CARERE-Seila project in Ratanakiri as well that of Oxfam and IUCN in the region (4.2.7).
• Vulnerability of remote ethnic minority communities and their dependence on the local environment is acknowledged as an important consideration before proceeding with tourism development.

Weaknesses

• The proposed promotion of private tour operators for eco-tourism needs clarification about how they will operate and be regulated.  Private operators with hilltribes in northern Thailand have had very negative impacts on the local communities.  It needs to be specified how private operators will contribute to the Government's budget for management of the national park. 

Recommendations

• Discussion and goal setting with local community stakeholders, and awareness raising about the potential problems, should be the starting point for any eco-tourism initiative.  Clear strategies and strong policies on protecting local community ownership and cultural values from the impacts of tourism must be developed by the project and partner agencies, with the participation of indigenous representatives, GO/IO/NGOs and human rights groups, and environment protection agencies well in advance of project interventions.  Any eco-tourism activities must have community management education prior to implementation.

Upland Agriculture (4.2.4)                                                        [TOP]

Strengths

• The report recognizes the crucial linkage between forest protection and the agriculture systems of highland people.  It acknowledges that traditional upland farming systems are mainly destabilized by external factors, such as forest and agriculture concessions, immigrant settlers etc.  It supports the Global Witness recommendation for cancellation of all concessions on indigenous people's uplands.  It recommends that project agricultural interventions build on the existing diversified skills and experience of the indigenous upland farmers.
• It recognizes the questionable sustainability of existing and planned industrial agriculture concessions (5.1).  "Without cautious consideration in the planning and implementation, these schemes are at risk of increasing resource competition and further environmental degradation".

Recommendations

• The analysis made here in section 4.2.4 and the constraints mentioned in section 5.1. are a sound basis for developing project interventions.  The recommendations for agriculture interventions made in section 4.3 should be reviewed to be consistent with  these sections.

Forest Land allocation                                                            [TOP]

Strengths

• Securing land user rights for local ethnic minority groups is acknowledged as being fundamental in order to control external and internal user pressure on natural resources.

Weaknesses

• There is no strategy given for securing land user rights

Recommendations

• Established customary user rights of forest land (for agriculture, protection and cultural uses) by indigenous communities, must be mapped as rapidly as possible throughout the Sesan basin (and other project areas) using the available GIS technology.  These maps, once endorsed by local authorities at the provincial and district level, will provide an effective instrument to ensure that local communities are included as important stakeholder in discussions regarding all proposed development interventions which affect them.  These may include agriculture, forestry and infrastructure projects of RTA 5771 or of other private and public proponents.
• RTA 5771 must (as a priority and pre-requisite for other project interventions) support the advocacy efforts of NGO/IOs and local community groups in the project area to ensure policies and principles in national and local decision making that respect and protect the legitimacy and rights of the local community stakeholders (especially indigenous ethnic minority groups).  Without this, other project interventions may be ineffective or even exacerbate poverty and environmental degradation.

Data Availability (4.2.1)                                                            [TOP]

Weaknesses

• The agency responsible for data management is not specified. Who will control access to the Land use and Forest Cover data and maps?  Past experience has shown that unless the data and GIS resources are managed in a multi-sectoral manner, certain agencies may control them to their own benefit, at the exclusion of other interests.

• Province and District wide Land Use mapping and zoning by line agencies may be used by speculators and investors to alienate more land from local communities for commercial purposes unless local user rights are protected in advance.

Recommendations

• Establish a multi-agency secretariat to facilitate easy access to the data and maps.
• As per recommendations for Forest Land Allocation as above ie ensure that legal protection of customary user's rights has been established before the data is made publicly available.
• Propose a specific plan for data distribution and sharing.

Biodiversity (4.2.6)                                                                    [TOP]

Strengths

• The report recommends monitoring and survey of the plant and wildlife species composition of the species rich dense evergreen and deciduous forests in Sesan District (overlapping with the Pheapimex-Fuschan logging concession).

Weaknesses

• The project should not assume that the Pheapimex-Fuschan Concession will be easily cancelled unless there is strong evidence of environmental and social impacts in conjunction with a well concerted lobby effort.
• No mechanism for engagement with MAFF/DFW or Pheapimex-Fuschan.

Recommendation

• RTA 5771 should consider funding and coordinating, mapping and survey of biodiversity (Plants and animals) in the above mentioned forest areas bordering the Virachey National Park.  This needs to take place as a matter of urgency and should not wait until the Pheapimex-Fuschan concession has been cancelled.  This study is important to determine what impact the Forest concession is having on biodiversity, watershed and cultural values and is consistent with the policy of concessions review and requiring Environmental and social Impact Assessment.  The survey would need to be done in conjunction with MAFF/DEW and with cooperation from Pheapimex.  WWF and the World Bank Biodiversity Project would be useful partners in this survey although they have no jurisdiction over the concession area.

Upland Agriculture (4.3)                                                                    [TOP]

Strengths and Opportunities

• Participatory approach to extension and on-farm research are emphasized.

Weaknesses and threats

The recommendations in this section focus on paddy development, irrigation schemes, cash cropping and commercial aquaculture as the solutions to food security and environmental degradation.  They seem to assume that swidden cultivation is the main cause of deforestation.  This is entirely inconsistent with the analysis given in section 4.2 and with the constraints to sustainability given in sections 5.1 and 5.2.  For example, 4.2.4 pinpoints commercial (agriculture and forestry) concessions and settlement schemes as being among the major threats to environmental stability.  Section 5.1 raises serious questions about the sustainability of tree plantations and industrial agriculture and associates such schemes with the risk of increasing resource competition and triggering environmental degradation.   The study on potential for water resource development by J. Himmel in 1997 gives a clear analysis of the limitations of paddy and irrigation development for meeting the food security needs of Ratanakiri's population. 

The recommendations given in section 4.3 are suitable for the lowland situation but not for highlanders.  They would benefit not only enterprising community members, but  opportunistic and exploitive people, who would most likely be immigrants with some means rather than the local rural poor. 

4.3.1 Participatory Community Development                                             [TOP]

Strengths

• Participatory approach is being recommended
• Inclusion of common property management

Weaknesses

• Who will be facilitating these participatory approaches?  Will they be skilled and experienced in this kind of approach?  Will they be familiar with and sensitive to ethnic minority people's culture and social context?  Will they be able to communicate in the local language?  If not, the result of the community organizing process will be very weak.  The current concensus is that staff meeting the above criteria do not yet exist, they will need to be trained.
• While in theory VDCs are bottom-up approach, in reality all the influence and power of decision making vests with the village chief and a small group.  The interim report lacks a description and analysis of the community level planning mechanism.
• How will the proposed interventions fit in with activities undertaken by existing programmes?
• The limited availability of government counterparts will put pressure on other programmes.

Recommendation

• Specify who will do PRA and CNRM and how they will be trained. xx

4.3.2 Income Generating Activities                                                              [TOP]

Strengths

• Food security is being emphasized as the first priority

Weaknesses

• Promotion of cashew and cash crops has been proven to exacerbate short-term deforestation in Ratanakiri and many other places as local villagers and immigrants scramble to clear land for the cash crops. (Refer to report by YRDP students and DoE May 2000). Markets are unreliable (as section 5.1 of the report acknowledges).  For instance coffee and cashew growers in Ratanakiri have suffered considerable economic losses this past year due to drop in prices on the international markets.  Dependence on cash cropping has been shown to exacerbate debt and landlessness of the rural poor in almost all of the Asian developing countries, along with a negative impact on diet and community health in general.  There is no reason to believe that Cambodia or Ratanakiri will be any exception.
• Section 5.1 also makes the point that the environmental sustainability of cash crop plantations is very questionable and "may trigger further environmental degradation" and risk food security problems.
• Cattle theft has been a serious issue affecting villagers in Ratanakiri over the last year.  Market demand in Lao PDR has been the cause of the great increase in theft.  Promoting a cattle market to Vietnam will likely exacerbate the problem of cattle theft even further.  Highland peoples have little recourse through the justic system.  A further complication is that  local law enforcement agencies do not have the capacity or means to adequately deal with the problem.
• Promotion of fish pond culture and fingerling production xxare a lowland activity.  In Ratanakiri, xxsuch activities run the risk of  benefiting only the resource rich who have the money to invest.  It is highly unlikely that this activity will result in poverty reduction or environmental protection of any kind. xxA further complication is that flat areas suitable for fish ponds are currently endangered by flooding. The report makes no mention of natural fisheries which are of high importance economically in Ratanakiri and to the rest of the country.  It is the natural fish stocks which the rural poor depend on for protein, not breeder fish.  

Recommendations

• The lack of analysis shown in this section, of the potential social and environmental impacts of promoting cash cropping, needs to be rectified as a matter of priority and urgency.
• Planning and implementation of cash cropping schemes should proceed with the utmost caution as per point number 3 in section 5.1
• The fisheries option should focus on promoting community management of natural fisheries along the Sesan River and other water bodies.  The feasibility of capture and pond culture needs to be re-examined with serious attention paid to economic, social and environmental considerations.

4.3.3  Improved Farming systems                                                            [TOP]

Strengths

• The report acknowledges that a better understanding of the farming systems is needed and recommends further surveys and study.

Weaknesses

• The recommendations assume that paddy will be "the motor to drive development and assist food security".  While this may work for lowland farmers, Himmel (1997) has pointed out that the potential areas for expansion of paddy production in Ratanakiri is limited.  It cannot be assumed that paddy development can meet all of the food security needs of Ratanakiri's population.  Since 1996, much of the main paddy growing areas along the Sesan River have been devastated by annual floods (Baird 2000 "Impacts of Yali Falls Dam along Sesan River").
• In light of the above mentioned studies and with reference to 4.3.3 regarding the "options for improving farming systems":  (a) prevention of the most serious floods affecting paddy rice production may be possible only through high level bilateral negotiations with the operators of the Yali Falls Dam in Vietnam.  (b) providing structures and irrigation schemes as a replacement for shifting cultivation would be feasible only for a small proportion of the population.  If applied to highlanders, this recommendation would necessarily involve relocation and resettlement of shifting cultivators which would run the serious risk of exacerbating environmental degradation in the short term.  (Refer to report on relocation program in Attapeu province, Lao PDR and other cases in Thailand and Ratanakiri). 

Recommendations

• Research and gain increased understanding of the existing farming systems before making any recommendations about interventions.  This applies particularly to the upland farming systems of the indigenous people.
• Funds for agricultural research should be channeled to competent NGOs already working in the area.

4.3.5  Support Services                                                                    [TOP]

Strengths

• Recognizes the need to redress the problem of access to support services by women
• Supports participatory on-farm research, but methods need to be clarified

Weaknesses

The recommendation of grants and subsidies and provision of micro-credit facilities has had marginal success in lowland areas.  The chances of success with subsistence highlanders who have little exposure to the cash economy would be very slim indeed.  The risk of creating indebtedness and subsequent land security problems, needs to be the subject of extremely stringent analysis before such schemes are further considered.

4.4  Infrastructure                                                                        [TOP]

Strengths and Opportunities

• The interim report recognises the need for improved community access to clean water, along with health education and maintenance training to manage the water systems
• Improved roads will facilitate improved access of the local population to health and education services, if and when these services are provided at acceptable levels.

Weaknesses and threats

• No Environmental and Social Impact Assessment is being required for infrastructure projects.  This is a very serious deficiency.
• No reference is made to current activities (except for misinformation about UNICEF's role in supporting wells)
• The suggestion that the clean water programme be combined with community based construction of toilets lacks any evidence of realistic situation analysis.
• Most of the budget is for infrastructure, although there is no credible problem analysis given.  This indicates a lack of transparency and accountability in this sector.
• District level roads (such as Hat Bok, Ko Pong) will accelerate the rate of deforestation and landlessness.  Almost all of the land along highway 78 in Ratanakiri has been alienated from the customary users by companies,  business interests and immigrant settlers since 1996.  This has been accompanied by rapid loss of the forest which is cleared for cash crops.  There is absolutely no doubt that, unless stringent enforcements are applied, the same will happen along district level and feeder roads as soon as these are upgraded.  Land speculation is rife in Ratanakiri.  Road-side land with good access in the highest demand. Lowland provinces, and neighboring countries have similar experiences with road construction.  Many of the issues in Ratanakiri relate to land security.  Roads without land security lead to increased resource pressure, forest clearing and speculation.  Thus road construction may actively work against project objectives.
• Without curtailing of logging, newly improved/constructed roads will quickly deteriorate due to heavy use by logging trucks.  Recently improved sub-district roads linking clinics with provincial level roads have deteriorated to the point that the provincial ambulance and health service trucks cannot access the clinic except in the dry season.

Recommendations

• The infrastructure interventions being proposed in this project, especially roads, have potential for causing devastating impact on the environment, and on the land security (and therefore food security) of the local population.  Stringent Environmental and Social Impact Assessment must be applied to all proposed infrastructure projects.  This must be undertaken by independent analysts (not the proponents of projects) with transparency and review including the participation of NGO/IOs working in the project areas.
• If the local population are to gain any benefits at all from improved infrastructure (especially roads and access) then the quality of health and education services provided to them must be drastically upgraded.  RTA 5771 should seriously rethink the priority of health and education in the project.  Upgrading services does not mean building more empty school buildings and clinics.  Upgrading the quality of these services (ie human resources development) should take precedence over infrastructure development in this project.

4.1  Social Development                                                                    [TOP]

Strengths and Opportunities

• Recognises the importance of capacity building for human resource development

Weaknesses and threats

• Lack of analysis of issues in highland villages.  50% of PRAs were done in lowland Khmer and Lao villages (although 75 % of Ratanakiri's population are highlanders).  The analysis of the results does not make adequate differentiation between the needs and problems of highland and lowland villagers; they appear to be treated as a homogenous population.
• Lack of quota or targets specifying beneficiaries from highland populations.  Benefits targeting lowland populations may exacerbate the gap in access to resources between the lowland and highland populations.
• The underlying issues concerning social development lack analysis and cultural perspectives.
• Grant money should be pursued for social development rather than loan money.  Increased indebtedness will not alleviate poverty. The government will be forced to promote and force commercial, cash-crop technologies of questionable sustainability as recognised in Section 5.1.

4.1.3 Education                                                                        [TOP]

Opportunities

• The interim report recognises the importance of providing educational services to the children and youth to enable the new generation to gain literacy and numeracy skills.
• The interim report recognises the importance of NFE for adults, with a range of interventions specifically designed for the age group and felt needs of the  communities.

Weaknesses of the Project

•      Yalli Falls has had significant impact on social development activities in the target districts. The interim report lacks analysis on the impact of the resultant  flooding on the social development and capacity building sector  (eg. NFE, formal education, community development and income generation activities).  A number of well established classes and activities were seriously disrupted and/or discontinued due to the food security crises resulting from the flooding.   Children, youth and adults alike have needed to devote much time and labor to agriculture production and food security issues by preparing new fields and forage from the forest due to the food security crisis.  Flooding has also forced well established indigenous villages near the Sesan to abandon their lowland paddy fields and relocate in upland fields far from village sites, disrupting their traditional income generation activities and long term development activities.

•     The interim report proposes construction of additional school buildings, which does not address the underlying issues.   Empty school buildings already abound, many of which are new and in good condition.  There is a dearth of teachers willing, motivated, and trained to teach in highland communities.  The proposed cost for school building construction is very high per unit.  Construction could be much more cost effective.

• The report lacks analysis of the root causes of lack of school attendance, and appropriate interventions to address these. Providing school and clinic buildings is not the appropriate response, but simply a blue print solution to superficial analysis.
• The report lacks  provision for training  local bilingual teachers.  One reason schools are empty is the lack of local teachers.  Teachers from outside the area are not committed to educating highland peoples, nor to living at  the district and  community level.  Bilingual teachers and bilingual curriculum and materials are needed to facilitate the indigenous students' learning.  This is  especially important for  the lower primary grades as village children speak little or no Khmer language.
• No mention is made of the extensive experience and wealth of  NFE  materials (including bilingual materials) already developed by GOs/IOs/NGOs specifically for indigenous communities in Ratanakiri.
• While proposing NFE for adults, the report lacks an NFE approach (both Khmer and bilingual) for children and youth which is distinct from the formal school-based education system.
• The report lacks recommendations for bilingual primary schools and bilingual NFE activities to address the needs of indigenous children who do not speak  the Khmer language.  Bilingual programmes are now possible as most of the indigenous languages in Ratanakiri now have a writing system using the Khmer alphabet (due to the work of ICC and EMU).
• The Vocational Training intervention proposed in the interim report have limited scope/opportunities and are more relevant for the lowland Khmer and Lao than the indigenous populations.
• The project does not mention the Department of Education as a stakeholder.  All education  interventions would need close coordination with the Department of Education.

Recommendations

• The wealth of experience and field tested materials (both Khmer and bilingual) from GOs/IO/NGOs  working in Ratanakiri are an important  resource for NFE programmes, both with adults and children.
•  Provision of funds for training local teachers through in-service programmes and pre-service programmes.  For pre-service programmes, provision of special quotas and stipends(eg. to attend the Teacher Training Centre in Steung Treng) are needed to  address the human resources issue.

4.1.5  Savings and Credit                                                                        [TOP]

Weaknesses

• Savings and credit (4.1.5) assumes that there is a workable bank system in place which is not the case. 
• S & C does not take into account the fact that most of the indigenous communities are still on a barter system and do not have a market economy. 
• This section makes no mention of alternatives to cash credit such as small animal raising schemes.
• S&C can increase or exacerbate indebtedness and may lead to landlessness, malnutrition, and other problems.
• S & C is unsuitable for implementation in Ratanakiri.  Such schemes run a high risk of exacerbating the poverty and indebtedness of rural highland people.  Schemes should be developed which benefit communities rather than individuals.

4.1.2  Health                                                                                              [TOP]

Recommendationss

• The wealth of experience and field tested materials (both Khmer and bilingual) from GOs/IO/NGOs  working in Ratanakiri are an important  resource for community health initiatives.  This includes bilingual and illustrated materials specially designed for highland villages.

Strengths and Opportunities

• The report recognises the importance of human resource development at the community level (eg. training of Traditional Birth Attendants), and identifies interventions addressing specific health needs of women.
• The report recognises the importance of addressing health issues in order to improve living standards of communities.  The importance of ongoing support for the health system is also recognised. IO/NGOs in Ratanakiri are also working towards these objectives.
• The importance of village health worker training, community health education, and primary health care is stressed. 

Weaknesses

• Health clinics and services do not lack materials or transport.  They are adequately resourced but lack effective management along with the problem of channeling of resources to the district levels.

• More attention needs to be given to sustainable  strategies which support primary health care initiatives.  These include development of community health committees, along with building on and supporting the various initiatives of NGOs currently working in Ratanakiri.

• Analysis of root causes and contributing factors to health issues is weak.  The analysis appears to have been stated to justify infrastructure development, specifically well drilling and road construction.  In fact, access to health services is being addressed through the establishment of health posts and training of local staff for remote communes.  Analysis by GO/IO/NGOs in Ratanakiri show that the main cause of family health problems is communicable diseases (malaria, TB, and ARI), exacerbated by inadequate nutrition.  Diarrhoeal diseases are a major concern, however the water quality is not the only important factor.  Poor food handling and lack of basic hygiene knowledge and practice are major contributing factors. Community health education has demonstrated that hygiene education alone can significantly reduced diarrhoeal rates in Ratanakiri.
• Health centres generally have adequate staffing levels and  the quality of  service is gradually improving.  However the clinic buildings are often empty as the local staff receive very low salaries.  Thus much of their time must be spent on farming or income generation activities, such that they cannot work a full day.  
• Local health training facilities are lacking, thus the majority of new staff must be recruited from outside the province. 

• The project will need to build on the experience of NGO/IOs working in Ratanakiri concerning clean water and hygiene training and initiatives.  The report incorrectly states that  infrastructure has been developed by UNICEF.  Until the year 2000, all infrastructure related to health improvements have been supported by NGOs.

QUESTIONS                        [TOP]

General

• Will prior informed consent (PIC) be obtained from the target communities before commencement of the project?
• Why was there no meaningful consultation with IO/NGOs during the study phase or regarding choice of the Sesan watershed as a target area?  Lack of consultation is not consistent with ADB policy?
• Why has the project decided to come to Ratanakiri after the strong recommendation by MoE and NGO/IOs represented in Jan 1999 at the mid-term review in Vientiane that the Sesan watershed in Cambodia does not have suitable characteristics for the kind of project interventions being conceived?
• Why is the project area overlapping with the World Bank biodiversity project target area?  Why are two large projects needed in the same province (and in geographically overlapping target communities).
• Who is the consulting firm implementing the project?  What is the relationship with the consulting firm implementing the WB biodiversity project?
• What feasibility studies have been conducted as to how the Cambodian Government will repay the loan component?  What analysis has been done of the economic and social burden that will be placed on the country to repay these loans?
• What is the project duration?  A minimum of  10 years will be needed.  The whole project is reliant on cultural adaptation by indigenous peoples.  If adequate time is not allowed for,  and technical fixes implemented, the project will be a cultural imposition with all the social problems that has entailed in other parts of the world with indigenous populations. 

 4.2  Environment

• The terms swidden agriculture, shifting cultivation, rotational agriculture, and slash and burn agriculture are all used in the document.  The differences between these terms need to be clarified.
• Who will control access to Land Use and Forest Cover data/maps generated by the project?
• How will the capacity of the Department of Forestry be increased and their political will to enforce sustainable forest management (given that they are currently giving support to concessionaires to carry out illegal activities)?
• Eco-tourism (4.2.7) mentions participatory approaches but do not clarify how this will be done, or who owns the process.
• How does the project intend to address the crucial issue of wildlife trade?

4.3  Agriculture

• Are the irrigation schemes being provided as an incentive or as compensation to convert from swidden cultivation? (section 4.3.3)
• Upland Agriculture (4.3.1, 4.3.4) mentions participatory approaches but do not clarify what methods will be used, or who owns the process.

·        If industrial agriculture concessions cannot be canceled as recommended in section 4.2.4, how will the project proceed with implementation of agriculture recommendations?

4.1.3  Education

• School infrastructure is stressed, however there are many empty school buildings in the province already.  How will the human resources (lack of teachers) be addressed?
• How will the project integrate with existing NFE programmes in Veunsai, O Chum, Kon Mum, and Taveng districts?

[TOP]

RECOMMENDATIONS FROM RATANAKIRI IO/NGOs

General 

• Prior informed consent (PIC) must be obtained from the affected communities.
• Information dissemination concerning the social impact of the project should be conducted in the villages that will be directly affected, before implementation begins.  This should be done in coordination with the GO/IO/NGOs working in the area.

Infrastructure

• Infrastructure should be put as a low priority, and the budget reduced accordingly.
• Mapping of customary land and forest, and security of user rights should precede infrastructure (roads), which is consistent with the recommendation for Land Use mapping (4.2.1).
• Independent environmental and social impact assessment must be a pre-requisite for all infrastructure development, especially roads. 
• District roads (building and upgrading) should be contingent on effective Forest Protection and Land Security arrangements for the rural poor being in place in advance in the locations concerned.

 4.2  Environment

• Build on existing experiences of Community Based Natural Resources Management (CBNRM) of NGO/IOs in the project area:  Focus on this as the main NRM strategy.
• Effective advocacy on the Yali Falls Dam may be the most significant contribution that RTA 5771 can make to ameliorating poverty in the Sesan Basin.  If this recommendation is not followed through, other project interventions in the Sesan basin may have only temporary and cosmetic impact (Section 5.1, point #5).         
• The project needs to specify a clear advocacy strategy to effectively advocate for mitigation of Yali Falls Dam .  This could include studies on the impact, and on the feasibility of de-commissioning Yali Dam.
• Implement CBNRM work, Sesan monitoring and community network building on NRM issues, through the existing IO/NGOs who have the experience on the ground already (IDRC/ CBNRM and NTFP Project).

 Develop a clear strategy for community participation in:

• eco-tourism
• agriculture development
• CBNRM
• Establish a long term independently funded agency (data clearing house) to ensure that data (such as land use maps and forest cover data) is available to all parties when needed.
• Capacity building for forest monitoring needs to focus on local community monitoring rather than relying on the DoF.
• Study how much indigenous land has been allocated to concessions.  If these cannot be canceled, give priority to the local communities for implementation rights of the concessions.
• Include Sesan community representatives in the Research Committee.

 4.3  Agriculture

• Pay serious attention and set quotas to ethnic and gender balance when recruiting and training extension staff and managers, and planning and assessing the access to benefits.
• Develop community fisheries that target the indigenous farmers, rather than individual schemes which may benefit resource rich immigrants and investors.
• Integrate cash crops into upland swidden cultivation, instead of expecting farmers to convert from swidden cultivation.
• It is recommended that the survey and analysis of land and upland agriculture issues be redone with participation of all significant stakeholders and practitioners.
• Subsidise the creation of marketing cooperatives for indigenous farmers.

 4.1  Education/Health/`Social Development

• Train local community members in basic education.  Develop local teachers from this pool of newly educated community members.
• Literature review and field information gathering is needed for analysis of reasons for poor access to health and education services.  Build on the experiences of NGO/IOs over the last 5 years.   More research is needed on the situation, eg: constraints to women's participation, constraints to Khmer language learning.

• Health should be recognized as a major need and therefore receive higher profile in the project.
• Support should be given to existing successful NGO initiatives which strengthen government health structures and services, as well as primary health care programs (which includes building community capacity to develop health promoting practices).
• Specific attention must be paid to addressing cultural and language issues in training efforts at all levels, along with the educational level of participants.  Training programmes from Phnompenh-based trainers are often too theoretical and sophisticated in content and language to be understood by local staff.

• Long term food security means land security for highland people.  Rice banks, and agriculture interventions are meaningless unless there is secure tenure of land provided.  The tenure must be suitable to the land use and way of life of indigenous people.  Importing the lowland system of land tenure is unsuitable for Highlanders (refer to ADHOC study 1998 and study commissioned by the council of Ministers, May 1999)
• Marketing and credit will marginalize the poorest in the short term, unless careful attention is given to ensuring that they are actual beneficiaries.  Cooperatives, capacity building, and other such efforts would need to be carefully planned and implemented, otherwise benefits will go to lowlanders and those already skilled in marketing, or those who have resources to invest already.

References

• Baird, IG (May 2000) Downstream Impacts of the Yali Falls Dam in the Sesan River Basin in Ratanakiri Province, Northeast Cambodia
• Himmel, Jeffrey (1997);  Potential for Water Resource Development in Ratanakiri.
• Youth Resources Development Project (May 2000) Unpublished report on "Causes of spontaneous forest clearing along the Taveng and Voen Sai Roads in Ratanakiri Province in early 2000". Commissioned by second Vice Governor of Ratanakiri.
• Study on needs and preferences of Highland villages for land tenure:  conducted by ADHOC in Cooperation with Ratanakiri Provincial Secretary General and Provincial Land Titles Department in 1998.
• Report on consultation with highland Communities regarding draft land law;  Study commissioned by the Council of Ministers and implemented in May 1999.
• Draft Cambodian Land law: section on Indigenous Community Land.

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