Rapid Assessment of the PRSP Process in Cambodia

INTRODUCTION

Extract from the speech of the NGO Forum Representative

at the UNDP Workshop on Poverty Reduction Strategies

Phnom Penh, Cambodia, 27-29 November 2000

The NGO Forum first saw a copy of the draft Interim Poverty Reduction Strategy (I-PRSP) when the sixth draft was circulated in English in August 2000. In September and October, an NGO-based consultant from The Philippines, hired with assistance from UNDP, joined the NGO Forum in order to assist the Forum in organising NGO consultations on the strategy. An NGO Forum team held interviews and workshops in Phnom Penh and four provinces with NGOs that work in sectors such as rural development, urban poor development, health, education, human rights, women’s rights and environmental protection. Efforts were also made to meet with other civil society informants, such as indigenous hilltribe leaders, industrial workers, commercial sex workers and urban poor community leaders.

The consultations were aimed at raising awareness about the I-PRSP and Socio-Economic Development Plan (SEDP) processes, and to seek suggestions on how civil society organisations could meaningfully contribute to policy formulation and monitoring. Sectoral summaries in both English and Khmer were developed which highlighted both the relevant sections of the draft I-PRSP and existing NGO recommendations resulting from these and previous NGO discussions. This two-month activity culminated in a National NGO Workshop held on 24-25 October 2000 and attended by 85 NGO representatives, mostly Cambodian. At the National Workshop, the participants prioritised NGO recommendations for poverty reduction, and began discussions on how NGOs could contribute to a national poverty monitoring system. This was achieved mainly through small group discussions in Khmer language, with translation provided to English where needed. Background information was provided in the plenary sessions, from both Cambodian and foreign speakers.

Government and donor representatives were briefed on key recommendations arising from this consultation on 3 November 2000.

‘Poverty reduction’ is not new for the RGC and NGOs and civil society in Cambodia. The government’s commitment to reduce poverty has been articulated in its First Five-Year Socio-Economic Development Plan 1996-2000. NGOs and other civil society organizations have actively contributed to poverty reduction in all sectors with various kinds of activities.

Moreover, the I-PRSP process is not the first time that NGOs in Cambodia have reached broad agreements on what should constitute development priorities to reduce poverty in Cambodia. There have been at least two occasions in the recent past in which NGOs have identified what kinds of reforms need to take place to ensure that development in Cambodia means the improved well-being and quality of life of the poor.

The participation by NGOs and civil society groups in these consultations, however, is still limited. The main barriers to participation are low NGO capacity, not enough time provided for NGOs to prepare for discussion in the consultations and language. Tripartite consultation mechanisms among NGOs, government and donors are still weak. To alleviate poverty in Cambodia, the government and NGOs together have to take responsibility and become less dependent on outsiders, however well-meaning and intentioned. To have a genuine and more meaningful NGO participation in the RGC’s poverty reduction strategy, the government has to be more transparent in the process of formulation and implementation of the Strategy and open to all stakeholders’ inputs.

In October 1999, at NGO consultations undertaken in the context of the World Bank’s Country Assistance Strategy (CAS), development priorities were identified by NGOs generally and by NGOs in Battambang and Phnom Penh.[1] Governance issues were a common theme in these consultations. On the occasion of the Consultative Group (CG) Meeting between the RGC and the international donor community held in Paris in May 2000, the Cooperation Committee for Cambodia (CCC) conducted a survey among its NGO members in February 2000 on the key areas for government reform. Again, governance issues figured prominently in the survey. (See Box 2)

At the more recent National NGO/Civil Society Workshop on the RGC’s Poverty Reduction Strategy held on October 24-25, participants ranked the key cross-cutting and sectoral issues that the government should address as top priority in its poverty reduction strategy. These discussions were facilitated by the preparation of brief sectoral papers and matrices, in English and Khmer, comparing what the I-PRSP says and related NGO/civil society recommendations on the following issues: Rural development and decentralization; Agriculture and food security; Land, forestry, fisheries and environment; Health and education; Women’s and children’s rights; Industrial workers and urban poor; Good governance and human rights; Disaster management.

Cross-cutting issues that were identified from initial consultations with various sectoral groups are shown in Attachment E. From among these cross-cutting issues, civil society participants ranked the top two priorities as:

· Introduce a realistic government salary system, linked to an impartial performance-based scale

· Reassess the respective roles of the public sector, private sector and civil society organizations (including local communities) in the delivery of basic services and management of natural resources to ensure affordable access of the poor to these resources.

· Decentralize local development planning, and allow local communities a greater say in strategies to combat poverty

· Increase resource allocation to rural areas to improve physical infrastructure, agricultural productivity and access to public and social services

Sectoral issues were also ranked according to priority as follows (see Attachment D for more details):

1. Increase resource allocation to rural areas to improve physical infrastructure and access to public and social services.

1. Prioritize land use planning and provision of land title to farmer as core of any assistance to agriculture. Reserve certain areas in land use planning for the increased number of small farmer communities.

1. Implement land reform which should focus on land distribution, land management and land administration.

2. Implement forestry reform to crackdown on large-scale illegal operations and protect the rights of poor communities and indigenous groups.

3. Implement fisheries reform to ensure sustainable access of the poor to fisheries resources.

1. Promote financial transparency and address corruption issues, particularly in health and education disbursements from the MEF, 'under the table payments', and the procurement of drugs by a private monopoly provider.

3. Address the HIV/AIDS threat through more awareness-raising and multi-disciplinary programs that especially target women and children in rural areas.

1. Improve women’s and children’s access to education and health services including reproductive health services, nutrition, communicable diseases and birth spacing.

2. Establish more health centers and motivate nurses to provide good health care services at the community level through increased salaries and more effective training.

1. Government should have plans in disaster preparedness, relief, mitigation and rehabilitation.

2. Government should have effective and efficient mechanism in relief and emergency services with good coordination and cooperation at all levels.

3. Disaster management program has to be yearly investigated to ensure transparency.

The above civil society and NGO recommendations to the I-PRSP, which is in response to the first stage in the preparation of the RGC’s poverty reduction strategy, were a product of vigorous critiquing of overall and sectoral strategies and policy framework as contained in the 7th version of the I-PRSP (dated 2 September 2000). This section will present highlights of initial civil society critique; more thorough analysis, however, needs to be done particularly in the area of potential and/or actual impacts on the poor of macro-economic policies in the I-PRSP.

The I-PRSP contains the following sections: Nature of Poverty; Review of Existing Strategies & Performance; Statement of Poverty Reduction Strategies & Objectives; Capacity-Building & Monitoring; PRSP Workplan; and Policy Matrix. (See Attachment C-3 for an overview of the I-PRSP. See Attachment C-16 for some changes between the 7th & 8th versions of the I-PRSP).

NGOs are pleased about many aspects of the I-PRSP but remain doubtful that it will be successfully implemented. The implications for government budget, institutional capacity and political will need to be ascertained. Further prioritization of the many issues covered by the plan would also be helpful.

The I-PRSP recognizes broad dimensions of poverty that include lack of opportunities, vulnerability, low capabilities and social exclusion. However, poverty in Cambodia is still measured using the income/consumption approach based on a poverty line. Using this measure, the 1999 Poverty Profile in Cambodia shows that 36% of Cambodians live below the poverty line; in 1993-94, the poverty rate was 39%. The I-PRSP also identifies Cambodia's most disadvantaged groups as: internally-displaced people and returned refugees, war widows, orphans, street children, squatters, people with disabilities and isolated ethnic minorities who have poor access to education, training and employment opportunities.

Many sectors in civil society do not agree that the number of poor people in Cambodia constitutes only 36% of the population. Based on their own experiences and perceptions as among the poor in Cambodia or whilst working with poor people directly, many believe that the poor easily constitute at least 50% of Cambodians. There should be a broader agreement between statistics experts in the government and civil society representatives about who and how many constitute the poor in Cambodia using broader dimensions of poverty. This should make use of more participatory assessments involving the poor themselves and why they think they are poor, as well as determining from them how they believe they can rise out of poverty. (See Box 3)

· Many NGO workers believe that the poor become poorer because of their lack of access to productive resources like land.

· Poverty is also linked to lack of political and economic power in Cambodia; the poor have no means to participate in decision-making mechanisms that affect their lives.

· From garment workers: Garment workers who consider themselves among the poor in Phnom Penh and were driven to the city due to poverty and lack of opportunities in the countryside, believe that the 36% figure for the number of poor people is too low. If garment workers live in the city, then receiving a salary of $45/month is 'poor'. In order to cope in the city and send some money to their families back home ($10-20/mo), garment workers need to work overtime (12-15 hours/day), rent cheap rooms ($5/mo/person), not eat well-balanced food. If they continue like this, their health will suffer and they cannot afford to pay for doctors and medicines. The government should think about the situation of garment workers - water, food, working conditions, and sanitation in their cheap dwellings -- garbage, bad smell, tired from work, falling asleep, mosquito bites.

· From a sex worker: “The sex worker is the poor, the poor becomes a sex worker.” Poor women become sex workers due to many reasons -- some were kidnapped or sold into prostitution from poor families in the rural areas, some were separated from husbands and hence find themselves with no man to support them. They do not want to be called ‘srey khoch’ (‘broken woman’) but as sex workers. No alternative jobs are available for them because they lack education or skills. HIV/AIDS is a real threat in their work and cases among sex workers go largely unreported. Brothel owners and the police exploit and harass them. Members of sex workers collectives believe that prostitution should be legalized in order to address their rights to a regular income, and social security benefits as regular sex workers

· From a women’s NGO worker: “Violence and conflicts makes us poor. Landmines means less agricultural land for poor people. Lawyers become rich in land conflicts, and the poor become landless. 'If we have conflict, we become poorer and poorer day by day. Conflicts should be settled among ourselves and no more go to the courts. Put money in agriculture rather than spend money to buy guns; soldiers carrying guns are unproductive, only protect the power of the already powerful.”

· From indigenous highlander women leaders: “We no longer have control over the forest resources in our village. Although we know that the government owns the forest and land, the government should first discuss with local communities regarding forest concessions.” Indigenous women totally relies in the land and the forest; “her market is in the forest.” “I dare to request, because when I attended meeting, the Governor says villagers (especially women) can give opinion. I was initially afraid of arguing (my case), but I dared to argue because the government said I can do so.” “‘If we lose our land and forest, we cannot compete with others in the marketplace.”

(See also Attachment B for workshop discussion results on poverty reduction among Cambodian NGO leaders in Battambang, Banteay Meanchey, Kompong Thom and Rattanakiri, and indigenous hilltribe leaders in Rattanakiri.)

The I-PRSP will build upon existing poverty reduction strategies and social and economic policies, including First Socio-Economic Development Plan 1996-2000 (SEDPI). The SEDPI emphasized rural development and stressed the need to balance this goal with the development of major urban growth poles. The SEDPI target allocation for pubic investment expenditures was 65% to go to projects in rural areas and 35% to urban areas. The implementation, however, turned out to be the opposite -- 65% of investments went to urban areas, while only 35% went to rural areas. Moreover, past efforts to reduce poverty have focused mainly on stand-alone projects that neglect the broader policy and institutional environment of poverty reduction.

This review would have better served its purpose had it given clear lessons from past experience, particularly with the implementation of the SEDPI. Why have more public investments gone to the urban areas rather than to rural areas as originally targeted? How can this be avoided in future? What kinds of ‘stand-alone’ projects did not contribute significantly to poverty reduction? These are but some of the questions that should be addressed in this section.

"The Royal Government's strategic motto is "Poverty reduction through high economic growth over the long term by ensuring environmental sustainability and social equity." The main elements are:

Consolidation of peace, stability and social order

Investment promotion

Domestic resource mobilization

Allocating investment to priority sectors and improving agriculture

Building institutional capacity and strengthening good governance

Integration of the Cambodian economy into the region and the world

Human resource development

Consolidation of the partnership with the donor community and civil society."[2]

The motto of high economic growth, environmental sustainability and social equity sounds good in theory, but in practice is a very difficult task, particularly in cases where social and economic policy objectives contradict each other. This occurs, for instance in cases where high economic growth necessitates the construction of environmentally-polluting industries, or community-displacing infrastructure, as in power dams or highway construction. In the particular case of Cambodia, an emphasis on high economic growth may not be desirable as long as adequate social (e.g. minimum wage legislation, social security) and environmental (e.g., pollution thresholds) regulations are still absent in the country’s legal and institutional framework.

The I-PRSP will remain a ‘wish list’ of what needs to be done as long as there is no clear prioritization of where the balance lies between macro-economic and social and environmental policies. Moreover, within the context of limited resources, the I-PRSP is not clear what proportion of resources will go to ‘growth’ programs, ‘environment’ programs and ‘social equity’ programs such as land reform.

The I-PRSP's framework linking poverty diagnostics to government policies (below) seems to present a coherent framework of some of the factors that cause poverty, and the policy recommendations to address the causes. The framework, however, glosses over the importance of structural causes of poverty which are closely linked to who and why certain groups of individuals continue to have access and control over land and other productive resources in Cambodia, to the detriment of the majority's poor population. This, in turn, brings about issues of 'powerlessnessness' and 'voicelessness' that have been referred to in the I-PRSP's many dimensions of poverty.

Empowering the poor and voiceless, moreover, should direct a set of policy actions that distributes Cambodia's productive assets equitably but also builds upon the social networks and institutions of the poor. This is an area in which many members of the nascent civil society in Cambodia have actively been promoting in recent years -- as, for instance, in such activities as organizing poor people to help themselves through village-based self-help schemes. It is important, then, to recognize these initiatives from NGOs and civil society groups as part of current efforts to combat poverty in Cambodia. Moreover, such initiatives should also be provided an enabling environment in order to prosper and contribute towards poverty reduction and national development.

"Growth is the most powerful weapon in the fight for higher living standards. Faster growth will require policies that encourage macroeconomic stability, shift resources to more efficient sectors, and integrate with the global economy."

Experiences in other countries show that the PRSP is not substantially different from old structural adjustment packages (SAPs) which the WB and IMF required borrowing countries to undergo before loans and grants were provided by these institutions. Moreover, the macroeconomic framework is still determined prior to the actual PRSP process.

In Cambodia, an IMF Poverty Reduction and Growth Facility (PRGF) was approved in October 1999.[3] At the same time, the IMF also approved a 3-year arrangement under the Enhanced Structural Adjustment Facility (ESAF). The ESAF provided support for Cambodia’s economic program for 1999-2002; previous arrangements covered the period 1994-1997. According to a Cambodian economist who has had experience working as adviser at the MEF, the macroeconomic policy conditions set out in the I-PRSP are similar to those contained in the ESAF.[4]

There have been two decades of debate, popular protest, and resistance to some aspects of WB and IMF macroeconomic objectives and structural adjustment policies because they are often perceived as inconsistent with poverty reduction[5]. These policies are perceived as: undermining government subsidies and social safety nets; favoring export industries over domestic production, the private sector over the public sector, large farmers over small farmers, foreign debt servicing over domestic citizen needs, and economic growth over employment generation. Thus an assessment of the poverty impact of those policies is all the more essential.

Civil society organizations recognize that economic growth is desirable and is necessary for development. High growth, however, comes with huge social and environmental costs, and exposes the economy to vulnerabilities. Moreover, high growth does not necessarily address the issue of inequality, and even push some sectors further into poverty.[6]

"The benefits of growth for the poor may be eroded if the distribution of income worsens. Even with economic growth there is still room for policies that target interventions to improve health and education outcomes. At the top of the list are female education to ensure gender equality, safe water and sanitation, child immunization, as well as social safety nets to protect the most vulnerable. Attention is also needed to the social structures and institutions (or ‘social capital’) which affect development."

A ‘social safety net’ approach to poverty reduction is tantamount to saying that, in the short, medium or more probably longer term, it is acceptable to have already poor and vulnerable groups become even poorer and more vulnerable. ‘Social safety nets’ are put in place to protect ‘losers’ along the way. In most cases, however, these ‘nets’ are far too little or too late to make a difference. Moreover, the RGC’s poverty reduction strategy should not shift the burden of ‘social safety nets’ to the poor’s already fragile social structures and networks. Put another way, NGOs and other civil society groups should not be made to take up the slack of government’s inability to provide resources directly to promote the well-being of vulnerable groups. The strength of NGOs lies not so much in providing funding for development costs, as in the ability to mobilize people, particularly at the grassroots level, into organized group action for self-reliance and self-development.

"Cambodia needs massive influx of investment during the next few years to generate economic energy and accelerate the speed for the take-off..... Integration of the Cambodian economy into the region and the world with the aim to increase the economies of scale by expanding the markets, improve factor mobility and reduce the prices of imported and exported products. This will also increase the attractiveness of Cambodia to investors, promote higher factor productivity, and create and develop comparative advantages of the nation through the participation in international competition and specialization."

Globalization and decreasing barriers to trade and investment flows has had several consequences that include: pressure on national governments to weaken and reduce their national standards; a “race to the bottom” in areas like labor and environmental standards; and eroding social safety nets, with especially negative effects on women. In the current Cambodian context, this economic policy translates into, among others, cheaper and more ‘competitive’ wages for industrial workers and cheaper agricultural imports from Thailand and other neighboring countries to the detriment of Cambodian farmers. Clearly, in light of these negative effects, the RGC immediately needs to undertake social and environmental impact assessments of the policy of economic integration into regional and global markets even before more trade and investment liberalization takes place. Moreover, there needs to be a clearer articulation on what Cambodian gains and how these gains can be maximized from current regional and sub-regional cooperation and preferential trade arrangements.

"Though well-targeted programs for rural areas could have quick impact on the rural population, poverty reduction strategy should not be overtly reliant on the development of agricultural sector, given poor performance of the sector in the past. Industrial and service sector development could become a powerful locomotive to pull Cambodia out of the shackles of poverty... The RGC has adopted the following industrial development policies: Export-oriented, natural-resource-based, labor-intensive and tourism-related industries."[7]

This policy statement sounds more like punishing poor Cambodian farmers for being poor. Since agriculture has been deemed an ‘inefficient’ sector, i.e., it has not delivered as many percentage points towards economic growth as with other sectors in industry and services, then the government might be better off no longer putting more resources into this sector. This ‘inefficient’ verdict on agriculture sector may be inaccurate since the I-PRSP acknowledges that, among others, the mandated 65% resource allocation to the rural areas did not materialize in the SEDPI; instead only 35% was allotted. Hence, it was not the fault of poor agricultural farmers that they remained ‘inefficient’; rather, policy was not implemented in their favor.

Moreover, not relying heavily on agricultural development is a misplaced strategy. The I-PRSP itself recognizes that poverty in Cambodia is largely rural and agriculture is the main occupation of the poor:

· Rural population, especially for whom agriculture is the primary source of income, account for 90% of the poor.

· Women comprise 65% of the rural population, and 80% of them are in agriculture.

· In 1999, only 11% of employed Cambodians were in wage employment in the rural areas.

Focusing resource allocation on the rural areas will have the most impact on poverty reduction, although this will not result in rapid economic growth. Where, then, will lie the RGC’s poverty reduction thrusts? Is high GDP growth more important than rapid rural poverty reduction?

The RGC should review current efforts at modernizing agriculture which, on one hand, calls for market-based reforms that will in effect reduce state subsidies to agriculture while acknowledging that the poor by themselves alone lack access to resources (e.g. land, credit, agricultural extension and technical support) that are needed for higher yields and greater productivity.

Moreover, rural poverty is the one of the major causes of the massive influx of the poor from the rural countryside to urban areas in search of work and livelihood opportunities. This rural-urban migration, in turn, has resulted in Cambodia’s urban blight -- rise of slum communities that have no adequate access to basic services (e.g., water, sanitation, electricity), increase in the number of trafficked and prostituted women, over-supply of labor that depresses wages, etc.

Cambodia’s industrial development policy as articulated in the I-PRSP will put more pressure on natural resources (e.g. forests, fisheries) and the environment. This policy, however, is silent on how it will affect the majority of rural populations who depend on these same natural resources for food and livelihoods. For instance, the privatization of common access resources, such as the leasing of fishing lots in support of industrial development, has resulted in increasing lack of access by poor fishers and their families of cheap sources of fish and protein needed as caloric requirements of poverty reduction.

The view emerging from the I-PRSP is that of natural resources (land, fisheries, forests) being considered as primarily an economic resource for exploitation for export markets, rather than as a major source of food and sustainable livelihoods, as well as an integral part of social networks of poor rural communities. The crucial contribution of common property natural resources to the livelihoods of the poor is grossly undervalued.

"The RGC has proposed a strategy that is based on the bottom-up, integrated, participatory, decentralized rural development. The objectives are to expand the number of Village Development Committees (VDCs) ... to cover up to 69 percent of all villages by the end of 2000. This will allow active community participation in grassroots institutions and increase the ownership of development projects, by shifting decision-making and accountability closer to individuals, households and communities."

This is a welcome development as NGOs have long advocated not only for allocating more resources to rural and isolated regions of Cambodia, but also for promoting public participation in state affairs in a bottom-up and integrated manner. Legislation on a more transparent, accountable and financially independent commune administration should be passed as soon as possible. This should ensure village participation and representation, including those of women.

NGOs are concerned, however, that the proposed commune electoral system will not foster sufficient downward accountability in Cambodia’s current political and cultural context. International experience shows that decentralization enables better poverty reduction only if sufficient attention is given to downward accountability, participation, and checks and balances to ensure ‘good’ local governance.

Embarking on land reform

"Land reform will focus on land distribution, land management and land administration that consists of: development of a national land policy; improved management of the national land stock; commencement of systematic land titling; tax reform; establishment of a legal framework to enforce property rights; the establishment of provincial, municipal and national master plans and zoning; development of rural housing."

Land reform is a potentially significant strategy towards social equity and redistribution of wealth in Cambodia, and hence should be given top priority in the poverty reduction strategy. The I-PRSP, however, does not acknowledge the extensive research that has already been done on landlessness.[8] Eight in ten Cambodians live in rural areas but one family in six has never had land or has recently lost their land. The RGC still owns 80 percent of the country but there has been no demarcation and very low investment in management of public land. Land speculation is rife in the cities and valuable state property is being sold for private gain. Property rights in less than 15 percent of privately owned land in Cambodia are formally registered or protected by law, resulting in land disputes. The courts are unable to adjudicate and provincial authorities do not have the capacity to conciliate land disputes. In the immediate term, NGOs urge the RGC to finalize the draft Land Law and related subdecrees that should increase sustainable production, strengthen social cohesion and protect the rights of the poor.

Ensuring the poor's access to natural resources. "Ensure sound natural resource management and address poverty by widening the poor’s access to forest, fisheries and water resources."

NGOs welcome this positive policy statement that ensures access of the poor to forest, fisheries and water resources. In the concrete, this should be translated into promotion of community-based management of common property natural resources for sustainable livelihoods of poor people. In the forestry sector, an evaluation of industrial concession managements in Cambodia should be conducted to assess whether the industrial utilization of Cambodia's forest resources is compatible with the goals of equitable social and economic development. Forest concessions with a record of illegal activity or which impact negatively on the rights of indigenous groups should be terminated. There should also be a crackdown on illegal forest activities should target large-scale operations with a view to addressing the culture of impunity. Appropriate forest and land laws and sub-decrees for community forestry and concession management should be enacted through a participatory process and with greater consideration of local communities, so as to ensure sustainable access of communities to forest resources.

The section of the IPRSP policy matrix on ‘Land and Forests’ should also cover fisheries reforms.

The right of local communities living nearby fishing areas to fish for subsistence should be legally protected. Local communities, NGOs and concerned agencies and institutions should be involved in a consultative process to draft a more realistic fishery law. Illegal fishing and the militarization of fishery resources should be stopped, and the harmful impacts of commercial fishing on local communities addressed.

Integrating the Governance Action Plan (GAP) into the RGC’s poverty reduction strategy should be a top priority, as has been identified by NGOs and civil society representatives at the October National Workshop. In its current form, the I-PRSP only contains bits and pieces of governance issues (e.g. corruption and the rule of law) rather than better integrating governance issues into the poverty reduction strategy. Adherence to the rule of law is a fundamental precondition for the realization of development. Anti-corruption legislation should be passed as soon as possible. Other public sector reform measures (e.g. upgrading performance-based salary scales, reform of the judiciary, etc) should also be implemented. As in the words of a farmer leader, “I cannot envision rural development without the necessary reforms in public administration first taking place.”

Health and education. "The RGC will increase spending on health and education and fully implement the Priority Action Program (PAP) for health and education.... In health sector, introduce cost-sharing partnerships with local communities through user fees and expand access and equity of services for the poor through a well-monitored system of user fee exemptions... The MoEYS will introduce user fees at the university level in 2000-2001 to formalize currently widespread unofficial fees and contribution. The MoEYS will not adopt user fees at primary and secondary levels as it will exclude an increasing number of poor children."

Increasing resource allocation from the military to the social sectors (education and health) have long been advocated by NGOs concerned with reducing the incidence of poverty in Cambodia. However, this policy seems to be inconsistent with the policy to implement user fees in the health sector. User fee schemes with ineffective exemptions result in even reduced access to health care by the poor who cannot afford to pay. Hence, user fees in the health sector should be reviewed. Moreover, financial transparency and corruption issues should be addressed particularly with respect to health and education disbursements from the Ministry of Economy and Finance (MEF), ‘under the table payments’, and the procurement of drugs by a private monopoly provider in the health sector.

Although the I-PRSP contains many references to gender equality and closing the gender gap, it does not have a clear policy articulation on how women can be integrated into development efforts and can contribute to poverty reduction. Moreover, although problems such as violence against women and trafficking are recognized in the I-PRSP, it does not provide concrete solutions in terms of legislation or relevant policy measures to address these problems. The same may be said of plight of children and their rights. For instance, the I-PRSP identifies street children as among the most vulnerable groups in Cambodia, and yet, adequate resources have not been allocated to address their plight. Furthermore, the I-PRSP is largely silent on the issue of children’s rights. There are no policy directives on a compulsory national birth registration, adoption, or a national juvenile justice system.

Disaster management

The I-PRSP recognizes that weather conditions, floods and droughts can have adverse impacts on food security and the lives of particularly vulnerable groups. An appropriate response is creating security through safety net programs. The I-PRSP, however, is silent on the issue of disaster management despite the fact that frequent disasters such as floods regularly impoverish large sections of the Cambodian population. A clear strategy needs to be articulated for disaster preparedness, relief, mitigation and rehabilitation. Mechanisms for coordination, monitoring and review need to be firmly in place. NGOs/CSOs can be effective partners in such a strategy given their close contact with rural communities affected by disasters.

Suggestions on how to incorporate priority concerns identified by NGOs/CSOs into the text of the I-PRSP[9]

The following comments are based on the final (8^th) draft for submission to Cabinet, dated October 2000.

In the third paragraph of the Foreword, the third sentence reads "Moreover, a consultative process was launched with active participation of donor community and Non-Governmental Organizations (NGOs) on 25 July 2000." However, NGOs are not aware of this launching and were not sent a copy of the I-PRSP until August.

§ We would like to suggest that the words "and Non-Governmental Organizations (NGOs)" be omitted from the above sentence, and that a subsequent sentence be added as follows:

"NGOs held extensive discussions on the I-PRSP in September-October, with technical assistance from UNDP."

§ At the end of the section on "Relationships with Donors and the Move to Partnership", we would like to suggest that an additional sentence be added to the end of paragraph 3.61 as follows:

"In September-October, the NGO Forum on Cambodia, with technical assistance from UNDP, led discussions on NGO/civil society concerns regarding poverty reduction."

§ At the end of the section on "Capacity Building and Poverty Monitoring", after paragraph 4.2, we would like to suggest that an additional paragraph be added as follows:

"Recommendations from NGOs/civil society on building blocks towards a participatory poverty monitoring system shall be given due consideration, including broad agreements on a common poverty monitoring indicators as well as mechanisms of RGC-NGO/civil society cooperation at national and subnational levels which may be used as venues for discussion and reporting-back on poverty reduction."

§ At the end of the section on "Arrangements for Full PRSP", after paragraph 5.5, we would like to suggest that an additional sentence to be added as follows:

"The process will allow active participation of the local communities and authorities in the preparation of the full PRSP. These include: raising more awareness about the PRSP, learning more about government poverty reduction policies and programs/projects; creating more venues for discussion/feedback and cooperation between the RGC and NGOs/civil society on the poverty reduction strategy; and strengthening the capacities of NGOs/CSOs to monitor the mplementation of the poverty reduction strategy."

The recent National NGO/CSO workshop identified a number of priority areas for poverty reduction. Many of these priorities are already reflected in the I-PRSP. The two main cross-cutting priorities identified to improve poverty reduction efforts were: 1) reform the public sector, and 2) promote rural development.

The I-PRSP strongly reflects this cross-cutting priority, especially with regard to finalizing and implementing the Governance Action Plan (GAP). The Council of Ministers has already received feedback from NGOs regarding the details of the GAP, which NGOs hope will be given due consideration. We would like to suggest the following additions to the I-PRSP:

§ In the Annex 1 of the I-PRSP, the section of the Policy Matrix entitled "IV.a. Measures to reduce corruption" could add the following:

§ The section of the Policy Matrix entitled "V.a. Civil service reform" could add the following:

"Adopt and implement the action plan for civil service reform, including creation of a realistic government salary system, linked to an impartial performance-based scale."

This cross-cutting priority is most strongly reflected in the latest version of the I-PRSP. Earlier versions were less supportive of a focus on rural development and agriculture, as reflected in the statement (now omitted), which said that the "...poverty reduction strategy should not be overly reliant on the development of the agriculture sector, given poor performance of the sector in the past." It needs to be recognised that focusing resource allocation on rural areas will have the most impact on poverty reduction in Cambodia, even if it be true that faster economic growth would be obtained through focus on other sectors. The strong emphasis on "faster growth" which is still contained in the document should be moderated to suggest that an appropriate rate of economic growth is needed which balances the need for economic growth with other poverty-related priorities (See "Macro-economic policies" below).

"Attachment D" of the NGO Report provides details of NGO/CSO recommendations on key sectoral issues, based on previous NGO documents and consultations. The National NGO/CSO Workshop suggested additions and corrections to this list, and ranked the most important recommendations. The highest ranked recommendations are summarised in Section III (pages 15-16) of the Main Report. Many of those recommendations broadly match the current contents of the I-PRSP. The following additions to the I-PRSP are suggested:

Add to Paragraph 3.32 of the section "Advancing Rural Development and Decentralisation":

"The councils will have a greater say in the development of their regions. The RGC is aware that the international experience regarding the impact of decentralisation on poverty outcomes is mixed[10], and that poverty reduction will require close attention to systems of accountability, especially the 'downward' accountability of commune councils to their constituents."

Add to the end of Paragraph 3.26 of the section "Promoting Sustainable Development of Agriculture":

"Food security and health in the agriculture sector will be enhanced by i) introducing and effectively enforcing laws to protect the health of small farmers and minimise environmental destruction, ii) promoting public education programs on pesticides hazards, alternative pest control and integrated pest management, and iii) increasing allocation to research and extension on ecological farming."

"Landlessness is a significant cause and important indicator of poverty in Cambodia. [11] Eight in ten Cambodians live in rural areas but one family in six has never had land or has recently lost their land. The RGC still owns 80 percent of the country but there has been no demarcation and very low investment in management of public land. Land speculation is rife in the cities and valuable state property is being sold for private gain. Property rights in less than 15 percent of privately owned land in Cambodia are formally registered or protected by law, resulting in land disputes. The courts are unable to adjudicate and provincial authorities do not have the capacity to conciliate land disputes."

Add to the end of paragraph 3.28 under the section "Promoting Sustainable Development of Agriculture"

"It is realised, however, that the most significant and sustainable contribution that forest resources can bring to poverty reduction is the value of timber and non-timber products to local communities. The impact of concessions on community access to these products has not yet been studied, and should be the subject of an independent and transparent evaluation."

Change the heading "Land and Forestry" in the Policy Matrix to "Land, Forestry and Fisheries" and add the following item:

"c. Fisheries Develop new fisheries legislation through a participatory process, to ensure sustainable management of fisheries resources and access of the poor to aquatic resources. 2000-2002."

Table 3.1 "Linking Poverty Diagnostics to Government Policies" recognises "Vulnerability" due to "Increased violence against women - rape, domestic violence, trafficking of women and children", but list no corresponding government policy to deal with these problems. The corresponding "Government Policy" should be:

This should be complemented by a new paragraph under the section "C. CREATING SECURITY" as follows:

a) The passage of laws dealing with rape, sexual harassment, domestic violence, prostitution and trafficking, followed up by wide dissemination of information about these laws and steps to ensure proper enforcment.

b) Education and public awareness building about all forms of violence against women, including education of military and police on issues of domestic violence.

Children in vulnerable circumstances would be better protected through establishment of a national juvenile justice system, compulsory national birth registration and introduction of a local child adoption policy and monitoring system.

Moreover, these policy actions should also be reflected as additional policies in the 'Annex (Policy Matrix)'.

Despite the obvious importance of good disaster management for immediate alleviation of poverty following disasters (Cambodia's recent floods are a good example), this topic is not yet included in the I-PRSP. Table 3.1 should include the following "Government Policy" under the heading "Creating Security":

This should be complemented by a new paragraph under the section "C. CREATING SECURITY" as follows:

In order to be prepared for external shocks such as floods, droughts, and other disasters, the RGC shall elaborate its plans for disaster preparedness, relief, mitigation and rehabilitation. Mechanisms for coordination, monitoring and review shall be developed."

Appendix 3: NGO Comments on Contents of the I-PRSP

NGO COMMENTS ON CONTENTS OF THE I-PRSP

Embarking on land reform

Disaster management