November 2024: update for our stakeholders

Allegation 1: Hundreds of people have been forcibly displaced from in and around the Samkos REDD+ project this year. This included burning of structures identified as homes, seizure and confiscation of property, and physical violence. Some people say they are now suffering from food insecurity. Some who submitted grievances through the available Facebook page did not appear to receive responses. In one example, officials in Anlong Reab commune in Pursat province identified more than 300 families with long-term ties to the area who reported losing farms they had relied on. Besides those families, many of the people displaced from areas in and around the Samkos REDD+ project throughout these provinces have longstanding ties to the land according to village leaders, commune officials and the Battambang Provincial Department of Environment. Project documents submitted to Verra said there will be no relocations or disruptions to livelihood associated with this project.

These allegations are entirely misdirected.

No Wildlife Alliance staff were involved in these alleged activities, which were in no way under the jurisdiction or responsibility of the REDD+ project.

The facts: This allegation refers to recent enforcement actions reportedly undertaken by the Pursat Provincial Authority under the direction of the Prime Minister’s National Committee, in response to significant illegal protected forest encroachment which is happening as people travel along a new road that is under construction in this area. To the best of our knowledge, evictions were conducted in conformance with Cambodian law and no one lost access to legally recognized farmland, but this would be a question best answered by the Cambodian authorities.

Suffice to say: Wildlife Alliance strongly condemns all abuses of human rights and extra-legal evictions.

Within Allegation 1, it says: “Project documents submitted to Verra said there will be no relocations or disruptions to livelihood associated with this project.”

This statement is correct. In fact, please see our response to Allegation 3 part 1 below for details of the Samkos REDD+ Project’s ongoing efforts to strengthen communities’ land rights.

Please also note that before we knew about these allegations, Wildlife Alliance decided to halt registration and credit issuance of the Samkos REDD+ Project under VM0009 and withdraw the verification audit that was underway. Wildlife Alliance intends to reinitiate the audit process under a new methodology (i.e. Verra’s new Consolidated Methodology VM0048 once it is launched).

Within Allegation 1, it says: “Some who submitted grievances through the available Facebook page did not appear to receive responses.”

This is incorrect. There have been no grievances recorded via the Samkos REDD+ Project Facebook page to date.

For complete transparency: We have received 22 grievances (which also include requests for help, natural resource crime reporting, and recommendations for the project) regarding the Samkos REDD+ Project, two of which were submitted incorrectly through the Southern Cardamom REDD+ Project’s Facebook page.

When we became aware of these grievances, one in June and another one in November 2024, Wildlife Alliance reached out to each individual to request more information so we could resolve the issues through our established processes (described below). As yet, neither individual has provided the necessary information and both cases remain open. We will resolve them as soon as possible.

With regards to our grievance process:

Each grievance received is treated and responded to in strict compliance with the Project’s Feedback and Grievance Redress Mechanism Policy. Grievances can be submitted via: community focal points, project staff, the Project Hotline, during meetings, the Project’s social media platforms, community grievances boxes, or posted to Wildlife Alliance’s offices. After a grievance has been submitted it is logged by the grievance clerk, and depending on the nature of the grievance, channelled to the respective project expert. All grievances receive a response – addressed either to the individual complainant or to the relevant community when grievances are submitted anonymously – within 30 days. Strict confidentiality is maintained.

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Allegation 2: Farmers in Kampong Lpov commune (ខេត្តបាត្់ដំបង / ស្រុករំឡូ ត្ / ឃ ំកំពង់ខពៅ) on the border of the Samkos REDD+ project with decades-long ties to the land according to local and provincial authorities are being displaced as part of a Ministry of Environment and Wildlife Alliance treeplanting initiative. Some, but not all, may be eligible for compensation in the future though they are already unable to farm on their land, which farmers and local authorities said they relied on for their livelihoods. Project documents submitted to Verra have stated “the Project does not require involuntary removal or relocation of communities or any activities important for their livelihood and culture.” (i.e. Samkos REDD+ project 1st monitoring report p. 27)

Within Allegation 2, it says: “the Project does not require involuntary removal or relocation of communities or any activities important for their livelihood and culture.”

This statement is correct.

The rest of Allegation 2 is entirely non-factual.

Wildlife Alliance has no involvement in tree planting activities in Kampong Lpov, and these activities are not associated with the planning or implementation of the REDD+ Project.

The facts: As part of the national campaign Circular strategy – Green, Clean, Sustainable launched by the Ministry of Environment (that aims to plant 1 million trees a year), local authorities and Provincial Departments of Environment (PDoEs) were encouraged to identify areas on state land for forest restoration.

Wildlife Alliance donated a total of 197,000 saplings to the Ministry of Environment, Veal Veng District Authority, and the PDoEs of Koh Kong, Kampong Speu, and Pursat. No saplings were donated by Wildlife Alliance to Battambang PDoE (Kampong Lpov commune is located in Battambang province).

Wildlife Alliance was not involved in identifying locations for planting saplings and has no knowledge of any farmers being blocked from land in Kampong Lpov. Indeed, to the best of our knowledge all the sites identified by the Ministry of Environment, Pursat Provincial Authority, and the relevant PDoEs to plant trees are on land owned by the Cambodian government.

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Allegation 3 (part 1): The boundaries for the Samkos REDD+ project overlap with a significant amount (more than 40%) of previously mapped traditional lands of the ethnic minority Por group, an Indigenous community living in the village of Phnom Rei located in Battambang province. (ខេត្តបាត្់ដំបង / ស្រុករំឡូត្ / ឃ ំតាខតាក / ភ្នំរ ៉ៃ).

Community lands were delineated by Cambodian legislation, which had nothing to do with Wildlife Alliance or the Samkos REDD+ project.

The facts: The Phnom Samkos Wildlife Sanctuary (the Protected Area in which part of the Samkos REDD+ Project is based) underwent several rounds of zoning consultations, with the latest zonation consultation workshop conducted on 10 February 2022. During the workshops, the community zones were discussed and consulted upon, commune by commune, including the community area of Phnom Rei. The consultation process was led by the Ministry of Environment, and the community areas in the Phnom Samkos Wildlife Sanctuary were delineated by Cambodian legislation (Order 01 and Sub-decree 245), which had nothing to do with Wildlife Alliance nor the Samkos REDD+ Project.

As for the project: Wildlife Alliance acknowledges and respects the land rights of the Por communities. As such, the Samkos REDD+ Project is helping to identify, inventory, and map the Por Indigenous Peoples’ lands, and bring any claims of land to the immediate attention of the relevant authorities.

Wildlife Alliance does not have the authority to grant claimed land but will do all we can to help ensure claims are resolved fairly. For example, we conducted Participatory Village Sketch Mapping as part of the Samkos REDD+ Project’s consultation for 28 villages and 14 sub-villages located near but outside the Project Area as part of the Samkos REDD+ Project’s ongoing consultation with communities.

There are three main aims of the Sketch Mapping:

1. make the community aware of the Samkos REDD+ Project Area boundary.
2. check with the community to ensure that community lands do not overlap with the Project Area.
3. bring to the attention of the relevant authorities land claims found to be overlapping with the Project Area in order to seek claims resolution (ultimately helping communities to strengthen their land tenure and rights).

The process consists of two main steps:

Step 1 (already completed) – Villagers were asked to define the village boundary by drawing it on a printout map. This map is further translated into a GIS map with the assistance of our GIS Specialist, to see if the village boundary as understood by the villagers is overlapping with the Project Area. In this process satellite imagery is also presented and displayed to villagers so that they clearly see the forest cover of the claimed area. The Sketch Mapping Team has no authority to define the village boundary, nor to make any decision on land allocation. The Sketch Mapping is simply a process of making the community aware of the project boundary and assisting the communities to map their village boundary.

Step 2 – In cases when potential overlaps were detected during Step 1, ‘ground truthing’ is conducted together with villagers, local authorities, PDoEs and other relevant stakeholders. This step intends to check the validity of a claim and to document it, so that the claim can be brought to the attention of the Provincial State Land Management Committee for resolution (the body with the authority to approve or deny a land claim).

During the Sketch Mapping land conflicts between Por Indigenous People and Khmer villagers were revealed, due to significant recent immigration to the area. It was also revealed that many Por, including the Por Chief, had sold their land to speculators.

This is a highly complex situation, but we continue our work with the Por Indigenous community of Phnom Rei and the other stakeholders detailed above – to help the community progress through the communal land registration process and obtain a communal land title (the strongest possible legal recognition of their lands).

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Allegation 3 (part 2): Villagers in Phnom Rei reported being displaced from their farmlands, detained, having their huts burned, their crops trampled and signs on their farms warning of imprisonment in recent months.

This is a gross mischaracterization of events.

The facts: Firstly, please see the previous answer for details of how the government delineated community lands and Wildlife Alliance’s efforts to support communities’ land rights and the resolution of land claims.

Secondly, as we’ve already made clear, Wildlife Alliance has no authority to enforce the law. We provide technical assistance to the Cardamoms Forest Protection Program (CFPP) which is a cross‐departmental program led by Judicial Police Officers (JPO) from the Ministry of Environment, supported by gendarmes of the Royal Gendarmerie Khmer. Law enforcement is therefore carried out by government officials with the mandate to enforce the law against forest crimes.

CFPP patrol units started to take action against new illegal land encroachments and forest destruction inside the Protected Area near Phnom Rei in early 2023. However, CFPP records show that no such cases involved burned and demolished huts, trampled crops, or being detained by CFPP patrols but again – this is a question for the Cambodian authorities.

As to the “signs” referred to in this allegation: one of the duties of CFPP patrol units, after recording illegal land encroachment, is to install a rectangular sign saying “this forest belongs to the state and illegal land encroachment is punishable up to 10 years of imprisonment”. These signs serve as a reminder of the relevant law (Article 850 of the Code on Environment and Natural Resources) and aim to deter further violations of it.

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Allegation 3 (part 3): The German development agency GIZ confirmed to me they helped the villagers of Phnom Rei prepare a map of their lands, including existing farmlands, around 2012 as part of the village’s preparation for an Indigenous Communal Land Title.

This map does not reflect the official position of the Cambodian government.

The facts: During the 2023 participatory Sketch Mapping (described above) the map mentioned in the allegation was shown to Wildlife Alliance for the first time. We had not previously seen the map or been aware of its existence. We are also not aware that it was ever used to make an official land claim or that it was ever recognised by the relevant authorities.

The map is not dated and makes no mention of the institution that provided it. In particular, we note that it has no endorsement stamp, signature of local authorities, provincial authorities, Ministries of Environment or Land Management, or any other related government institution mandated to manage protected areas and state lands. To the best of our knowledge therefore, this map does not reflect the official position of the Cambodian government.

Moreover, we have serious concerns as to the map’s accuracy having consulted satellite imagery which shows no evidence of occupancy in the area before 2019.

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Allegation 3 (part 4): Por leaders stated they are now being pressured by the Samkos REDD+ project to withdraw overlapping land claims. Battambang Provincial Department of Environment states that Wildlife Alliance told him not to grant the villagers of Phnom Rei ownership of their land claims overlapping with the Samkos REDD+ project, whose boundaries Wildlife Alliance led efforts to map.

Neither Wildlife Alliance nor any member of Samkos REDD+ Project staff has ever pressured any community member to withdraw a land claim, or pressured any official to deny such a claim.

We repeat that the community areas were determined by legislation through a consultation process that was led by the Ministry of Environment and had nothing to do with Wildlife Alliance or the REDD+ Project. Meanwhile, the project is working hard to strengthen the land rights of communities and seek the fair resolution of land claims – as detailed in our response to Allegation 3 part 1.

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Allegation 4: Chong farmers in the Areng Valley continue to be arrested and have also said they continue to have their property destroyed by Wildlife Alliance ranger patrols. When a villager whose property was destroyed raised concerns about these issues at an FPIC meeting in Thma Doun Pov commune in June 2024, Wildlife Alliance staff denied ranger patrols had ever burned or confiscated villagers’ property.

These extremely serious allegations are non-factual and misleading.

The facts: Concerning the FPIC meeting in Thmar Doun Pov in June 2024, there were two concerns raised on these issues:

1. A woman said that when she arrived six years ago from another province (Kampong Cham), she had bought a piece of forest land which is outside the community area. She claimed that she could not cultivate the land because the authorities told her that her land is forestland and she is not allowed to clear the trees. She was invited to provide any information to support her claim – but could not remember where the land was, or provide any evidence of ownership. Wildlife Alliance staff shared their contact details and should we receive the necessary information, we will of course alert the relevant authorities to the claim.
2. Another woman whose land is located inside the community area close to the project boundary, asked if she could cultivate and clear the land. Wildlife Alliance’s FPIC team responded that she could do so if her land is indeed inside the community area, but advised her to confirm the location with the Chhay Areng Ranger Station first.

It is important to note that these were conversations, and no supporting documents were provided to Wildlife Alliance.

Wildlife Alliance is not aware of destruction or confiscation of any property in Chhay Areng. We have not been presented with any specific evidence to the contrary. If the author of these allegations has any such evidence, it should be presented to Wildlife Alliance so that we can properly investigate and respond to it.

Without such evidence, it would be grossly irresponsible to publish this claim.

As described already, there is no such thing as “Wildlife Alliance ranger patrols.” The “rangers” referred to are government employees led by the Judicial Police Officers (JPO) from the Ministry of Environment, supported by gendarmes of the Royal Gendarmerie Khmer. Wildlife Alliance’s role in each CFPP station is to organize logistics, maintain the equipment, take rangers to the hospital when needed, manage food supplies, and monitor patrols to ensure good governance, compliance with the law, and respect of human rights.

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Allegation 5 (part 1): The FPIC meetings at Thma Doun Pov, Pralay and Chumnoab communes, which I attended, appeared to contain misinformation and coercion. In one example, a local authority told community members right before they voted: “This project is a project to raise funds for local development… It is not a forest protection project.” He also implied Chong and local villagers would not be able to receive ownership of their farmlands if they did not vote in support of the project.

This is a gross mischaracterization of events.

Wildlife Alliance does not misinform or coerce members of the community during Free Prior and Informed Consent (FPIC) meetings, or willingly allow them to be misinformed or coerced. We emphasise that clear and accurate information was provided to community members about the project at this most recent round of FPIC meetings, and the seven rounds prior to it. We cannot, of course, control the opinions and comments that are raised independently by others in FPIC meetings.

The facts: Wildlife Alliance undertakes FPIC consultations with all communities in the Project Zone on an ongoing basis, and a formal FPIC process is conducted annually. This is a continuous process. From the start, a substantial majority of community household representatives has supported the Southern Cardamom REDD+ Project, as confirmed by independent third-party audits. The number of villagers supporting the project has risen substantially, with over 93% of household representatives expressing support in the latest round of FPIC conducted from June 4 to September 5, 2024. In the communes mentioned above, the results were: 81% support in Pralay Commune; 82% in Chumnoab Commune, and 88% in Thma Dan Pov Commune.

We understand from our correspondence with the journalist who is apparently behind these allegations, that the local authority referred to is the Chief of Pralay Commune. Wildlife Alliance obviously cannot speak to the Chief’s intention in making his reported comments, but we believe he was trying to convey the message that the revenue generated by the sale of carbon credits is critical to the villagers receiving ongoing technical and financial support with regard to land titling and livelihood activities. He is correct in this message, and to present this reported comment as “coercion” is both absurd and disingenuous.

However, we agree that any comments made during an FPIC meeting are open to interpretation, including by those looking to harm the project, especially when they are used in isolation and out of context.

We are categorical that every member of the community has the right to participate in and share their views in an FPIC meeting. To hinder this would be a breach of our duty of care to the community. It is not for Wildlife Alliance to police what others say. Indeed, it would be culturally inappropriate for us to contradict a commune chief at a meeting attended by many of his constituents.

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Allegation 5 (part 2): There was also no real opportunity at these meetings for villagers to contest project boundaries despite concerns raised by community members over its impact on their farmlands.

This allegation is deeply misleading as it doesn’t reflect the reality of what has been an extensive, comprehensive and multi-year process of Participatory Land Use Planning.

The facts: The boundaries of the Southern Cardamom REDD+ Project Area were established after the lands of communities were defined and codified, prior to the establishment of the Southern Cardamom REDD+ Project. This crucial result enabled the land rights of communities to be enshrined in law prior to the establishment of the REDD+ project – securing community land tenure across 28 villages in 11 communes, delineating 12,248 land parcels covering 28,883 hectares of land, and ultimately benefiting 5,980 families who previously had no legal recognition of their rights to the land.

The Participatory Land Use Planning process through which this was achieved is detailed extensively in our recent open letter, which thoroughly refutes the notion that communities were not provided with a meaningful opportunity to review and, where warranted, contest project boundaries.

We emphasise that community members have had extensive opportunity to consider the project maps. To reiterate what has been shared in the open letter and other documents we have made publicly available:

• A high-resolution map of the Southern Cardamom REDD+ Project is available to the public on both the project website and project Facebook page.
• During the eighth round of FPIC meetings in 2024, the map was again displayed at each meeting and villagers were given at least 50 minutes to ask questions.
• The map is routinely shared with community members at each FPIC meeting, including the seven rounds prior to the 2024 FPIC meetings.
• If a community member is in any doubt, they can call the project’s hotline to check whether a specific location falls in the Project Area and/or wider Protected Area.
• Maps are available in villages, commune halls, and other public places and all ranger patrol stations.

Moreover, community members are free to contest the project boundaries at any time, which they can do at FPIC meetings, through the FGRM or any other method of communication with the project.

Wildlife Alliance has no jurisdiction over the boundaries and where these issues cannot be easily resolved, they must be referred to the appropriate authorities. As such, it is simply not the purpose or function of FPIC meetings to establish land boundaries (nor do FPIC meetings serve that purpose or function in any project of this kind). That process is under the jurisdiction of the Cambodian government, and is separate and distinct from the operations of the REDD+ project.

Finally, anyone who does not wish to support the project is under no obligation to vote in favor of the project – but we repeat that the results of the secret ballot at these meetings were: 81% support in Pralay Commune; 82% in Chumnoab Commune, and 88% in Thma Dan Pov Commune.

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Allegation 6: Dr. Suwanna Gauntlett’s open letter states: “We will provide formal human rights training to all Cambodian government rangers and WA staff, and this will be done with the assistance of the OHCHR. Training will follow the UN Guiding Principles on Business and Human Rights. We also want to ensure that staff are trained regarding the importance of human rights due diligence and how such due diligence should be conducted.” I contacted the UN OHCHR on August 11 and they stated they have no agreement to do this with Wildlife Alliance or the Ministry of Environment and were never approached by either party.

The open letter has been updated to reflect the information below.

Wildlife Alliance contracted Mr Stephan Bognar – Director of Sustainability and Lead Trainer on Human Rights at WWC to train all CFPP rangers in international best practice on human rights and rangers code of conduct. Mr Bognar has been working directly with Indigenous communities across the Asia-Pacific region and designed a specialized training module for rangers and conservation officers called HUMAN RIGHTS through REDD+. He is amongst the foremost experts on these matters, including through his work with UNHCR. He was recognized by the City of San Francisco and given the Environmental Citizen’s Award in 2005, and the International Ranger Federation Commendation Award in 2014.

On 13 June 2024, Mr Bognar met with Ms Roueida El Hage, the Director of OHCHR Cambodia to explore the possibility of co-delivering several human rights workshops to government rangers working in the Southern Cardamom REDD+ Project. Ms El Hage explained that although OHCHR delivers human rights workshops in Cambodia annually, they do not partner with organizations to co-deliver internal training. Ms El Hage did say how pleased she was that WWC has been able to deliver its HUMAN RIGHTS through REDD+ training workshops to government rangers, and offered to provide materials to guide these workshops.

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Allegation 7: Community members and local farmers in other locations throughout the project reported being evicted as a result of Wildlife Alliance-led activities which have been cited in project documents submitted to Verra and used to certify projects. For example, residents in the village of Prolean (ស្ពលាន) in Kandaol commune in Botum Sakor District in Koh Kong province say they were forced off their farmland in the early 2000s to make way for the creation of Sovanna Baitong and that the vast majority of those affected by this did not receive compensation.

References to “throughout the project” are vague; the Southern Cardamom REDD+ Project covers some 450,000 hectares, and the Project Area is home to approximately 16,000 people. To the extent that the author of the allegations has evidence, it should be presented to Wildlife Alliance so that we can properly investigate and respond to it.

In the meantime, we reiterate the lengthy Participatory Land Use Planning process that was undertaken to delineate community lands and to prioritize, plan, and implement the Southern Cardamom REDD+ Project. To the best of our knowledge, no one lost access to their legally recognized land through this process. However, as stated repeatedly, we are committed to improving the process for addressing grievances related to land claims.

The account of events regarding Sovanna Baitong is a gross mischaracterization.

The facts: No resident of Prolean village was forced off farmland as a result of the creation of Sovanna Baitong, and where land was affected, residents were compensated and received support from the Community Agriculture Development Project (details below).

In truth, the 1,200 hectares encompassing Sovanna Baitong village was identified following a lengthy and comprehensive Participatory Rural Appraisal and consultations with local authorities, villagers, the Ministry of Agriculture, Forestry and Fisheries, the Forestry Administration, and the 42 Southwest Elephant Corridor Steering Committee (National Level Committee). This area, which was uninhabited, degraded state forest, was then converted by government sub-decree from public state land to private state land to be managed under the Koh Kong Provincial Authority.

For context:

Sovanna Baitong Village was created in 2004 as a Community Agriculture Development Project (CADP) developed by Wildlife Alliance with technical assistance from the Ministry of Agriculture, Forestry, and Fisheries, Ministry of Land Management, Ministry of Environment, Koh Kong Provincial Authority and the Netafim company. Over eight years, the project employed five international agronomists and irrigation specialists from Israel, and a team of 15 local project staff living with the villagers to implement side-by-side best practices for modern agriculture.

The Community Agriculture Development Project aimed to offer an alternative livelihood to the poorest, landless farmers who often lived deep inside the forest, isolated from communities, and practicing unsustainable forest slash-and-burn agriculture.

During a lengthy and comprehensive engagement process, those families were offered the opportunity to move voluntarily to Sovanna Baitong at which point they received a 1.5-hectare plot per family if they chose to join the CADP. The project fully supported the families in starting their lives in the village and helped them sell surplus produce at local markets.

Since its creation, the CADP project in Sovanna Baitong village has provided 187 families (which grew today to 283 families) with the following (fully and independently verified) positive impacts:

• Each family is provided a 1.5-hectare plot, for which they will receive a hard title once the systematic land registration is finished (a very lengthy government process).
• The CADP helped build the village’s primary school in 2005. Today, 166 students are enrolled there.
• The CADP built 7.8 km of roads throughout the village, and helped villagers transport produce to markets in Andong Teuk and Sre Ambel.
• The CADP provided a village-wide irrigation system.
• The CADP created and maintains a 20-hectare community orchard. Income generated by the orchard is managed by the Agriculture Association of Sovanna Baitong and is used together with Wildlife Alliance’s subsidy to maintain the village’s infrastructure.
• The CADP provided free and/or heavily subsidized equipment, seedlings, livestock, fertilizer, and land plowing.

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