Saturday, February 2, 2008

The Questionable Tonle Sap Initiative


The Tonle Sap River Basin is important to some two million Cambodians. Livelihoods of communities living around the Tonle Sap Lake depend on its rich natural resources. Further, the seasonal flooding provides spawning grounds for fish in the flooded forests. During rainy season, communities are able to fish and cultivate rice at the same time in the flooded areas. With its diverse natural resources, the United Nations Educational, Scientific and Cultural Organization (UNESCO) and the government of Cambodia identified the Tonle Sap region as a biosphere region in 1997 and was subsequently designated by a Royal Decree in 2001.

The Asian Development Bank (ADB) has established itself as the leading funding agency in the Tonle Sap Basin. (Jessica Rosien, April 2006) The Bank’s involvement in Tonle Sap Basin started in 1998 as part of a technical assistance (TA) for the Mekong Region amounting to US$1.65 million. It has the objective of identifying investment projects related to community-based natural resources management.

With the goal of pro-poor sustainable growth and equitable access to natural resources, the ADB launched the Tonle Sap initiative in 2002. The initiative has four major projects: Tonle Sap Environmental Management Project (TSEMP) with a total cost of US$19.4 million; Tonle Sap Sustainable Livelihoods Project (TSSLP), US$19.7 million; Lowland stabilization Project, US$1 million; and Watershed Management Project, which is still in the pipeline.

The holistic approach applied by the ADB to the Tonle Sap is commendable. It uses a basin-wide integrated approach in managing the Tonle Sap River Basin. Tonle Sap is part of the Bank’s Regional Cooperation Strategy and Program (RCSP) for the Greater Mekong Subregion (GMS). The GMS-RCSP aims to facilitate growth and development in the region. However, there are projects under the GMS that hinder the attainment of the goals of the Tonle Sap Initiative. Specifically, the development of hydropower infrastructure in the upstream Mekong River will eventually have significant negative environmental and social impacts on the Tonle Sap Basin.

Environmental and Social Impacts

According to the ADB, built structures such as dams, weirs, and flood control works could alter water quantity, quality, and timing. (ADB TA Report, October 2005) Said infrastructures have negative environmental and social impacts on the downstream communities, in particular the Tonle Sap Basin.

The Tonle Sap Lake is a tributary of the Mekong River. Built infrastructures in the upstream Mekong River could modify flooding patterns. In the case of Tonle Sap, the disruption of the natural flooding could lead to the decline of fish supply due to the blocking of fish migration. The forests in the Tonle Sap, which serve as rich spawning grounds, will also be significantly affected and become inaccessible to fish.

The disruption of flooding patterns in the Tonle Sap will lead to loss of habitat and will affect the fishery resources. (ADB, October 2005) This in turn will have major impact to the lives of the communities that depend on the natural resources of the Tonle Sap for their livelihoods. With the disruption of the flooding pattern in the Tonle Sap, the villagers’ practice of simultaneous fishing and rice cultivation in the flooded areas will be severely affected. This will in turn lead to possible loss of income and change in the way of life of the people living around the Tonle Sap Lake.

One example of the negative impact of large-scale infrastructure is the controversial Nam Theun 2 hydropower project. The cumulative environmental impact assessment conducted by the Nam Theun 2 Power Company (NTCP) admits that “Water levels at Phnom Penh will be lower during floods and increased during the dry season. Annual maximum level of the lake will also be reduced. Changes in flow patterns will have a small negative impact on the floodplain and Tonle Sap lake fisheries as these are favored by high wet season water levels.”

(, p.6)

Even if the EIA for Nam Theun 2 stated that the impacts will be “small,” if one considers the total number of existing and planned hydropower projects in ADB’s Mekong Power grid, it is not hard to deduct that many small impacts could add up to very significant impacts.

The Tonle Sap Initiative paved the way for the establishment of community fisheries (CF) to promote participatory natural resources management. However, CF members complain about the absence of authority for CFs to enforce regulations. The bureaucracy in reporting illegal activities provides a wide space for the illegal fishers to escape captivity.

CF members also complain about the non-exclusiveness of CFs. Outsiders are allowed open access to CFs and since they have less incentive to abide by the CF regulations, they often engage in illegal, unsustainable fishing practices. This means that CF efforts on the sustainable natural resources management will be undermined lessening the incentive for CF members to adhere to the regulations.

Safeguard Policy Violations

Environment Policy

Based on the Report and Recommendations (RRP) of the ADB President on the Proposed Asian Development Fund Grant for the Kingdom of Cambodia on the Tonle Sap Sustainable Livelihoods Project, the cumulative impact of built structures on the Mekong is a main concern of the Bank among the external factors affecting the Tonle Sap.(RRP, November 2005) However, Rosien pointed out that ADB’s view on the impacts of hydropower development on the upstream Mekong on the Tonle Sap is not consistent with the RRP statement. The Final TA Report for the Tonle Sap Sustainable Livelihoods The Project shows that the ADB is merely operating on the assumption that there will be no significant environmental impacts, without having undertaken scientific testing to back this assumption. This violates the precautionary approach, to which ADB subscribes in its Water Policy. If the ADB were following this approach, it could not use the lack of scientific evidence to justify its decisions on infrastructure projects that affect the Mekong River and the Tonle Sap.

This also shows that the Bank has not undertaken cumulative environment environmental impact assessment to determine the effects of upstream development on the Tonle Sap Basin. The Bank failed to holistically assess the impacts of the transboundary issues of ADB’s project plans. (Rosien, 2006)

Further, the implementation of the Mekong Power Grid will have substantial negative impacts on the Tonle Sap Basin and the lives of the millions of Cambodians who depend on it. According to Rosien, if the ADB is truly adopting an integrated approach to the Tonle Sap River Basin, it should not push through with hydropower developments that are not carefully planned. The project should also have meaningful participation from project affected people.

The failure of the Bank to conduct a cumulative and integrated environmental impact assessment (EIA) for the entire GMS shows the shortcoming of the Bank in factoring the environmental, social and economic impacts of large-scale infrastructures, such as dams, to the Tonle Sap River Basin and surrounding communities.

Based on the independent analysis conducted by the Mekong Watch on the EIA of the Chong Kneas Environmental Improvement Project (CKEIP), the EIA was lacking and significant environmental impacts were omitted. (Rosien, 2006)

Involuntary Resettlement Policy

The ADB came up with a Land Acquisition and Resettlement Framework (LARF) to safeguard communities against negative resettlement impacts caused by infrastructure projects. However, there are certain provisions which are ambiguous. (Rosien, 2006)The ADB conducted consultations only on some of its projects at a very limited extent. Majority of the villagers have little knowledge about the Bank’s projects. Villagers are unlikely to agree with their relocation if the compensation given them will improve their previous situation. Therefore, the Bank should consult with the communities to identify subprojects that will be implemented in a participatory manner.

Other Issues and Concerns

With the present hierarchical and political setup in the communities, there is a great risk that women will not be heard during discussions.

There is a risk of organizational congestion due to the overlaps among the different line agencies/bodies of the government. Poor communication and coordination among these line agencies could hinder the attainment of the goal of sustainable natural resource management.

There is also a lack of participation in the project design. It is not even sure if the recommendations from the different communities on some of the Bank’s projects were even incorporated and adopted.

Lessons to Learn

The inconsistency of the projects, program and approach to the Tonle Sap and GMS clearly shows that the ADB should improve the coherence of its overall policy. (Rosien, 2006) If the Bank is really serious about promoting social, economic and environmental sustainability in the Tonle Sap River Basin, it should conduct an integrated EIA of the entire GMS. Without doing so, the success of the GMS will undermine the gains of the Tonle Sap initiative.

While in the past, it is clear that the ADB has not conducted comprehensive impact assessments of infrastructure projects, the Bank has now taken a step towards this direction through its recently approved TA on the Influence of Built Structures on the Tonle Sap which is supposed to provide scientific data on impacts of infrastructure projects. This is encouraging. However, whether the ADB will utilize the results from the studies and be guided in its infrastructure development projects remains to be seen.

The ADB should ensure that all stakeholders and affected people of its projects be consulted. Based on the principle of free prior informed consent of the World Commission on Dams, the ADB should conduct meaningful consultations. People should have the right to say no to projects or request for changes in the project design.

The design of the Tonle Sap Initiative requires that the Bank and the different line agencies of the government should work together. However, there has not been a very good track record of inter and intradepartmental cooperation. Without such coordination, the Tonle Sap Initiatives chances for success are not very high.

To ensure voices of women will be considered in the decisions for planning and project design, the ADB should integrate gender perspective in its planning and design for all projects in the Tonle Sap River Basin. (Rosien, 2006)


ADB. “Proposed Asian Development Fund Grant Kingdom of Cambodia: Tonle Sap Sustainable Livelihoods Project.” Report and Recommendation of the President to the Board of Directors. Manila: ADB, November 2005.

ADB. “Technical Assistance to the Kingdom of Cambodia for the Study of the Influence of Built Structures on the Fisheries of the Tonle Sap (Financed by the Government of Finland).” Manila: ADB, October 2005.

Rosien, Jessica. “Can the Asian Development Bank Save the Tonle Sap from Povert?: An Analysis of the Asian Development Bank’s Operations in the Tonle Sap.”Australia: Oxfam Australia, April 2006.
(, p.6)

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