BANK INFORMATION CENTER ORGANIZATION MYANMAR

BIC
AMPLIFYING LOCAL VOICES TO DEMOCRATIZE DEVELOPMENT
The Bank Information Center (BIC) partners with civil society in developing and
transition countries to influence the World Bank and other international financial
institutions (IFIs) to promote social and economic justice and ecological
sustainability. BIC is an independent, non-profit, non-governmental organization
that advocates for the protection of rights, participation, transparency, and public
accountability in the governance and operations of the World Bank Group and
regional development banks.
“The development finance landscape is rapidly shifting, and BIC has an important role in
keeping up with the trends and working with civil society and communities to influence the
development activities that profoundly impact their lives. I am honored to lead BIC through
this exciting transition period” – Elana Berger
Wunna Htun
Myanmar Program Coordinator
whtun@bankinformationcenter.org
Wunna has been working with ActionAid Myanmar for five years in different
capacities, the last one as the Governance Thematic Coordinator. He was
instrumental in building capacity among youth and supporting them to work for
the community for short and long term development for their own community. His
responsibilities at Action Aid included regular assessment and review of the
impact of governance work, build and maintain relationship with
Union/regional/local government and initiate a network of like-minded
organizations at the national level with the focus of budget watch and
governance work.
He holds a Post Graduate Diploma in Political Science from Yangon University

After a 25 year-long absence, International Financial Institutions (IFIs)
returned to Burma in 2012 in support of the country’s political and
economic transitions.
Following the election of the civilian government in November 2010, the
leadership of President Thein Sein indicated, in the eyes of the international
community, signs of reform.
International donors such as the World Bank Group (WBG) and the Asian
Development Bank (ADB) sought to support the reform process by deploying
their staff, opening their country office, conducting assessments, rolling out their
interim investment plans, and funding a few projects. Since their formal re-
engagement in 2012, these multilateral institutions have stepped up their lending
and non-lending activities.
The civil society organizations of Burma, both those that are based inside and on
the border of the country, were very clear in reminding the IFIs to avoid rushing
into a country where the military still exerts a huge influence over the government
(25% of the seats in Parliament are reserved for military personnel) and military
cronies dominate the formal economic sector. However, donors continue to
exhibit an overwhelmingly positive view about the prospects of Burma’s political
and economic reforms and have already moved ahead with multi-million dollar
projects.
History of IFI Engagement
Burma (also known as Myanmar) has been a member of the World Bank Group
since 1952 and a member of the Asian Development Bank since 1973. However,
both institutions froze regular operations in the country in 1987 after the
government failed to pay back its loans. While the IFIs could not provide
investment lending during this period, the World Bank was allowed to support a
multi-donor response to the onslaught of Avian flu and a joint assessment of the
aftermath of Cyclone Nargis.
In 2010, the country held its first general election in 20 years, and the Thein Sein
presidency reached out to the donor community to support his reform agenda. In
2012, the World Bank and ADB put into action their respective interim assistance
strategy to enable them to perform limited technical assistance and so-called
“quick win, peace dividend” projects. Burma owed around $420 million to the WB
and $512 million to the ADB in arrears.
The US economic sanctions that restricted the flow of US aid to Burma were
lifted on September 26, 2012, and the country’s outstanding debts were cleared
in late January 2013 when Japan provided two bridge loans totaling
approximately $900 million for Burma to clear its arrears with ADB and WBG.
Both the World Bank Group and the Asian Development Bank in turn issued
loans to the country on January 22, 2013 and January 14, 2013 respectively so

that Burma could repay Japan and pave the way for both IFIs to recommence
their lending.
Back Ground
International Monetary Fund
While BIC does not actively monitor the IMF, the institution has been critical in
shaping Burma’s economic policy in recent years.
In contrast with the WBG and ADB, the IMF did not stop its engagement with
Burma during military rule, though its engagement up until 2012 was limited to
unpublished Article IV consultations. On December 28, 2012 the government of
Burma sent a Letter of Intent to the IMF, which outlined the economic policies of
the government for the year 2013 and requested assistance from the IMF to
implement those policies. Its two main aims were to ensure macroeconomic
stability (e.g. low inflation, build up of international currency reserves) and to
strengthen the institutions that ensure this stability (e.g. exchange rate system)
and set benchmarks for indicators of success. The IMF agreed to a Staff
Monitored Program in January 2013 and have invited the community to attend
public sessions since then to hear the results of the annual Article IV
consultations.
Country Strategies
An integral part of the IFI re-engagement in Burma was the development of a
short-term country strategy to guide the WBG and ADB investments for the first
18-24 months of investment. The ADB approved the Interim Country Partnership
Strategy (ICPS) on October 26, 2012, which was focused on creating and
enabling economic environment for growth, improving rural livelihoods and
infrastructure development, and capacity building. The ICPS was extended to
cover investments through 2016 and will be replaced by a long-term Country
Partnership Strategy that is expected to be approved in late 2016/early 2017.
The World Bank Board of Directors approved the short-term Interim Strategy
Note (ISN) on November 1, 2012, whose three pillars concentrated on
institutional reform to better economic and private sector performance, short term
benefits, especially to conflict-affected communities, and preparing for the longer
term strategy. Local and international CSOs noted several concerns with the ISN
development process, as articulated in a letter sent to the Board of Directors in
August 2012. Among the concerns was the lack of a transparent and
accountable consultation process and the short turnaround time between
disclosure of the final ISN and Board Approval.
The ISN was replaced with a Country Partnership Framework (CPF), which was
finalized in April 2015 and outlines the Bank’s engagement in the country from
2015 to 2017. The CPF is larger than the ISN as it involves a greater lending
volume to a greater area in a larger number of sectors. Burma was one of the

two pilot countries in Asia for the Bank’s new CPF development process, which
now includes priorities from IDA, IFC, and MIGA. Part of this new process
included the development of the Strategic Country Diagnostic (SCD), which is
intended to be a thorough evaluation of the country’s needs prior to articulating
the Bank’s strategy for poverty reduction.
Many of the concerns raised during the ISN consultations were raised again
during the CPF consultation process, in particular around the short timeline for
developing both the SCD and the CPF. The Asian Development Bank, which
began to re-engage at around the same time as the World Bank, did not start its
long-term country partnership strategy consultation process until after the
November 2015 elections in Burma , which led many to question the World
Bank’s rush to get this CPF out the door.
A formal written submission regarding the content of the CPF, especially its focus
on agriculture and energy, was submitted to the World Bank Burma Country Staff
on September 12, 2014 by 30+ Burma civil society groups. Given the fragile
peace-process and lack of reliable data in Burma, upstream risk assessment and
a robust consultation process are critical in ensuring that the CPF is effective in
meeting its development goals.
More information about the World Bank’s new Country Partnership
Framework Process:
Country Partnership Framework, Bank Information Center website
CSO Recommendations on the World Bank’s Draft Interim Strategy Note for
Burma (Myanmar), September 2012
Joint Submission on the Proposed World Bank Group’s Country
Partnership Framework
(CPF) in Myanmar, September 2014
The World Bank Group’s portfolio in Burma is small, but growing rapidly. While
local and international partners, with BIC’s support, have been tracking the active
and proposed projects, the four projects listed below highlight common concerns
around transparency, public participation, accountability, conflict sensitivity and
environmental and human rights protection.
National Community Driven Development Project
Telecommunications Sector Reform Project
Agriculture Development Support Project
Yoma Bank Equity Project
World Bank Board of Executive Directors (BIC website)
Ulrich Zachau
Country Director, Cambodia, Lao PDR, Malaysia, Myanmar, and Thailand
Tel: +66 2 686 8300

Email: uzachau@worldbank.org
Address:
30th Floor, Siam Tower
989 Rama 1 Road
Pathumwan, Bangkok 10330
Thailand
Abdoulaye Seck
Country Manager, Burma
Tel: +95 1 654 824
Email: aseck1@worldbank.org
Address:
No.57 Pyay Road
6 1/2 Mile, Hlaing Township
Yangon
Myanmar
Kyaw Soe Lynn
Communications Officer, Burma
Tel: +95 1 966 2866 ext 240
Email: klynn@worldbank.org
IFC
Vikram Kumar
Resident Representative, Burma
Tel: +95 1 654 824
Email: VKumar3@ifc.org
Address:
No.57 Pyay Road
6 1/2 Mile, Hlaing Township
Yangon
Myanmar
Chu Thi Van Anh
Communications Officer, Burma, Lao PDR,Thailand, and Vietnam
Tel: +84 4 3824 7892 ext. 608 (Vietnam)
Email: canh1@ifc.org
ADB
Winfried Wicklein
Country Director, Burma (Myanmar) Resident Mission
Email: wwicklein@adb.org
Yan Naing Hein
Civil Social/External Relations Officer, Burma (Myanmar)
Burma (Myanmar) Resident Mission Contact Information, ADB website
BIC
Joe Athialy
Acting Director, Asia Program
Tel: +91 98711-53775 (Delhi)
Email: jathialy@bankinformationcenter.org
Wunna Htun
Myanmar Program Coordinator, Asia Program
Tel: +95 94480 16197 (Yangon)
Email: whtun@bankinformationcenter.org
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After a 25 year-long absence, International Financial Institutions (IFIs) returned to
Burma in 2012 in support of the country’s political and economic transitions.
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SERVICES & TOOLS
BIC provides a variety of advocacy services and tools including:
• Education and training materials to assist
communities around the world in understanding
and influencing the projects and policies of
international financial institutions, such as the
World Bank and regional development banks
• Access to hard-to-obtain project documents and
information on international financial institutions
• Analytical work on key developments within institutions
and detailed case studies of problem projects
• Strategic support for monitoring individual projects
and policies, for example the Oyu Tolgoi Mine Project in
Mongolia and the Lignite Power Project in Kosovo.
.• Policy research and advocacy to promote rights,
transparency, accountability and participation in the
operations and governance of the institutions
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The Bank Information Center (BIC) partners with civil society in
developing and transition countries to influence the World Bank
and other international financial institutions (IFIs) to promote
social and economic justice and ecological sustainability.
BIC is an independent, non-profit, non-governmental organization
that advocates for the protection of rights, participation,
transparency, and public accountability in the governance and
operations of the World Bank Group and regional development
banks.

AMPLIFYING LOCAL VOICES
The Bank Information Center (BIC) partners with
civil society organizations around the world, to
influence the World Bank and other international
financial institutions (IFIs) to promote social and
economic justice and ecological sustainability.
The Community BIC Serves
BIC is a principal source of information for
communities affected by IFI-financed projects and
policies and the organizations they work with,
which aim to address the negative impacts of
economic globalization. BIC is also a resource for
government employees, IFI staff, the media,
academics and the public.
Opening Political Space
Communities are sometimes excluded from shaping
the very development policies and projects that
affect them. Socially and environmentally
sustainable development only happens when
communities get the information they need to
participate effectively in decision making.
By opening political space around development
decision making, BIC strives to ensure that local
communities and organizations have a voice in
the decisions that affect them.
FOCUSING ON IFIs
The international financial institutions, which
include the World Bank, the International
Monetary Fund (IMF) and regional development
banks, constitute the largest source of
development finance in the world.
The IFIs, and in particular the World Bank, are
a primary source of development knowledge,
publishing research that frames the debate on
development issues. Other donor institutions
often take their lead from the World Bank, thus
amplifying the impact of those institutions'
lending approaches and decisions.
IFI loans to finance investment projects and policy
changes in developing countries promise to reduce
poverty and encourage economic development. However,
ill-conceived IFI loans, projects and programs have
often caused widespread environmental and social
damage including irreversible impacts on natural
habitats, displaced communities and indigenous peoples.
IFI activities are often carried out without the informed
participation of affected people or, in some cases, even the
legislatures of the Banks' borrowing countries. Despite some
progress the IFIs still do not release comprehensive
information in a timely manner during project design and
implementation. Finally, as publicly financed institutions, the
IFIs should be held accountable for the consequences of the
projects and programs they finance in developing countries.
WORKING TO DEMOCRATIZE DEVELOPMENT
BIC's work focuses on four elements to democratizing
decision making within powerful public institutions:
• Protecting economic, social, cultural and
environmental rights, in part by promoting greater
consistency between IFIsafeguard policies and
international law, standards, and norms.
• Building civil society networks interested in access to
information at the IFIs, promoting transparency at the
regional development banks and strengthening
recourse mechanisms available to the public when
information is denied.
• Holding IFIs accountable by strengthening and
extending the mandates of the World Bank
Inspection Panel and internal accountability
mechanisms at other IFIs, while at the same time
promoting alternative channels of accountability.
• Demanding greater opportunities for civic
engagement by evolving a set of lessons learned,
principles, and guidelines that can help civil
society set the terms of engagement in future IFI
project and policy processes
I + I

5/13/2018 Burma - Bank Information Center
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Burma
Home » Regional Programs » Asia Program » Burma
Development Bank (ADB) sought to support the reform process by deploying their
staff, opening their country office, conducting assessments, rolling out their interim
investment plans, and funding a few projects. Since their formal re-engagement in
2012, these multilateral institutions have stepped up their lending and non-lending
activities.
the border of the country, were very clear in reminding the IFIs to avoid rushing into
a country where the military still exerts a huge influence over the government (25%
of the seats in Parliament are reserved for military personnel) and military cronies
dominate the formal economic sector. However, donors continue to exhibit an
overwhelmingly positive view about the prospects of Burma’s political and economic
reforms and have already moved ahead with multi-million dollar projects.
History of IFI Engagement
Burma (also known as Myanmar) has been a member of the World Bank Group
since 1952 and a member of the Asian Development Bank since 1973. However,
both institutions froze regular operations in the country in 1987 after the
government failed to pay back its loans. While the IFIs could not provide investment
lending during this period, the World Bank was allowed to support a multi-donor
response to the onslaught of Avian flu and a joint assessment of the aftermath of
Cyclone Nargis.
In 2010, the country held its first general election in 20 years, and the Thein Sein
presidency reached out to the donor community to support his reform agenda. In
2012, the World Bank and ADB put into action their respective interim assistance
strategy to enable them to perform limited technical assistance and so-called “quick
win, peace dividend” projects. Burma owed around $420 million to the WB and
$512 million to the ADB in arrears.
The US economic sanctions that restricted the flow of US aid to Burma were lifted
on September 26, 2012, and the country’s outstanding debts were cleared in late
January 2013 when Japan provided two bridge loans totaling approximately $900
million for Burma to clear its arrears with ADB and WBG. Both the World Bank
Group and the Asian Development Bank in turn issued loans to the country on
January 22, 2013 and January 14, 2013 respectively so that Burma could repay
Japan and pave the way for both IFIs to recommence their lending.
International Monetary Fund
While BIC does not actively monitor the IMF, the institution has been critical in
shaping Burma’s economic policy in recent years.
After a 25 year-long absence,
International Financial Institutions
(IFIs) returned to Burma in 2012 in
support of the country’s political and
Following the election of the civilian
government in November 2010, the
leadership of President Thein Sein
indicated, in the eyes of the
international community, signs of
reform.
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In contrast with the WBG and ADB, the IMF did not stop its engagement with
Burma during military rule, though its engagement up until 2012 was limited to
unpublished Article IV consultations. On December 28, 2012 the government of
Burma sent a Letter of Intent to the IMF, which outlined the economic policies of the
government for the year 2013 and requested assistance from the IMF to implement
those policies. Its two main aims were to ensure macroeconomic stability (e.g. low
inflation, build up of international currency reserves) and to strengthen the
institutions that ensure this stability (e.g. exchange rate system) and set
benchmarks for indicators of success. The IMF agreed to a Staff Monitored
Program in January 2013 and have invited the community to attend public sessions
since then to hear the results of the annual Article IV consultations.
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Burma
activities.
The World Bank Group’s portfolio in Burma is small, but growing rapidly. While local
and international partners, with BIC’s support, have been tracking the active and
proposed projects, the four projects listed below highlight common concerns around
transparency, public participation, accountability, conflict sensitivity and
environmental and human rights protection.
reform.
National Community Driven Development Project
Summary
The Myanmar National Community Driven Development (CDD) Project was
approved by the Board of Directors on November 1, 2012. The total project
cost is $86.3 million, of which the World Bank is contributing $80.0 million
through an emergency recovery loan. This emergency lending allowed the
Bank to quickly disburse the loan to the Government of Burma prior to the
clearance of the country’s arrears, which did not occur until January 2013. The
project aims to provide grants to poor rural communities for small-scale
development projects which are selected by communities themselves, though
the Bank has stipulated that the projects identified at village tract level should
be infrastructure-based such as road extensions, bridges, classroom building,
etc.
The CDD project is a six year project, and is intended to reach 3 townships in
the first year, 5 more in the second year, and 7 more in the third year. By the
end of the sixth year, CDD projects will have been implemented in a township
in all 14 of Burma’s states and regions as well as the union territory, covering
a total of 640 village tracts. The first three townships chosen for this project in
May 2013 were Kyunsu in Tanintharyi Division, Kanpetlet in Chin State, and
Namhsan in Shan State. Each village tract will receive an average of $27,000
per year for three years, which is sent to the village tract directly once the
project is approved. The project has been assigned the environmental

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assessment category B, which means that it is anticipated to have limited
social and environmental impacts.
Concerns
For the World Bank, the rationale for this project is to shift the paradigm from a
top-down development approach to a bottom-up one. The idea is that if the
communities themselves choose the projects while the Department for Rural
Development (DRD) implements them, the projects will serve as a confidence-
building measure between the communities and the government. However,
the fact that the DRD is part of the Ministry of Border Affairs (a military-run
ministry) still raises many concerns for CSOs, and the lack of experienced
facilitators has compounded the problem. In addition, the focus on
infrastructure-only projects is particularly limiting for many of the targeted
communities. In Namhsan, Shan State, for example, the need was not for
infrastructure, as they already had a hospital and a new school, but for
community livelihood support and capacity building for the hospital and school
staff, which is not what the CDD provides. Namhsan was also the site of
ongoing conflict between the local armed groups and the Burma military
during the first year of the project, which led many CSOs to question the
township selection process given that the Bank required that all of the
selected sites be located in non-conflict zones.
The issue of consultation and transparency has also been a problem so far
with the CDD project. Many groups felt that despite the rhetoric, the CDD was
being rushed through, implemented in a top-down fashion as opposed to
bottom-up, and did not have space for communities to provide input. For
instance, many remote village tracts were visited only once by the facilitators,
where Steps 1-6 of a ten step process were conducted. These steps include
information dissemination, volunteer election (some villagers who were absent
from the meetings were “volunteered” by others), forming committee
members, and choosing a project from a pre-defined priority list. According to
the project information, this cycle requires at least three visits by the facilitator,
but in this case the whole process was squeezed into 3 hours. To make
matters worse, in many cases the facilitators’ visits were only announced two
days in advance, which prohibited many villagers who needed to work from
attending the meeting. This rush to cut corners undermines the entire purpose
of the project and deepens the mistrust between communities, the
government, the international NGOs hired as facilitators, and international
institutions such as the World Bank.
Resources
DRD response to IFI Watch Myanmar’s Namh Sam report, 10 February
2015
Verifying World Bank Claims About CDD: A Report on the Namh Sam
Township Project, IFI Watch Myanmar, October 2014
Burma Country Manager response to IFI Watch Myanmar, 29 May 2014
Notes and Recommendations on the CDD Project, IFI Watch Myanmar,
April 2014
CSOs Lambast World Bank for ‘Hasty’ Grant to Burma, The Irrawaddy, 7
November 2012
Community Driven Development, World Bank website
Telecommunications Sector Reform Project
Summary
The Telecommunications Sector Reform Project is a $31.5 million public
sector project funded by IDA that was approved by the Board of Directors on
February 6, 2014. The project is intended to provide an enabling environment
to support a liberalized telecom sector and to help provide access to
extremely rural areas. Component 1 includes the improvement of the
regulatory environment. The Myanmar Post and Telecommunications (MPT)
will take over the regulatory role for the time being, and they will receive on-
the-job training from Bank staff and regional regulators. Component 2 includes
the development of a universal access fund and strategy, especially to provide
coverage to extremely rural areas. The second phase pilot projects will be
funded by a one-time subsidy to the four main operators to build infrastructure
in areas which are not commercially viable. Component 3 includes the
improvement of e-Government in Burma, including the launch of the Myanmar
National Portal. The Portal will be mobile-friendly and should help improve
access to information regarding licensing and other relevant data
(subscriptions, quality of service, etc). The project has been assigned the
environmental assessment category B, which means that it is anticipated to
have limited social and environmental impacts.


Concerns
Civil society organizations have noted a number of gaps in the project
documents and have sought to bring them to the attention of the project team,
country staff, and Executive Directors. In particular, civil society would like the
Bank to commit to risk assessments and support for safeguards prior to
implementation in all three components of the project, especially given the
history of abuse perpetuated by the Ministry of Communications and
Information Technology (MCIT), the project implementer. Currently, Burmese
law and practice does not protect users from unwarranted security agency
surveillance or collection of personal data, and the government may seek to
enlist state-owned MPT or new private operators in such abuses without
appropriate safeguards for rights.
The World Bank must have a primary interest in ensuring that security
agencies are not able to conduct surveillance, procure user data, or disrupt
communications without an accountability process that involves independent
oversight to protect rights (i.e. obtaining a warrant from an independent and
competent judicial authority). Such a process does not now exist. Rather, the
MPT has been responsible for regulating internet filtering and monitoring
surveillance in conjunction with government security agencies.
While the commitments made by the Burma Country Manager to review the
suite of telecommunications policies focused on issues of privacy, data
collection, cyber-crime, access to and freedom of information (which was not
described in the project documents) was welcome, it is insufficient unless
those laws are revised and removes the government’s ability to wield bias and
abusive powers as it aids the Burmese government in modernizing Burma’s IT
infrastructure and launching eGovernment services.
It is also critical that the project team develops a consultation framework for
use by the government during Component 2, which involves the construction
of the telecommunications infrastructure in rural ethnic areas and which may
have a number of indirect but serious land and environmental impacts caused
by the influx of labor, movement of construction equipment, biased land laws,
and lack of a domestic safeguard policy framework. According to the available
project documents, it is unclear whether the Bank will provide oversight of the
Environmental and Social Management Framework, undertake safeguards
assessments, lead mitigation efforts, or build the institutional capacity of MCIT.
Past consultations with CSOs were disappointing, so the lack of clarity on
implementation of the project, especially the physical components, is
particularly worrisome.
For instance, the documents for the first consultation with NGOs regarding the
project were disclosed only a few days beforehand and indicated that the
Bank had already consulted ethnic groups widely. When CSOs demanded that
the list of ethnic groups consulted be published, the project team admitted that
they had not done any other consultations besides the one in Yangon but had
included the statement in the draft project documents in anticipation of future
consultations. The document was immediately taken down from the Bank’s
website, but CSOs still feel as if they cannot trust what is recorded in the
Bank’s documents because of this instance.
Resources
Letters
Response to World Bank Country Manager, 10 February 2014
Burma Country Manager Response to CSO letter, 25 January 2014
CSO letter to the World Bank Board of Directors on the Burma Telecom
Project, 21 January 2014
CSO letter to the World Bank Southeast Asia Country Director on the
Burma Telecom Project, 21 January 2014
Media
Telecom investments threaten privacy rights in Burma, DVB, 4 February
2014
World Bank Pledges $2 Billion in Aid to Myanmar, Radio Free Asia, 27
January 2014
Reforming Telecommunications in Burma: Human Rights and
Responsible Investment in Mobile and the Internet, Human Rights
Watch, May 2013
Agriculture Development Support Project

Summary
The Agricultural Development Support Project (ADSP) is a $100 million public
sector project funded by IDA that is expected to go to the Board of Directors
for approval on February 5, 2015. The project is focused on the productivity
improvement of small-holder farmers through Water User Groups in Burma’s
dry zone, namely in the Naypyitaw, Sagaing, Bago East, and Mandalay
regions. The three major components are: (i) irrigation management, which
will focus on reforming the way irrigation schemes are managed as well as
fund some strategic studies; (ii) farm advisory services, including classic
training on basic problems such as inadequate seed production, technology,
fertilizer, and agrochemicals; inexistence of public extension services; and
increasing labor costs (which will be addressed through the farm
mechanization subcomponent); and (iii) project management. There is also
space for an emergency fund to allow the project team to quickly re-allocate
resources in the case of an emergency. The project has been assigned the
environmental assessment category B, which means that it is anticipated to
have limited social and environmental impacts.
Concerns
Agriculture is core to the development of Burma, as 70% of the country’s
population relies on this sector for their livelihoods, most of whom are small-
holder farmers. The most burning issue regarding agriculture in Burma today
is that of land – land grabbing by cronies and the miltary is a major problem
and one that will not go away unless the lands of small-holder farmers are
protected. There is a fear that World Bank investments in agriculture will
promote agribusiness in Burma, which has already prompted mass land
grabbing by cronies, leaving local farmers landless without compensation.
Of particular concern is the intersection between agriculture, energy and
extractives, and land as conflict drivers in Myanmar. The ethnic groups of
Burma, which represent about 40% of the total population, occupy 70% of the
country’s land that is rich in natural resources. However, the government has
already granted several land concessions to national and international
business interests for agribusiness, energy, and minerals,though no one in the
local communities has seen these contracts. For instance, large amounts of
land has been granted to Chinese businesses for energy production,
especially in Kachin State where conflict is ongoing. In fact, the conflict in
Kachin State was reignited in 2011 over an argument between the KIO and
the military over access to electricity generated by a hydropower dam owned
by a Chinese company.
This project could seek to exacerbate some of these issues if it does not take
into account the complexities of land conflict and governance risks. The team
is hiring consultants to conduct some of these surveys, but it is important that
they learn from the negative examples of the Thilawa Special Economic Zone
and the Cambodian Land Management and Administration Project how to
adequately address legacy land conflict issues. There are a lot of questions
and concerns about the Ministry of Agriculture and Irrigation’s capacity to
ensure that the rights of farmers are promoted in the program, how much of
the benefits will flow down to the smallholder farmers, and also how the
program can protect against land loss by smallholders. In addition, CSOs in
Burma are concerned that all of the consultations for the project thus far have
only been conducted in Yangon with senior staff from international NGOs,
while stakeholders such as ethnic groups and small land holders in rural areas
that will be directly impacted by the project have never been consulted.
Resources
Myanmar ADSP Meeting Notes, 3 September 2014
VIDEO: Progress and Perspectives on the Interim Strategies of the
World Bank and ADB in Myanmar, World Bank Spring Meetings, 9 April
2014
Myanmar Agricultural Development Bank: Initial Assessment and
Restructuring Options, World Bank: Livelihoods and Food Security Trust
Fund, April 2014
Myanmar: Capitalizing on Rice Export Opportunities, World Bank:
Livelihoods and Food Security Trust Fund, February 2014
Yoma Bank Equity Project
Summary
The Yoma Equity Project is a $10 million International Finance Corporation
investment approved by the World Bank Group Board of Directors on July 1,


2014. The investment will consist of (i) quasi-equity; (ii) senior loan; and (iii)
trade finance through IFC Global Trade Finance Program (“GTFP”). The
investment is intended to help expand the small and medium-size enterprise
(SME) portfolio of the client, Yoma Bank, thereby increasing SME access to
lending in Burma generally. The project has been assigned the environmental
assessment category FI-2, which means that while the project may have some
negative social and environmental impacts, the client is responsible for
managing the environmental and social risks of its sub-projects.
Concerns
The IFC’s Performance Standards do not apply directly to FI projects,
meaning that the responsibility for assessing the social and environmental
impacts of the particular FI portfolio is delegated to the client. The client is not
required to disclose sub-clients or sub-projects, perform consultations, or
conduct environmental or social impact assessments. This tool is supposed to
allow the IFC to finance smaller projects than is typically feasible, but in
practice it often leads to less supervision and poor verification on the
documents submitted by the client. This of course creates serious
accountability issues, especially if the FI lending happens to go to a client that
has a checkered history and without even the minimum standards of
Corporate Social Responsibility. As a result, FI projects have come under
scrutiny in recent years, especially in India and Honduras, as illustrated by the
CAO’s audit of IFC FI projects in February 2013.
While the IFC claims that part of this project will include advisory services for
Yoma Bank staff to develop and implement an Environment and Social
Management Framework, Yoma will be operating in an environment where
there are no country system safeguards in place and therefore little
accountability if they fail to implement the ESMF. The role of the IFC in
overseeing the implementation and monitoring of the project is going to be
very important in this case, especially because of Yoma Bank’s checkered
past. These concerns include Yoma’s membership in the business ecosystem
that has been developed for many years by its main sponsor, Serge Pun and
associates, through the creation of different companies, business holdings,
and other investment deals or joint ventures with some major multinational
companies and overseas banks, some of which go to agribusiness, golf
courses, real estate development, and industrial infrastructure including the
Thilawa SEZ. These investments have been linked with human rights
violations including forced evictions, clearance of forests, industrial wastes
and labor issues.
Resources
Foreign Aid Funding Luxury Hotels in Myanmar, Inter Press Service, 1
June 2014
Press Release: International Finance Corporation (IFC) Should Postpone
Burma Investment, US Campaign for Burma, 27 May 2014
DVB talks to Vikram Kumar, IFC, DVB, 3 August 2014
Bank Information
Center
(202) 737-7752
1023 15th St NW
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
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Unported License.

Burma
activities.
Civil Society Analysis
 Understanding and Influencing IMF Policy Advice in Myanmar, New Rules and
Bank Information Center, April 2016
 Concerns and Recommendations Regarding Peace Funds, Burma Partnership
and KESAN, October 2012
 Accessible Alternatives: Ethnic Communities’ Contribution to Social
Development and Environmental Conservation in Burma, Burma Environmental
Working Group, November 2009
 Opportunities and Pitfalls: Preparing for Burma’s Economic Transition, Yuki
Akimoto (OSI/BIC), 2006
 Multilateral Development Banks and Burma: A Resource Book from the Bank
Information Center, October 2004
Project Briefs
 IFC: Maha MicroFinance Project brief, April 2016
 WB: Myanmar EITI Implementation Project brief, December 2015
 ADB: Power Transmission Improvement Project brief, October 2015
 ADB: Enhancing Rural Livelihoods and Incomes Project Brief, September 2015
 WB: Myanmar National CDD Project Additional Financing Brief, June 2015
 IFC: Ooredoo Myanmar Project Brief, June 2015
 WB: National Electrification Project Brief, May 2015
 WB: Ayeyarwady (Irrawaddy) Integrated River Basin Management Project
Brief, November 2014
 WB: Agriculture Development Support Project Brief, September 2014
 IFC: Yoma Equity Project Brief, June 2014
Media
reform.
English
Español (Spanish)

 Burma: Will International Financial Institutions Get It Right this Time?, April 14
2016 (Huffington Post)
 DVB talks to Vikram Kumar, IFC, DVB, 3 August 2014
 DVB talks to Kanthan Shankar, World Bank, DVB, 27 June 2014
 Foreign Aid Funding Luxury Hotels in Myanmar, Inter Press Service, 1 June
2014
 World Bank Pledges $2 Billion in Aid to Myanmar, Radio Free Asia, 27 January
2014
 Multilaterals Warned Not to Go Too Far, Too Fast in Myanmar, Inter Press
Service, 18 April 2012
World Bank Country Strategies
 Burma CPF page, Bank Information Center website
 Joint Submission on the Proposed World Bank Group’s Country Partnership
Framework (CPF) in Myanmar, September 2014
 CSO Recommendations on the World Bank’s Draft Interim Strategy Note for
Burma (Myanmar), September 2012
Other Resources
 Quick Facts on IFI Re-engagement in Burma, 2014
 Burma Country Page, World Bank Website
 World Bank Myanmar Facebook page
 Burma Country Page, Asian Development Bank Website
 Myanmar in Transition: Opportunities and Challenges, Asian Development
Bank, August 2012
 Burma Project, Transnational Institute
Bank Information
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1023 15th St NW
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Unported License.

1
Joint Submission on the Proposed World Bank Group’s Country Partnership Framework
(CPF) in Myanmar
September 2014
We, the undersigned organizations in Myanmar and other countries, respectfully submit
these comments to the World Bank Group to inform the development of the Country
Partnership Framework for Myanmar. We belong to civil society organizations and ethnic
community networks with a focus on human rights, environment, peace and mediation, and
good governance with significant expertise and experience in Myanmar.
We offer these comments after a series of discussions among us and exchanges with the
World Bank representatives.1
Our comments also take into account our observations on the
performance of the World Bank Group in developing and implementing its two-year Interim
Strategy Note (ISN). The Bank will recall that in September 2012, Myanmar organizations
provided a joint submission that commented on the substantive issues with the proposed
pillars in the ISN. Some of the concerns and recommendations there remain relevant to the
Bank’s Myanmar CPF. In this submission, we provide recommendations pertaining to
priority issues that should be addressed as the Bank deepens its country activities in the
next five years.
I. Adopt a conflict-sensitive approach to development as a way to support nationwide
efforts towards a comprehensive peace process
Despite progress on various fronts in the form of ceasefires with ethnic non-state armed
groups, Myanmar remains in a state of active ethnic, political, and religious conflicts.2
Moreover, as the Rohingya persecution in Rakhine State and the recent mob violence in
Mandalay clearly indicate, the potential for violence is not limited to areas of the periphery
in which there are active ethnic insurgencies. World Bank investments could easily become
focal points of public opposition and conflict if they aggravate the root causes of conflict –
such as racial inequity, land and resource grab and forced displacement from traditional
livelihood resources– and they will certainly be affected by conflict if they are carried out
without sensitivity and awareness to conflict dynamics.
The World Bank in Myanmar has been the subject of public criticisms over its recent project
loan approvals3
in part due to lack of systematic approach to analyzing the risks of conflict
1
This submission is an elaboration of the three-page summary of comments that was submitted to the World
Bank Myanmar team last August 21, 2014 by the IFI Watch Myanmar on behalf of its members and partners.
This summary is in Annex A.
2
Bank staffs have expressed differing opinions on the nature of Myanmar as a conflict-affected country. At the
Bank’s Washington, DC, CPF consultation on July 29, 2014, Bank staff assured civil society organizations that
they recognize the conflict dynamics in Myanmar and will apply conflict analysis on a project level. However,
other Bank representatives have told groups represented on this submission that they do not consider Myanmar
to be a conflict country.
3
For example, one of the Bank’s Community-Driven Development pilot sites was at Namhsan in Northern Shan
State, a zone of active conflict. Soon after Namhsan was chosen as a project site, conflict intensified causing
project delays. Although intensification of conflict was not linked to the Bank project, villagers were
intimidated by the violence and became frightened to participate in consultations related to the project lest they
be questioned about ties to ethnic insurgents. The World Bank’s recent approval of telecommunication reform

2
that surround the projects. The World Bank moved the project loans forward despite
legitimate civil society concerns and calls for meaningful consultations with concerned
communities. We have seen a number of projects pushed to the Board based on rushed and
ill-designed project design which could have been improved if risk analysis and mitigation
inputs were incorporated in the planning phase. The World Bank representatives justified
these projects on the basis of ‘lender-borrower relationship’ whereby the government is
their main client and partner. They also use the ‘multiple transition’, ‘huge investment
potential’ and ‘infrastructure deficit’ narratives, to inform their efforts to mobilize greater
investments in the public and private sectors. These justifications are inadequate because
the country remains in a condition of active conflict and fragile reforms.
The government suffers from lack of local legitimacy, with many of its existing laws and
current institutions being unresponsive and unaccountable, do not guard against corruption,
and fail to provide access to justice, in direct contradiction to the government’s mandate to
protect its citizens. While the government may be the direct client, ultimately development
investments should sustainably benefit the population in line with the WBG’s three strategic
focal areas: Reducing poverty; Investing in people and supporting reforms. The World Bank
Group’s own internal review processes have clearly indicated that in fragile and weak
governance contexts, it is essential to take a phased approach, improving governance and
building knowledge and capacity before significantly increasing investments/loans
What we are seeing in the indicative areas for World Bank’s investment plans under CPF is a
greater volume of financing flowing to soft and infrastructure projects across multiple
sectors. The Bank must not only focus on the quantity and speed of project approvals. It
must seriously take into account the breadth of analysis, quality of public consultations, and
the use of conflict-sensitive approaches. If there is no sector-wide analysis of the drivers,
institutions and dynamics that perpetuate conflicts such as the militarization of resource-
rich areas that are mostly populated by ethnic communities, capture of the legislative,
judicial and executive branches of the government by the military and their cronies, risks are
high that the investments under the CPF would be met with poor public support and many
forms of conflict.4
,5
The CPF does not explicitly state as an intention to help break the cycles
of violence and lessen the stresses that drive them. It seems to us that the Bank is more
driven by getting more money out the door and mobilizing the flow of private sector finance
into a country run by a government that is deficient of legitimacy, accountability and
institutional capacity to end violence, deliver justice, provide support for the livelihood
security of its poor populations, and manage the governance of natural resources for future
generations.
support project loan and the IFC financing of SMEs via a financial intermediary, Yoma Bank, were met with
substantive concerns relative to lack of risk analysis and risk management, among others.
4
This is one of the primary recommendation areas for World Bank’s engagement in fragile and conflict affected
states (FCS) as contained in the 2011 World Development Report on Conflict, Security and Development.
5
In the recently published study of Kim Jollife, Ethnic Conflict and Social Services in Myanmar’s Contested
Regions (June 2014), he mentioned that failures to incorporate an analysis of the conflict drivers and conflict
dynamics and how to mitigate them in aid projects often perpetuate conflicts over territorial and local
governance claims or re-ignite local tensions. See: http://asiafoundation.org/publications/force-
download.php?f=%2Fresources%2Fpdfs%2FMMEthnicConflictandSocialServices.pdf

3
Since Myanmar is technically and essentially a fragile and conflict affected state, the WB
must do things differently.
Specific recommendations:
1. State as a key component of the CPF that it supports peace and institution building and
long-term socio-economic opportunities to the ethnic communities and the poor urban
and rural populations.6
2. Do a sector and program wide risk analysis and risk management in compliance with
relevant operational safeguard policies and business procedures and applying the
Systematic Operations Risk-Rating Tool (SORT). SORT is specifically intended to help the
World Bank to assess and monitor risks across all its operational instruments and
country programs. It applies to the CPF to focus management attention on high risk CPF
during preparation and implementation and to establish risk management as an integral
component of the country engagement and is updated throughout the life of the
operation and CPF.7
3. Do a conflict mapping and analysis of the drivers of conflict for the country as a whole,
and analysis for each individual project. In particular, the Bank should consider that
projects involving large-scale acquisition of land or displacement, taking place partially
or in whole in areas of the country that are subject to active armed conflict, or targeting
the disposition or distribution of valuable natural resources present a high risk of
exacerbating conflict or igniting new conflict.
4. Practice enhanced transparency in order to avoid exacerbating conflict. Bank
contractors, partners, and consultants – even if indirectly linked to the Bank’s operations
– should be assessed for compliance with internationally recognized guidance on
mitigating conflict impacts of investment, such as the Voluntary Principles on Security
and Human Rights and International Alert’s publication Red Flags: Liability Risks for
Companies Operating in High-Risk Zones. The results of this due diligence should be
subject to public consultation and published both in English and Myanmar language.
5. Ensure that the CPF includes a clear commitment about the level of resources that will
be allocated for the implementation of safeguards, enhanced consultation and
participation processes, and the support of governance reforms. This should also
indicate the ways in which the performance evaluation and incentives of World Bank
Group project staff and management will be linked to the delivery of poverty reduction
and development impacts, and implementation of environmental and social safeguards.
6
The Bank has, in fact, been stating peace and institution building as one of its key engagement areas in
transitioning and post-armed conflict states. See for example, the Bank’s 2015-2018 partnership strategy in the
Philippines: http://www.worldbank.org/en/news/press-release/2014/06/12/world-bank-group-announces-new-
partnership-strategy-for-philippines. Myanmar needs to have the same engagement area given the fragility of
transitions and the frequency of active conflicts.
7
Based on the World Bank’s Interim Guidance Note on SORT, dated June 25, 2014.

4
II. Protect peoples’ land and resource rights of rights and support small-scale and
ecological agriculture
We support the Bank’s intention to focus on strengthening land governance as part of the
CPF, but we think it essential that the World Bank take a step back and conduct a
comprehensive land rights survey as part of the CPF process. Land-grabs are almost
universally identified as the most widespread human rights abuse in Myanmar.8
The
context is an unusually complex mixture of historical confiscations by the military regime,
ongoing displacement to make way for private investment and development, secondary
displacement because of skyrocketing land prices near economic development zones, and
land confiscation in favor of military groups and crony businessmen in ceasefire areas that
were off-limits to development until recently. Already, the first major donor-funded
development project – the JICA-funded Thilawa Special Economic Zone – has led to the
wrongful displacement of hundreds of farmers with inadequate provision for transitional
assistance and rehabilitation of livelihoods, and thousands more are on the verge of being
displaced.9
The Bank should have express, positive goals to promote land tenure security for the poor,
and especially to protect the land rights of smallholder farmers and other traditional users
of land from encroachment by the powerful. This would be in line with the commitments
made at the highest level by the World Bank Group Board and President about tackling land
grabs and improving land governance and tenure security for communities, in line with its
own polices and international standards such as the Voluntary Guidelines on the
Governance of Tenure (VGGTs).
6. Undertake a comprehensive land study10
as part of the CPF process and prior to
undertaking any project-related funding. This study can also feed into the national land
use policy development program. This study should cover the various causes of land
tenure insecurity, land loss, and land-grabbing in Myanmar, with a focus on the Bank’s
priority sectors, including agriculture, transport, telecoms, and FDI promotion. The Bank
should then use this study as a blueprint both to avoid investments with a high-risk of
land loss – such as large-scale plantation agriculture, certain types of dams, and Special
8
The Bank must prioritize the comprehensive land survey as a priority activity in the CPF. Without this, it will
be difficult to look at the scale and extent of land grabbing and impacts to affected farmers’ rights. Among the
other areas to cover in the study is how judicial review on the decision of the land administrative bodies can be
improved and how farmers can access such reviews and decisions not only at the Supreme Court but also at the
state or regional high courts.
9
This is a recent example of a failure to conduct adequate EIA, SIA and HRIA in the relocation site, which
shows many breakdowns in complying with international guidelines.
10
We emphasize that the World Bank must not do the land study in isolation. There are aid agencies such as
SDC, USAID and EU that are supporting current initiatives for a national land use policy development program
which includes consultations and efforts to harmonize existing land laws (farmland law, vacant, fallow and
virgin land management laws) and the FDI law. By working with these agencies, it can contribute to the joint
methodologies for the studies and consultations. One of the lessons we learned from dissociating the study from
the other donor processes is that it is difficult to change the bad results, which create negative outcomes on land
governance. Make it a primary strategy of the study to include farmers associations, ethnic groups, their
supporting civil society actors and other relevant stakeholders to be meaningfully consulted so that concrete
provisions are established to protect the rights of smallholders including ethnic minorities and women.

5
Economic Zones in certain areas of the country – and to identify the need for careful
contingency planning to avoid land loss – such as where the Bank is investing in recent
ceasefire areas, where the population traditionally practices shifting agriculture, and
where land has been subject to historical arbitrary confiscation by the military regime. It
should also use the study to prioritize investment and projects in economic sectors that
promote land rights for the poor. And it should prioritize the principle of free, prior, and
informed consent with respect to projects that affect the land rights of persons who are
traditionally dependent on land for their livelihoods and cultural identity.
7. Orient World Bank Group’s financing instruments and technical assistance to
strengthening land governance with great caution – and securing the land tenure of
small holder farmers. It is undeniably important to work with the Myanmar Government
to improve the formal land tenure system, but the Bank must learn from the negative
lessons of the Land Management and Administration Project (LMAP) in Cambodia.11
The
approach must be more nuanced than simply assisting with the formalization of land
title and issuance of land certificates. LMAP in Cambodia facilitated land grabs because
it financed formal land titling without promoting access to adjudicatory mechanisms for
poor land users, and because it turned a blind eye to the ways in which the land titling
system disadvantaged the poor living in land that was desirable for redevelopment.
The land tenure system in Myanmar has many weaknesses – chief among them the
Virgin, Fallow and Vacant Land Act, which allows the government to reallocate land that
it considers to be vacant or abandoned without judicial process, the excessively
complicated and bureaucratic land titling process, which provides ample opportunities
for the wealthy and well-connected to game the system and appropriate land that is
used by others without their knowledge, and the general lack of judicial review for land-
related abuses when the government is involved.12
8. Focus on reforms that enable users of the land to preserve their rights13
and usages by
giving legal recognition and protection to traditional land use patterns and building
independent administrative and judicial institutions, rather than prioritizing the
commodification of land (which can accelerate land loss). It should avoid promoting
land registration processes that can be used as weapon by the powerful and well-
connected to acquire land title over desirable areas that are already occupied, or to
ratify illegitimate land grabs of the past. Rather, it should work with Myanmar civil
society groups, communities, other aid agencies and donor support judicial and
legislative reforms, and the Myanmar government to develop rational, just land use
11
There are many reports from concerned civil society organizations and experts. The World Bank’s Inspection
Panel’s case tracker on LMAP provides comprehensive information. See:
http://ewebapps.worldbank.org/apps/ip/Pages/ViewCase.aspx?CaseId=7.
12
See, e.g., Food Security Working Group’s Land Core Group, Legal Review of Recently Enacted Farmland
Law and Vacant, Fallow and Virgin Lands Management Law (2012), at http://www.forest-
trends.org/documents/files/doc_3274.pdf.
13
Small holder farmers’ rights should be prioritized instead of the big plantation owners. Currently, the Virgin,
Fallow and Vacant Land Act provides for the issuance of 5,000 acres to an investor for each application, which
can granted ten times. Even the Land Confiscation Act of 1894 still applies. These laws are a systematic tool
for “land grabbing”, i.e. massive land confiscations and concessions.

6
resolution and rationalization processes that are participatory, adequately protect land
tenure for smallholder farmers and the poor, and allow for land restitution where land
grabs have already taken place.
9. Concentrate on funding projects that increase the livelihoods opportunities for
smallholder farmers as opposed to large-scale plantation owners. This should include
access to rural credit mechanisms that are appropriate to smallholder farmers;
traditional microfinance, for example, may not suit the needs of farmers because of the
relatively large amounts that farmers need to borrow14
and the mismatch between
microcredit loan terms and the crop cycle.15
Farmers must be able to borrow adequate
amounts of capital at reasonable rates against their harvest, and to pay the loans back
after the harvest. In addition, Bank programs should promote the diversification of farm
incomes and related insurances – for example, expansion into processing and other
value-added income-generating activities. These are necessary measures for small
farmers to increase the productivity while protecting their land ownership.
III. Facilitate job creation through assistance to small and medium enterprises and private
sector lending
We support the Bank’s proposed focus on creating jobs outside the agricultural sector but
strongly believe that this initiative should focus on small and medium enterprises and not
solely on manufacturing. Moreover, the Bank should target truly small-scale enterprises to
provide resources and build capacity, rather than allowing relatively large business to
benefit from the Bank’s programs.
10. Support to SME16
,17
should include the following elements:
 Loan subsidies and preferential access to credit. Today, SMEs can at best borrow
money in Myanmar at a subsidized rate of 8.5%18
. There is no special loan program
to ease access to credit for new businesses, and credit is generally only extended to
business in operation for more than three years19
. The Bank practice active
surveillance of its $30 million grant to Yoma Bank to ensure that the SME financing
program actually fund new and established domestic micro and small enterprises.
This means that the IFC must go beyond its general stance and rigorously monitor
14
See, e.g., Mariana Kim, Rural Poverty Alleviation in Burma’s Economic Strategy: A Comparative Evaluation
of Alternative Interventions to Increase Rural Access to Capital at 13 (2013) (paper prepared for MDRI, noting
low penetration of microcredit into the agriculture sector and inadequacy of financing terms).
15
See, e.g., Tomoko Kaino, Rural Credit Markets in Myanmar: A Study of Formal and Non-Formal Lenders at
7, Asian Journal of Agriculture and Development, Vol. 3, Nos. 1 & 2.
16
We note that in supporting SMEs, it must be framed at financial inclusion especially of the local poor, with
increased and secure employment of local population and sustainable use of local resources as one of the key
indicators of the development outcomes.
17
In Myanmar, the World Bank Group must recognize and support co-operatives and social enterprises. These
generally operate with the objectives to ensure greater social welfare of workers and suppliers while upholding
environmental standards and using profits made to plough back into the enterprise.
18
See GIZ, Myanmar’s Financial Sector: A Challenging Environment for Banks at 30 (2013), available at
http://www.giz.de/en/downloads/giz2013-en-financial-sector-myanmar.pdf.
19
Ibid. at 34.

7
the development outcomes of the loans made by the financial intermediaries to
which it provides support in Myanmar. Access to financing also needs to be made
available outside of Yangon, with a special focus on establishing SMEs among
historically underprivileged minority communities and other vulnerable groups.
 Assistance and education on registration. Registration can be a difficult, expensive,
and time-consuming process for any business, but especially for micro and small
enterprises. However, because registration can often increase access to formal
financing (and thus, lower interest rates),20
SMEs have a particular interest in
successfully registering.
 Technical assistance and management/finance training. Myanmar’s SMEs will be
increasingly exposed to international competition as the country opens its markets
to the ASEAN Economic Community. They therefore need additional capacity
building on basic business skills in order to reduce default rates, indebtedness and to
ensure competitiveness.21
11. Practice transparency and impose stringent human rights requirements in private sector
lending, including financial intermediary lending. Given the degree to which powerful
economic actors still control profitable sectors in Myanmar, it is necessary for the Bank
to require heightened levels of transparency, anti-corruption controls, and human rights
standards from its private sector investment targets, including financial intermediaries.
Recent IFC experience in Honduras – another country where land-grabbing by wealthy
and politically connected businessmen create instability and the possibility of violence –
shows the need to conduct serious due diligence and require strict guarantees from
investment targets.22
IV. Prioritize energy access for the poor
Eighty seven percent (87%) of Myanmar’s 60 million populations is without access to
electricity.23
The country is currently using 20 times less energy than the world average and
can only meet 50% of its gas demand and 60% of its electricity demands. Moreover, biomass
(mostly wood, charcoal, animal waste and agricultural residue) provides about 70% supply
of Myanmar’s energy.24
(While it is accessible for poor households, its use is limited to
cooking. It is grossly inadequate for lighting, heating and small scale industry needs.)
The country suffers from chronic electricity shortages. While urban areas always face
brownouts and blackouts, most rural areas are without basic electricity for lighting. There
simply is no network of electricity that brings power to where most of the population lives.
20
See Aung Kyaw, IDE Discussion Paper No. 148: Financing Small and Medium Enterprises in Myanmar at 45,
(2008), available at http://www.ide.go.jp/English/Publish/Download/Dp/pdf/148.pdf.
21
See Soe Sandar Oo, “Burma’s SMEs Uneasy Ahead of Asean Trade Zone,” The Irrawaddy, Dec. 3, 2013, at
http://www.irrawaddy.org/business/burmas-smes-uneasy-ahead-asean-trade-zone.html.
22
See CAO Audit of IFC Investment in Corporación Dinant S.A. de C.V., Honduras, CAO Ref: C-I-R9-Y12-
F161 (Dec. 20, 2013); CAO Investigation of IFC Environmental and Social Performance in relation to:
Investments in Banco Financiera Comercial Hondureña S.A., CAO Ref: C-I-R9-Y13-F190 (Aug. 6, 2014).
23
See International Energy Agency, Energy for All: Financing Access for the Poor (Paris: OECD/IEA, October,
2011
24
See United Nations Development Programme - Myanmar. Accelerating Energy Access For All in Myanmar.
May 2013.

8
This massive energy poverty hampers the growth of industries, household productivity and
better education of children.
The World Bank, along with the aid agencies, is well placed to help address extreme energy
poverty. However, it should be cognizant of the fact that this poverty is a consequence of
neither limited investment in energy infrastructure nor lack of energy supply. The reality is
Myanmar has huge but untapped energy resources.25
It is largely a product of bad
governance26
of the energy sector. In Myanmar, this bad governance is demonstrated by the
following:
 Skewed priority of energy production, particularly the export orientation of
energy from natural gas, crude oil and petroleum products to address the
consumption demands of China and Thailand instead of meeting its domestic
needs. This defeats the policy goal of the government, which is energy
independence and energy security.
 Absence of coherent plans and investments to improve energy efficiency and
promote renewable energy (solar, wind, small-scale/pico hydro) despite their
huge potential to power off-grid communities in addition to stimulating small
business/income generation opportunities for communities with the introduction
of these alternative energy technologies.
 Absence of a central regulatory ministry for energy efficiency and standardization
 Overlapping but highly uncoordinated functions of nearly 10 ministries dealing
with energy, which is further complicated by antiquated and recently approved
energy-related policies
 Absence of a comprehensive power development plan based on comprehensive
options assessment and integrated energy resource planning
 Absence of energy policy or power development plan that integrates climate
change risks in energy investments
Energy is one of the primary needs of Myanmar that is undergoing economic reconstruction.
As the country is at a still early stage of initiating political and socio-economic transitions,
energy access of the poor and energy independence and security should be high on the
policy and institutional reforms in this sector. Clearly, Myanmar needs affordable electricity
for millions of poor households, secure and stable energy supply for domestic industries,
health care facilities, and agricultural production and food industries. Myanmar has vast
opportunities for reforming the energy sector given its diverse energy sources, their
attractiveness for support from the donor community and private sector investments, and
the ever-increasing demand from the energy-poor households
We know that the Bank is only one of the supporting institutions to help transform the
25
See Myanmar’s Ministry of Energy, “Development in Myanmar Energy Sector,” Presentation to the
Subregional Energy Forum, Vietnam, November 22, 2008, and International Energy Agency, “Share of Total
Primary Energy Supply in Myanmar,” October 2011
26
In this context, we define governance to refer to existing rules, institutions, traditions, practices and shifting
politics that influence decisions in the sector with far reaching implications to populations, economic
development and the environment. It can cover the rule of law, quality of policies and energy development plan,
effectiveness of government institutions, political stability, the control of corruption, and the enforcement of
transparency and safeguard systems.

9
energy poverty in Myanmar. However limited its financing, technical and analytical services
might be, the World Bank Group must frame its support as part of the sustainable energy
future of Myanmar with access to energy for all people on top of its priorities based on a
diverse portfolio of energy sources generated from reliable, affordable and environmentally
sound zero/ultra-low-carbon energy technologies.
12. Prioritize energy access for the poor. This must be accompanied by supporting the
necessary energy policy reforms and institutional development that prioritize clean,
affordable, and decentralized energy services as opposed to heavy reliance on on-grid,
centralized and coal-based system. Among the concrete measures to consider is by
allocating grants and soft loans as well as several trust funds for the rehabilitation and
for retrofitting of existing gas plants. These are parts of energy efficiency measures to
prevent leakages and widen the distribution network (including transmission lines) to
deliver accessible and affordable energy for poor households, both in urban and rural
areas.
13. While the Bank’s Electric Power Project will certainly help provide power to more of the
country, the Bank should ensure that it makes electrical hookups less expensive for
micro, small, and medium enterprises in Myanmar. Electricity is currently too expensive
for most locally-owned small businesses in Myanmar. Without inexpensive electricity
hookups, it will be difficult for locally-owned businesses to be competitive in Myanmar,
and within the ASEAN region.
14. Provide the rural poor with affordable off-grid renewable energy options.
15. To meet diverse demands such as cooking, heating and productive and process uses, a
portfolio of energy sources other than just electric power is needed.
16. Assist in developing Myanmar’s local energy markets and rural entrepreneurship.
Caution must be taken here. It must not swiftly result in the privatization of energy that
increases the undue influence of the military cronies. The Bank must create a framework
to improve private sector engagement so that there will be a competitive, transparent
process, which includes evaluating the companies who will be bidding to improve gas
production for domestic market.
17. No coal. For existing coal plants, the World Bank can support the government in the
decommissioning. Not only is coal power dirty (causing public health concerns and
carbon emissions, polluting waterways and water resources), it is also water use-
intensive and over the years, it becomes inefficient. The Bank must comply with its
Energy Strategy Directions Paper (adopted in July 2013), which has stringent restrictions
relative to investments in coal power.
18. No high-risk hydropower. While the Bank staff stated that it will not yet invest in
hydropower (including in major streams such as Irrawaddy and Salween) until it has
done a series of studies, it is not a guarantee that the Bank will keep its distance from

10
large-scale, destructive dams. We urge the Bank to comply with the recommendations
from the World Commission on Dams (WCD) given the extraordinary risks of large dams.
We also urge the Bank to conduct a comprehensive options assessment that takes into
account possible mix of grid and off-grid options or an emphasis of renewable and
decentralized energy for the rural poor, among others; drawing on its own experiences
including from neighboring countries where the WB supported the Nam Theun 2 Dam27
19. Lastly, promote an Integrated Resources Planning (IRP)28
for energy efficiency and
conservation. IRP is a widely accepted decision-making tool to identify multiple benefits
in energy programs. It can support the Bank and the government, the regulators and
utility operators to evaluate the full range of cost and risk factors for all options for
delivery of local utility services, including all end-use efficiency approaches. IRP also
enables a participatory process in which planners work together with other interested
stakeholders, including community, civil society and energy experts, to identify and
prepare energy options that serve the highest possible public good. It also supports the
establishment of mechanisms to monitor, evaluate, and update energy plans as
conditions change.
We welcome further opportunities to discuss these substantive recommendations with the
World Bank Group before and after the approval of the CPF.
Endorsed by:
Myanmar organizations
1. Action Committee for Democracy Development and Network for Democracy and
Development
2. All Arakan Students' & Youths' Congress (AASYC)
3. Association of Human Rights Defenders and Promoters (HRDP)
4. Burma Environmental Working Group (BEWG)
5. Burma Partnership
6. Chin Land Natural Resource Watch Group [CNRWG]
7. Dawei Development Association [DDA]
8. Forum for Democracy in Burma
9. Green Network Sustainable Environment Group
10. Green Soul (Ton Tay)
11. Heinrich Boell Foundation, Yangon
12. Human Rights Foundation of Monland (HURFOM)
13. Irrawaddy River Conservation Network
14. Karen Environmental and Social Action Network (KESAN)
15. Karen Human Rights Group
16. Kachin Peace Network
17. Kayah Myae Witness
27
New York Times Aug 22, 2014: http://www.nytimes.com/2014/08/24/opinion/sunday/large-dams-just-arent-
worth-the-cost.html?_r=0
28
See Prayas Energy Group, Electricity Governance Initiative, and World Resources Institute 2013. 10
Questions to Ask about Integrated Resource Planning. http://www.wri.org/project/electricity-governance

11
18. Kayah State Student Union
19. Kit Thit Lu Nge
20. Land Core Group
21. Magway EITI Watch Group
22. Mon Civil Society Organization’s Network
23. Myanmar Alliance for Transparency and Accountability (MATA)
24. Myanmar China Pipeline Watch Committee
25. Nay Chin Sayar Youth Network (Sagaing)
26. Network for Democracy and Development
27. Network for Environment and Economic Development (NEED Myanmar)
28. Paung Ku
29. Research and Translation Consultancy Cluster
30. Shwe Bo Shwe Chin Thae Society Group [SSSG]
31. Shwe Gas Movement (SGM)
32. Sein Young So Activities (Mandalay)
33. Tamar Yeik
34. Tavoyan women's Union
35. Union of Karenni State Youth (UKSY)
36. Voice of Women
37. Wan Lark Rural Development Foundation
38. West North Region Ethnic Youth Group
39. The Women's League of Burma (WLB) comprised of 13 member organisations
Supporting organizations
1. Actionaid
2. Actions Birmanie (Belgium)
3. Alternative ASEAN Network on Burma
4. Burma Campaign UK
5. Bank Information Center
6. Gret (French NGO, Professionals for Fair Development)
7. Heinrich Boell Foundation, Yangon
8. Helvetas
9. NGO Forum on ADB
10. US Campaign for Burma

12
Annex 1:
Summary of comments and recommendations on CPF
Submitted to the World Bank Myanmar Team on August 21, 2014
I. Comments and recommendations regarding consultation processes
A. Feedback received on SCD consultation meetings in Yangon and other townships
i. The two-hour allocated time is too short.
ii. By conducting the consultations separately among government, INGOs and
local CSOs, the opportunity for CSOs to be heard by government and other
stakeholders is lost. It would be helpful to have opportunities to gather a
wider range of stakeholders, while also providing a separate space for each
group to be able to speak freely.
iii. Limited prior knowledge on the substance of the meetings makes it difficult
to participate meaningfully.
B. Feedback received on CPF consultation meetings:
i. There is need for indications that CSO inputs are being taken into
consideration in decision-making. It would be helpful for the consultation
process if the World Bank provides information on which particular
recommendations were adopted and which were not, and to provide
reasons.
ii. In discussing sectors that the World Bank should work on, participants were
only given 20 minutes to discuss. This is a very important issue that should
have been discussed more thoroughly and systematically.
iii. If the discussion questions had been sent along with the invitations, the CSOs
would have come up with more comprehensive points.
iv. Language needs to be clearer and more understandable. Some terminology
does not make sense when translated into Burmese. For example the phrase,
“pipeline” is ambiguous and the word itself is difficult for Burmese and those
who speak local ethnic language to understand.
v. There needs to be consultations at the grassroots, rural level. ie village level
consultations
vi. The question on coal power was raised during the consultation twice, but no
answer was given. It would be good if clear answers are given especially to
questions as crucial as this – if not during the consultation event itself, then
after through other forms of communication.
vii. Overall, the consultation itself felt rushed. Local CSO participants generally
did not find it to be meaningful.
viii.Consultations are vital to designing projects well, and should therefore not be
treated as a mere “rubberstamp” activity. There should be a comprehensive
consultation strategy for projects, as well as a central unit to implement this.
ix. There should be follow-up consultations. One consultation in one place is not
enough.
x. Publicize the draft SCD and CPF and allow reasonable time for comment by
civil society and other relevant actors.

13
II. Substantive comments and recommendations about areas of work of the
World Bank
A. In determining the “poorest of the poor”, the World Bank should broaden its range
of sources of information for indicators of poverty, and not just limit itself to
government-provided data. A number of non-government service delivery groups,
along with other kinds of non-government groups, could provide useful information
on this.
B. Conflict sensitive approach:
a. There needs to be a comprehensive conflict analysis undertaken in order to
understand the complexities of working in Myanmar. With ceasefires still at an
initial stage, the real substantive aspects of the peace process are yet to start.
Thus, Myanmar is still fragile and prone to conflict. Indeed many areas are active
conflict areas. This is an issue that cannot be ignored and projects can
potentially disrupt the peace process. No long term plan for Myanmar can be
effective without a deeper understanding of peace and conflict as this is
intrinsically linked to poverty and economic development/underdevelopment.
For example, the CDD project; Namhsan was chosen, but soon after, conflict
with the TNLA intensified, not because of the CDD project, but it caused delays,
with many villagers scared of being asked about if they had seen the TNLA.
b. The Bank must also practice responsible engagement with media as part of its
WB access to information and transparency standards. Given the juvenile nature
of many local media whose exposure to investigative journalism, objective
reporting, and familiarity with the complex nature of public and corporate
finance remains low, they can potentially exacerbate or mitigate conflicts.29
C. General comments about the CPF:
a. Why did the World Bank move quickly from the ISN to a CPF? Other countries
such as Nepal and Cambodia implemented another ISN rather than moving
straight to a CPF due to instability. With religious violence, stalled peace process
and the uncertainly leading up to the 2015 elections, Myanmar is facing its own
instability.
b. Related to this, what were the benchmarks/indicators that were met so that the
World Bank could move forward from the ISN to the CPF? Did the ISN fulfil its
stated intentions and what criteria were used to appraise this?
D. Supporting existing local initiatives/convergence:
a. Focus on ethnic areas and local support local solutions. Community
organizations have shown resilience in the face of conflict and oppression to
provide services to their communities. These should be actively supported, not
side-lined, as they have legitimacy, greater understanding of local needs and as
such are more effective. This is particularly salient in relation to convergence
with local health and education systems, including cross-border aid. Many
ethnic organizations have been providing these services as the state has been
unable to. These local systems have been effective for many years and by
29
Please note that this paragraph is the latest addition.

14
bypassing them, it will undermine confidence in World Bank projects as well as
waste the knowledge, experience and competencies built up over years.
E. Land rights:
a. A broader understanding of the legal framework on land ownership and use, the
perpetrators of land grabbing, and the cultural caveats of the importance of land
and natural resources is a must. Without this, it will be too easy for the World
Bank to make the mistake of exacerbating the problem, by bringing more
powerful actors and money into already vulnerable areas. The question needs to
be asked: Will the World Bank become involved in technical assistance/policy
advice/financing of a program that seeks to achieve greater land tenure security,
especially for the poor?
F. Agriculture:
a. Focus on improving the status of smallholder farmers rather than plantation-
style corporate farming and agribusiness. 70% of the people in Myanmar work in
agriculture.
b. Provide support services to smallholder farms, including access to good credit.
c. Establish comprehensive rural finance systems to sustain farmers, especially
smallholders. This includes access to mid and long-term credit, land tenure and
abolition of arbitrary taxation and local monopolies in the supply of inputs.
Microfinance, while good for high frequency traders, stall holders, etc, is not
really a solution to the biggest credit problem in Myanmar, which is the wide-
scale indebtedness of the country's cultivators. Farmers need proper rural credit
– the sort that only needs to be repaid after harvest - not standard microfinance
loans that require weekly repayments.
d. Champion FPIC since most of the agricultural investments are in ethnic lands.
e. Ensure that agricultural investors can access long-term credit and make it a safe
& efficient savings vehicle.
f. Ensure that measures must contribute to increased capacity for farmers to
diversify, including extension into processing and marketing agriculture products.
G. Small and Medium Enterprises (SMEs):
a. Increase focus and commitment in providing resources and building capacity for
real SMEs (not big companies that are loosely classified as “SMEs” due to high
threshold values) such as providing access to credit and technical assistance.
Support should target the strengthening of and/or the establishment of locally
owned SMEs in all ethnic and vulnerable communities.
H. Energy:
a. The World Bank has indicated it will return to supporting hydropower
developments, even after the long years of controversy, failed and over-cost
projects. In Myanmar such projects are particularly problematic due to dam
projects’ role in exacerbating conflict and displacement; the linked problems of
corruption, poor construction quality and high seismicity and flood risk; chronic
lack of benefit sharing; etc. With its claimed dedication to poverty reduction,
fighting corruption and slightly more accountable processes compared to

15
Chinese, Indian or Burmese government funding mechanisms World Bank
involvement might not be all negative, but the World Bank has a very long way
indeed to go to prove itself not complicit.
b. Stay away from coal.
c. Green energy is the way forward.
d. How will the WB ensure that the energy produced will go to the local people and
not sold off to Thailand/China etc?
I. Private sector lending or contracting:
a. Provide more transparency in private sector lending and open processes up for
CSO consultations.
b. Employment generated through private sector projects are not automatically
benefitting the poorest of the poor because often these projects require high-
level skills; companies seldom invest in long-term trainings for skilled
employment.
c. Establish clear regulations for companies concerning financial transparency,
anticorruption as well as standards on business and human rights relating to
social responsibility, environment, gender and labor, so as not to strengthen and
further entrench cronies and former military leaders who now control most of
the private capital in the country. Refrain from loaning or extending cooperation
to private companies unless they comply with these regulations.
d. Ensure that contracts for World Bank Group projects incorporate compliance
with IFC and ILO core labor standards.
J. Telecommunications:
a. Assess land rights risks involved in building infrastructure.
b. Generate an effective policy on data privacy protection and apply this across all
projects. Consult a wide range of CSOs in developing this policy.
K. Road and infrastructure building:
a. Assess impacts not only on actual areas covered by projects, but also on areas
which, though not proximate, will likely be affected by the projects e.g. locations
where communities might be relocated
III. Questions on areas of work of the World Bank:
a. Will the WB support small hydropower projects?
b. Will the WB work in ethnic areas?
c. What are indicators used to determine “poorest of the poor” areas? Is this limited to
government information?
d. Will the WB be investing in hydropower? Dejan Ostojic and Kathan Shankar have
been noted to say that they are not currently planning to work on the hydropower
sector. However, hydropower is part of the energy mix according to the National
Energy Plan.
e. To what extent have changes to the WB safeguards impacted its qualified (January
2001) endorsement of the World Commission on Dams guidelines?
f. Will the WB support coal projects?
g. Will the Bank make an explicit commitment to convergence activities?

16
IV. List of IFI Watch’s prior recommendations that the World Bank has fully or partially
adopted:
a. Consultation: Moving from very short notice to two-week notice.
b. Documents: Moving from no provision of relevant documents when invitations
re sent to the provision of documents in both Myanmar and English language in
invitations.
c. Moving from asking participants to download documents to sending PDF
documents.
d. National Community Driven Development (NCCD): Strong and concrete reasons
and recommendation from Magway CSOs for the selection of township ---- these
were taken into account and incorporated.
e. Reasonable transportation and accommodation costs for one invited participant
per organization attending the consultation from outside the consultation
location is reimbursed upon submission of receipts now.

Document of
The World Bank
FOR OFFICIAL USE ONLY
Report No. 72458-MM
INTERNATIONAL DEVELOPMENT ASSOCIATION
AND
INTERNATIONAL FINANCE CORPORATION
INTERIM STRATEGY NOTE
FOR
THE REPUBLIC OF THE UNION OF MYANMAR
FOR THE PERIOD FY13-14
30 October 2012
Southeast Asia Country Management Unit
East Asia and Pacific Region
International Development Association
International Finance Corporation
This document has a restricted distribution and may be used by recipients only in the performance of
their official Duties. Its contents may not otherwise be disclosed without World Bank authorization.
PublicDisclosureAuthorizedPublicDisclosureAuthorizedPublicDisclosureAuthorizedPublicDisclosureAuthorizedPublicDisclosureAuthorizedPublicDisclosureAuthorizedPublicDisclosureAuthorizedPublicDisclosureAuthorized

CURRENCY EQUIVALENTS
(Exchange Rate Effective as of August 31, 2012)
Currency Unit = Myanmar Kyat (MMK)
US$1.00 = MMK 872
Fiscal Year: April 1 - March 31
ABBREVIATIONS AND ACRONYMS
ADB Asian Development Bank NMSP New Mon State Party
ASEAN Association of South-East Asian Nations PEFA Public Expenditure and Financial Accountability
Assessment
CAS Country Assistance Strategy PER Public Expenditure Review
ICA Investment Climate Assessment PFM Public Financial Management
ICT Information and communications PGAE Partnership Group on Aid Effectiveness
technology
IDA International Development Association QSEM Qualitative Social and Economic Monitoring
IFC International Finance Corporation Sim Social Impact Monitoring
IMF International Monetary Fund SOE State-owned enterprise
ISN Interim Strategy Note SPF State and Peacebuilding Fund
KIO Kachin Independence Organization UN United Nations
KNPP Karenni National Progressive Party UNDP United Nations Development Program
KNU Karen National Union UNFPA United Nations Fund for Population Activities
LIFT Livelihoods and Food Security Trust Fund UNICEF United Nations Children's Fund
MICS Multiple Indicator Cluster Survey UNODC United Nations Office on Drugs and Crime
MIGA Multilateral Investment Guarantee Agency UWSA United Wa State Army
MMK Myanmar Kyat WBG World Bank Group
NGO Non-governmental organization WDR World Development Report
NLD National League for Democracy WFP World Food Programme
IDA IFC
Regional Vice President Pamela Cox Regional Vice President Karin Finkelston
Country Director Annette Dixon EAP Regional Director Sergio Pimenta
Country Manager Kanthan Shankar Regional Manager Mekong Simon Andrews
Task Manager Nikolas Win Myint Task Manager Charles Schneider
NGO on-overmenal oganzaton WR Wrld eveopmet Rpor

ACKNOWLEDGMENTS
The following World Bank Group staffcontributedto thepreparationofthis Interim Strategy
Note: Marialonata,Luc Lecuit,James Seward,Mathew Verghis, JuliaFraser,LarsSondergaard,
CharlesSchneider,Sofia Busch,Xuemei Guo, NicholasMarwell,ShalindraDilhanMylvaganam,
Nitaya Chatnantawej,Khwima Nthara,MarkusKostner,Asmeen Khan, Pamornrat
Tansanguanwong,Vikram Raghavan,PaavoEliste, Tenzin Norbhu, ShabihMohib, Robert
Taliercio,Edith Bowles, Anna Elicano, ThawdarSann, andKyaw HtutAung.

THE REPUBLIC OF THE UNION OF MYANMAR
INTERIM STRATEGY NOTE
TABLE OF CONTENTS
I. INTRODUCTION AND RATIONALE ......................................................................... 1
II. COUNTRY CONTEXT AND KEY DEVELOPMENT CHALLENGES............... 1
Recent Political and Security Developments ............................................. 1
Recent Economic Developments.................................... ................. 3
Poverty and Human Development..................................... ............ 5
Governance ............................................................... 8
Myanmar's Development Strategy .................................................... 9
III. REVIEW OF THE WBG'S PAST ENGAGEMENT........................................... 11
IV. WBG INTERIM STRATEGY ..................................... 11
Strategic Foundations ....................................................... 11
Objectives and Programs ..................................................... 12
Implementing the ISN....................................................... 18
Partnerships.. ............................................................ 19
V. RISKS ........................................................... 20
Annex 1: Myanmar at a Glance ......................................... 22
Annex 2: Myanmar Indicative Activities FY13-14 ..................................... 24
Annex 3: Development Coordination Matrix (preliminary, as of September 2012) . ............. 25
Annex 4: Summary of Consultations .............................................. 26
Annex 5: Map of Myanmar ................................................... 27
Boxes
Box 1: Myanmar in History .............. . ....................... ......... 2
Box 2: Myanmar's Agricultural Potential ................ 6....................... 6
Box 3: Experiences in Development Cooperation ............................ ..... 10

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