Joint Open Letter: Seeking Clarification Regarding Sand Exports

Released in October 2016

Your Excellency Mr. Suy Sem, Minister of Mines and Energy,

We, the undersigned civil society organizations (CSOs), are writing to request clarification regarding sand exported overseas by Cambodia during the period 2007 to 2015. His Excellency Dith Tina, Secretary of State and spokesman for the Ministry of Mines and Energy (the MME) has been quoted as saying that Cambodia’s global sand exports amounted to 10,669,212 cubic meters (just over 17 million tons) between 2007 and 2015. However, the only official export data issued to date by the Cambodian government in relation to sand exports, from the Ministry of Commerce, only discloses sand exports to Singapore for the same period, totaling about 2.8 million tons. The Cambodian government is yet to explain to which other countries it is exporting sand to, or at what price this sand is being sold for.

Specifically, we ask the following questions: Will the MME, the MoC or the Ministry of Economy and Finance (MoEF)’s Department of Customs and Excise disclose the countries Cambodia has exported these 17 million tons of sand to, as well as the value of these exports, per country and per year? Secondly, can any Ministry disclose what percentage of this figure of overall exports of sand is from freshwater sources (such as creeks, rivers, lakes, etc.) and what percentage is sea sand (i.e. from coastal estuaries)?

According to data from the MoC, Cambodia exported a total of about 2.8 million tons of sand, valued at just over 5.5 million USD, to Singapore between 2007 and 2015. However, the United Nations’ Commodity Trade Statistics Database, which mirrors data from the Singaporean government’s department of trade statistics, shows figures of 72.8 million tons of Cambodian sand imported into Singapore. Can the MME, the MoC or the MoEF explain this gap of over 69.9 million tons of sand, valued at 746.5 million USD, between the amount of sand the Cambodian government reports having exported to Singapore, and the amount of sand the Singaporean government reports having imported from Cambodia?

We are deeply concerned that the livelihoods and human rights of affected communities continue to be adversely affected by sand dredging in Cambodia.

Your letter of 17 June 2016 stated that you welcome requests by the public wishing to access documents relevant to sand mining in Koh Kong, such as Environmental Impact Assessments (EIAs) and hydrological reports, etc. We appreciate your stated commitment to transparency, and we request that you follow through on this commitment by providing the information requested in this letter, in full. More generally, we strongly urge you to make all EIAs and hydrological reports in relation to sand dredging publicly available as soon as possible, to enable scrutiny by members of the public, affected communities and civil society. Specifically, we request that the MME makes these documents available via its own website, or if not possible, that it digitizes them and sends them to the undersigned CSOs. Such a move would demonstrate the Cambodian government's commitment to inclusive, sustainable development, as outlined in the 2030 Agenda for Sustainable Development.

Sand dredging, even when conducted with good intentions, can have a significant impact on local communities and the natural environment. We, the undersigned CSOs, are deeply concerned that the livelihoods and human rights of affected communities continue to be adversely affected by sand dredging in Cambodia. Further, we are concerned about the long-term impacts of sand dredging on Cambodia’s natural environment. We note the decisions of the governments of Vietnam, Indonesia and Malaysia to ban or restrict sand exports to Singapore due to environmental concerns, and we urge Your Excellency to consider instituting a similar ban or restriction in Cambodia, in the interests of Cambodia’s long-term sustainable development.

We remain willing and available to work with the Cambodian government to protect Cambodia’s natural resources, as well as the livelihoods and human rights of people living in affected communities, and in the pursuit of Cambodia’s sustainable development. We appreciate your consideration of our requests.

Yours sincerely

Affiliated Network for Social Accountability Cambodia (ANSA)
Boeung Chhouk Community (Phnom Penh)
Boeung Kak Community (Phnom Penh)
Boeung Trabek Community (Phnom Penh)
Borei Keila Community (Phnom Penh)
CamASEAN Youth's Future (CamAsean)
Cambodia Development People Life Association
Cambodia Indigenous People Organization (CIPO)
Cambodia Indigenous Youth Association (CIYA)
Cambodian Center for Human Rights (CCHR)
Cambodian Human Rights Action Committee (CHRAC)
Cambodian Human Rights and Development Association (ADHOC)
Cambodian League for the Promotion & Defense of Human Rights (LICADHO)
Cambodian Youth Network (CYN)
Coalition for Integrity & Social Accountability (CISA)
Coalition of Cambodian Farmer Community (CCFC)
Community Legal Education Center (CLEC)
Community Peace-Building Network (CPN)
Dork Por Community (Takeo)
Equitable Cambodia (EC)
Former Boeung Kak Women Network Community (Phnom Penh)
Housing Rights Task Force (HRTF)
Independent Monk Network for Social Justice (IMNSI)
Indigenous Youth (Preah Vihear)
Indradevi Association (IDA)
Khmer Youth Association (KYA)
Koh Srolao Community (Koh Kong)
Kuoy Ethnic Community (Preah Vihear)
Land Community, I Village (Preah Sihanouk)
Land Community, Prek Chik Village (Koh Kong)
Land community, Traeng Trayueng Commune (Kampong Speu)
Land Conflict Community, Krenh Village (Pailin)
Land Conflict Community, Krous Village (Battambang)
Land Conflict Community, Skun Village (Siem Reap)
Lor Peang community (Kampong Chhnang)
Mother Nature (MN)
Not One More (N1M)
People Improvement Organization (PIO)
Phnom Bat Community (Kandal)
Ponlok Khmer
Railway Station, Toul Sangkae A community (Phnom Penh)
Samkum Teang Tnaut (STT)
SOS International AirPort Community (Phnom Penh)
Transparency International Cambodia (TIC)
Youth for Peace (YFP)
Youth Resource Development Program (YRDP)

For a fully-referenced copy of this letter, please see the attached file.

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