Memorandum submitted by Christian Aid
· Christian Aid has been working in Afghanistan since 1986 and has built up considerable expertise on rural development and civil society mobilisation through its work with Afghan partner NGOs in western Afghanistan.
· There have been many achievements of the engagement by the international community in Afghanistan since 2001. However, this progress is now threatened by the growing Taliban-led insurgency, weak government capacity, a lack of protection of human rights, and relatively poor co-ordination of aid spending by international donors.
· Afghanistan remains the poorest state in Asia. Efforts to tackle poverty in the coming years will be complicated by the ongoing conflict between insurgency groups on one side and the Government of Afghanistan (GoA) and NATO/US forces on the other. This is affecting the overall climate for reconstruction; the ideological dimension to the conflict will also endanger the ability of Western aid agencies to work across 'the frontline' and deliver assistance to the poorest communities.
· DFID needs to work with other UK government departments to mitigate any divergences between military and development objectives, for instance by ensuring that international humanitarian law is upheld during UK military operations and that all avenues for a peaceful solution to the conflict are explored.
· The significant injection of international aid into Afghanistan since 2001 has brought many benefits to the population, including new infrastructure and expanded public services. However, donors and GoA also need to pay attention to the large, current gap between domestic revenues and public expenditure. A concerted effort is required to increase independent GoA capacity and revenues so that when aid flows eventually decline, these gains can be safeguarded.
· While Christian Aid supports DFID's existing policy of budgetary support, we believe that more flexibility is required in the way it is operated. This would enable the Department to respond to humanitarian emergencies or other pressing challenges, such as the under-development of Afghan civil society.
· We would caution against a 'knee-jerk' response by DFID to the current problem of opium poppy cultivation. Its focus should remain on tackling the root causes of production, notably the lack of alternative livelihood options for farmers. This said, there is considerable scope for improvement in DFID's existing alternative livelihoods 'package' in Afghanistan: it should concentrate above all on strengthening the legal agricultural sector in opium-producing provinces - since agriculture is the main source of employment for Afghans - as well as raising overall living standards.
· We would call on the UK Government to undertake a full review of the mandate for its Provincial Reconstruction Teams (PRTs) in Afghanistan. We remain concerned by the ongoing involvement of the military in aid delivery - the development value of these projects is unproven and the use of the military in this way continues to have an impact on the perceived neutrality of humanitarian and development aid agencies. We believe a new approach is needed by the UK which re-affirms the importance of distinct roles for military and civilian actors for achieving long-term stabilisation in conflict environments.
1. Christian Aid in Afghanistan
1.1 Christian Aid started working with Afghan partner NGOs in 1986 and established a representation office in the country in 1997 during the period of Taliban rule. We currently work with 16 organisations in Ghor, Farah, Herat, Badghis and Faryab provinces (in the west and north-west of the country) on rural development and civil society mobilisation. In recent years Christian Aid has also actively contributed to emergency responses, including the 2001/02 humanitarian crisis and the 2006 drought.
1.2 Christian Aid's work is focused on the following thematic areas: (i) rights education and civil society strengthening; (ii) rural livelihoods and livelihoods-related skills development; (iii) disaster risk reduction; and (iv) the legal and social protection of women. Our programme has three cross-cutting issues, which are integrated into each of the four themes. These are: gender equality, HIV/AIDS and environmental sustainability and climate change. The country budget for 2007-08 is $1.6 million.
1.3 Our strength lies in the long-term relationships which we have built with Afghan communities through our partners and our support for community and civil society participation in development strategies at a variety of levels. For example, in 2005/06 we facilitated the setting up of a mechanism through which civil society groups could input to the discussions on the National Development Strategy. One of our partners in western Afghanistan has been working to establish democratically-elected 'shuras' (village committees) which involve participation by all members of the community.
2. Overall assessment of situation
2.1 There have been many achievements resulting from the engagement of the international community in Afghanistan since 2001. These include the new Constitution, the 2004 and 2005 elections, the revival of education, progress in rebuilding war-damaged infrastructure and the return of approximately four million refugees to the country. However, this progress is now being undermined by a range of new threats to the Afghan state, some of which have their roots in policy mistakes of the 2001-05 years. These threats include the growing insurgency, which has now spread to provinces in the west, north and centre of Afghanistan, the high levels of corruption within the government and police, the burgeoning drugs trade and the problem of weak capacity in public institutions.
2.2 Afghanistan is still the poorest state in Asia, with over half of the population living below the poverty line. One in nine women is likely to die during their lifetime from pregnancy-related causes and some 40% of the rural population suffer recurring food shortages each year, or are at risk of them. Limited access to a clean water supply, healthcare, electricity, housing and employment remain pressing problems.
2.3 The current insecurity - caused by a mix of the Taliban-led insurgency, the ongoing activities of illegal militias tied to provincial warlords or factional commanders, and general criminality - is having a debilitating effect on the environment for development. The direct attacks on aid workers and other development actors is one manifestation of the problem and has curtailed the mobility of aid staff. For example, since 2003 over 70 NGO staff have been murdered in attacks by armed groups. Another is the general deterioration in the business and investment climate caused by the actual or perceived insecurity. This is now affecting provinces, such as Herat, which were previously considered more stable.
2.4 Since 2001 there has been progress in improving the human rights situation in Afghanistan. Prominent examples would be the lifting of the Taliban regime's restrictions on girls' education and the steady growth of an independent media. On the other hand, the intimidatory power of warlords and their proxies remains strong in most provinces and the notion that the Government of Afghanistan (GoA) is interested in protecting ordinary citizens from abuses of power was damaged by the recent election of former warlords to Parliament, as well as by the passing this year of the Amnesty Law. (The latter will make it difficult for those responsible for gross abuses of human rights during the war years (1978-2001) to be held to account for their crimes.) In the South the closure of many schools after attacks or the threat of attack by the Taliban, together with the assassination of teachers and many women holding public office, have hampered progress on education and women's rights.
3. Conflict between security and development agendas
[See also section 6]
3.1 There is a significant conflict between these agendas for donors in Afghanistan, including DFID. The original peace-keeping and stabilisation role for NATO/ISAF was altered last year by the movement of troops to the south and the subsequent offensive against insurgency groups. The more NATO becomes involved as a direct party to the conflict, the more difficult it will be for implementing agencies viewed as pro-Western or pro-GoA - including those funded by DFID - to deliver aid to communities lying beyond 'the frontline'. Some international NGOs may be able to negotiate humanitarian access with different political factions, as happened during the Taliban period, but the ideological opposition to Western involvement in some quarters is likely to place limits on this.
3.2 In Afghanistan, DFID's development objectives may clash with short-term military objectives and it needs to work in partnership with other government departments to mitigate any divergences. Firstly, it should work to ensure that UK and international military forces in the country fully respect international humanitarian law. While we abhor the deliberate targeting of civilians by insurgency groups, we are also concerned by the rising number of civilians killed as a result of NATO and US air-strikes and other military operations. (Civilian casualties resulting from NATO/US operations have risen this year despite assurances at the end of 2006 that greater efforts would be made to minimise them.)
3.3 Secondly, the Government as a whole should explore new avenues for tackling the insurgency beyond the purely military option. It should encourage GoA to begin peace talks with insurgency groups, as was recently proposed in a motion by the Upper House of the Afghan Parliament. This could build on the progress made at the Peace Jirga held in Kabul in August between Afghan and Pakistani tribal leaders and government officials and offer a way out of the current impasse.
3.4 Spending on the security sector in Afghanistan easily outstrips spending on health, education or rural livelihoods (taken individually). According to the World Bank, the security sector accounted for 39% of total public expenditures or $1.33 billion in 2004/05. Proposals are currently on the table for a rise in police numbers to 82,000, even though the Afghanistan Compact envisaged a maximum size of 62,000. Building up the strength and effectiveness of the Afghan army and police is an important objective in view of the present chronic insecurity. However, donors also need to avoid creating structures that could become unaffordable in future (see also section 5).
3.5 We believe that donor spending on the Afghan National Army and Police should not be increased further until there is more evidence of improved ANA and ANP quality - measured in terms of their responsiveness to citizens, non-corrupt practices and an ability to manage effectively a greater proportion of policing and security tasks. A proper balance also needs to be found between spending in these sectors and other, currently under-funded areas, such as the justice sector and agriculture. An example of the existing problems in the criminal justice system was illustrated by a recent survey undertaken by a Christian Aid partner on the issue of domestic violence in western Afghanistan. In only 10% of cases of chronic domestic violence had women sought help from the police and courts.
3.6 One way of ensuring a more consistent approach to donor funding within the security sector would be to end the current policy of having 'lead donors' for each 'pillar' or sub-sector. This has led to a wide divergence in available funds for the different pillars. Instead we believe that funding for the criminal justice elements of the security sector (i.e. police, counter-narcotics and justice) should be brought under a single roof and underpinned by a single, GoA-led strategy.
4. Budgetary support
4.1 In general, we support DFID's decision to allocate the largest share of UK aid to the Afghan Government, including through the Afghanistan Reconstruction Trust Fund. Too much aid is currently spent by other donors outside the direct control of the Government through the External Budget - as much as three-quarters of the total. When decisions on aid spending are taken out of the hands of the Government, this reduces the extent of downward accountability to citizens and Parliament. In the past it has also undermined the Afghan Government's development strategies because spending has often been poorly co-ordinated.
4.2 However, there are a number of challenges that DFID faces if it is to make its current policy of budgetary support successful in the long term. These relate to the following issues: i) flexibility, ii) sustainability, iii) government capacity and iv) visibility.
4.3 i) UK aid would be more effective if spending decisions were made more flexible. For example, a joint UN-GoA appeal was launched in July 2006 to raise funds from the international community to combat the severe drought affecting the country. In November, DFID announced it would allocate £1 million to the Ministry of Rural Rehabilitation and Development for drought-relief activities. However, the capacity of this Ministry to respond to humanitarian emergencies such as this is still low. A better approach would have been to allocate half of the funds to the relevant UN agency, the World Food Programme, and half to the Government - immediately after the launch of the appeal.
4.4 At present DFID funding for women's rights organisations, the media and other civil society organisations is very limited, with the FCO generally offering more assistance in this field. By supporting small projects of this type DFID could make an important contribution to strengthening Afghan civil society and enable it to deal with some of the serious human rights challenges mentioned in 2.4.
4.5 ii) The injection of aid into the Afghan economy post-2001 has brought significant benefits to the country. However, at some point in the future aid flows to Afghanistan will decline. To safeguard the development gains of the last six years it is vitally important that donors focus now on measures to improve the fiscal sustainability of the Afghan State in anticipation of this. The high costs of security sector expenditures have already been highlighted above. The donor-funded elements of health services and the National Solidarity Programme are further examples of programmes that would struggle to survive without external support. Last year the World Bank reported that domestic revenues only accounted for 4.5% of Afghan GDP, which was only one quarter of the average for low-incomes states. To close the large gap between recurrent expenditures and domestic revenues will require a concerted effort to expand the latter, so that a large fiscal deficit is avoided when aid flows eventually decline.
4.6 We believe DFID should play a lead role in developing and co-ordinating a donor and GoA strategy to tackle this problem of low domestic revenues. Some of the specific policy issues it should look at are:
· Promoting the expansion of Afghan services and industries in the formal sector in order to increase tax revenues;
· Reviewing the impact of existing external tariff policies on customs revenues (e.g. tariffs on imports are low by regional standards);
· Expanding the remit for government tax authorities and improving tax law enforcement in the business sector;
· Reassessing the current policy which restricts the ability of the Afghan Central Bank to lend to the Government;
4.7 iii) A further problem is the ongoing lack of capacity within Afghan institutions, particularly for service delivery - a key tool for poverty reduction. Surprisingly, the Afghanistan Compact paid very little attention to this issue. It is clear however that provincial and district governments continue to face a range of problems, such as low staffing levels and a chronic shortage of funds for 'non-salary' expenditures, including textbooks and furniture for schools, hospital maintenance, and water and sanitation facilities. Primary healthcare services are by and large still being delivered by international NGOs, although there have been improvements in the level of care. DFID ought to press for new targets to be included in future strategies which focus directly on measures to improve government capacity in frontline public services.
4.8 iv) When we questioned our partners regarding UK assistance, a common response was that they had had no direct experience of DFID's work in Afghanistan, for example in the form of a funding relationship or a strong presence in their province. Obviously, UK aid may sometimes be difficult to identify since it has passed through implementing agencies or GoA. But their observation does suggest DFID could benefit from having a more active presence in provinces where its aid is spent, whether it be in terms of more community outreach work or improved monitoring of aid spending.
5.1 The counter-narcotics policies being pursued by GoA and international donors is suffering from a crisis of credibility. This is due to the year-on-year increases in the cultivation of opium poppy being reported by the UN Office on Drugs and Crime and the continuing high level of opium and heroin exports from Afghanistan.
5.2 We would caution the Government against 'knee-jerk' reactions to this admittedly worrying development. The focus on alternative livelihoods (AL) for farmers and interdiction measures higher up the supply chain must be maintained, although some revisions to the AL strategy should also be considered (see 5.5 and 5.6). The appeal of more widespread eradication as a policy response is not based on any accurate understanding of the causes of the drugs trade in Afghanistan (see next section). Furthermore, experience from Latin America - and increasingly in Afghanistan - shows that if eradication happens in isolation from other policies, such as the building up of the rule of law and economic development, it will not succeed and can engender social unrest and increased support for opposition groups.
5.3 The causes of the drugs trade in Afghanistan are various and include rural poverty, a harsh climate (which makes it difficult to grow other crops), government and police corruption, lax border controls and a strong international market for heroin. In a recent survey conducted by UNODC of more than 300 village headmen in poppy-growing areas the main reasons given for the growing of poppy were economic in nature: in order of their frequency of mention, they were i) poverty reduction, ii) the financial attractiveness of opium and iii) the possibility of obtaining immediate credit ('salaam') by selling the future opium harvest to traders.
5.4 Farmers grow opium poppy because it is a profitable and predictable crop and because there are currently few alternative sources of income in rural communities. The most effective method of dealing with the trade at this level would be to expand rural development programmes in provinces and districts where poppy production is highest or where there is a risk of production. Such interventions should be broad-based and aimed at developing the economic potential of the whole province, including measures to improve the employment, health and education levels of the population. This will be more effective than efforts to compensate individual farmers.
5.5 Despite the high levels of investment by the UK in AL - at least from 2005 - the bulk of money earmarked for AL is being spent on programmes which either provide employment for public works-type construction projects (e.g. National Rural Access Programme) or offer micro-credit facilities (e.g. MISFA). These programmes are useful but do not in themselves address the key cause of the problem, namely the weakness of the agricultural sector. Agriculture employs an estimated 80% of the population in Afghanistan and developing a strong (legal) agricultural sector is crucial if poppy production is to be reduced.
5.6 DFID should re-engage with GoA and donors on this issue and consider supporting new policies on agriculture in Afghanistan, including:
· Improving irrigation and water resource management;
· Achieving food security through expanded cereal production;
· Introducing a formalised credit system and extension services for farmers;
· Building the export capacity of perennial horticulture (e.g. fruits, nuts and vines);
· Improving marketing by 'off-farm' rural enterprises, for example by promoting co-operatives;
· Increasing agricultural research capacity and encouraging technology transfer.
5.7 DFID should also undertake a review of its policy of allocating aid to the Counter-Narcotics Trust Fund (CNTF), which has proved an ineffective tool for disbursing funds for AL, especially via NGOs. It should withdraw unspent funds from the CNTF and reallocate these funds as well as future ones for AL, in the line with the type of broad-based intervention mentioned above.
6. Military involvement in aid delivery
6.1 Christian Aid continues to have concerns regarding the involvement of the British Army in aid projects in Afghanistan. These relate to four aspects of existing Provincial Reconstruction Team (PRT) projects: the impact on 'humanitarian space', their unproven development value, the risk of security objectives dominating their conception, and the lack of scrutiny by Parliament of this type of aid spending. (An additional problem is that they distract UK and NATO troops from their core mission of stabilisation and expanding the capacity of Afghan security forces.) For these reasons we would call for a review by DFID of its policy of funding Quick Impact Projects (QIPs).
6.2 Although the current focus of this debate is Helmand, the importance of protecting 'humanitarian space' has relevance for all provinces of Afghanistan, where there is a continuing threat to the safety of Afghan and international aid agency staff. This threat is, in part, caused by the association of these agencies with the military and the Afghan Government, which can be exacerbated if the military is involved in aid delivery.
6.3 Concerns about the development benefits of QIPs were raised in a joint donor evaluation report in 2005, to which the UK was a party. It stated that military aid projects 'could have been delivered more cheaply and efficiently by other aid providers' and that 'time pressure for delivery during short assignments promotes a "just do it" approach with limited concern for long-term impacts and sustainability.'
6.4 In the initial stages of the Helmand deployment (spring 2006) it appears that there was insufficient oversight by DFID of aid spent by the military in the province. According to some DFID sources, it was not until six months after the deployment that the inter-departmental committee in charge of monitoring QIPs in Helmand was functioning effectively - and in the first two months there was apparently no monitoring at all. During this period a significant amount of aid was used for QIPs with security objectives, such as establishing police posts and making political assessments. This spending should surely have been made from the Ministry of Defence's budget, not by DFID.
6.5 DFID should be more transparent about the way aid is spent in Helmand; if there are trade-offs between poverty reduction and military objectives, these must be reported openly to Parliament and the public. A public debate is probably required on the admissibility of these types of projects under current rules for ODA spending.
6.6 In view of the problems highlighted here, our recommendation is that DFID should suspend its funding of QIPs in Afghanistan until a full review has been conducted of their development value. The Government should also undertake a review of the existing PRT mandate in Afghanistan. It should progress towards a situation where the development tasks of PRTs are separated from the military tasks. In areas where greater stability exists, NATO PRTs should hand over all responsibility for reconstruction and development to civilian bodies. This would be in line with the UN's guidelines on the use of military assets in complex emergencies as well as DFID's Humanitarian Policy.  Both emphasise that military involvement in humanitarian situations should be a 'last resort' (ie. only when no civilian alternative exists) and time-bound.
SUMMARY OF RECOMMENDATIONS
1. In light of the growing number of civilian casualties in Afghanistan, and in order to safeguard previous development gains, DFID should work jointly with MoD and FCO to ensure stronger measures are taken to minimise civilian deaths from NATO/US airstrikes and other military operations.
2. HMG should explore with GoA new avenues for bringing about a peaceful resolution to the existing conflict, including through talks with insurgency groups.
3. Donor spending should not increase further for the Afghan National Army and Police until there is more evidence of quality improvements. A better balance must be sought between ANA and ANP funding and that for under-funded sectors, such as agriculture and justice.
4. The practice of nominating 'lead donors' for different pillars within the security sector should be ended; instead a single fund should established for spending on all elements relating to criminal justice issues, which is underpinned by a single, GoA-led strategy - this would encourage better co-ordination on these issues and reduce existing spending disparities.
5. DFID should retain a greater degree of flexibility in its annual budget to allow it to respond to humanitarian emergencies and other pressing issues, such as civil society development.
6. Donors should address the worrying issue of GoA's fiscal deficit. DFID should take a lead in developing and co-ordinating a new strategy to tackle the problem of low domestic revenues.
7. In view of the continuing weak capacity of GoA, particularly on service delivery at the provincial level, DFID should press for new targets to be included in future GoA/donor strategies that focus on enhancing this capacity.
8. DFID should consider taking steps to increase its visibility in those provinces of Afghanistan where UK aid is spent.
9. DFID should maintain its focus on alternative livelihoods as a solution to the opium trade. However, it should give enhanced support to broad-based economic development strategies in provinces where production is highest. The primary focus should be on agriculture, in view of the country's dependence on this sector, but improving health, education and general living standards are also important.
10. DFID should withdraw its funds from the Counter-narcotics Trust Fund and reallocate them to support broader rural development programmes.
11. DFID should suspend its funding of QIPs until a full review has been conducted of their development value. HMG (ie. DFID, MoD and FCO) should also undertake a review of the existing PRT mandate in Afghanistan. For the Helmand PRT, it should consider introducing a clearer separation between the development and military tasks of PRTs. And in areas where security has improved, it should argue for NATO PRTs to steadily withdraw from engaging in reconstruction or development work, in line with existing UN and DFID guidelines.
 One Herati partner reports that the recent bomb blasts in the city, combined with the murder of local politicians and the spate of kidnappings of businessmen, have reduced people's willingness to invest in the city.
 For convenience, we refer to 'NATO' from this point on.
 Cf. Articles 51, 52 and 57 of the 1977 Additional Protocol to the Geneva Conventions regarding the protection of civilians in wartime.
 Although exact figures on civilian casualties do not exist, the Afghanistan NGO Safety Office (ANSO) recently attempted a calculation for the January to (end of) June period, based on the incident reports it receives from civilian and military sources. It found that in this period there had been 678 conflict-related civilian deaths; 331 had been caused by the activities of international military forces. ANSO Quarterly Data Report, Second Quarter, 2007.
 DFID's particular contribution could relate to civic aspects of peace-building.
 p.xii, Cops or Robbers? The Struggle to Reform the Afghan National Police, Afghanistan Research & Evaluation Unit, July 2007
 The survey was conducted in five districts of Herat province.
 The exact proportion should be determined by the particular circumstances of each budgeting year and also an assessment of the importance of needs lying elsewhere - however the current split of two-thirds to one-third seems sensible.
 For instance, DFID missed an opportunity in 2006 to fund an initiative by Afghan and international NGOs to monitor the new National Development Strategy.
 During the period of transition to fiscal sustainability, we believe donors should maintain existing aid commitments - with the possible exception of the security sector.
 p.32, Afghanistan: Managing Public Finances for Development, World Bank, 2006.
 In the three years after 2001 the gap between recurrent expenditures and domestic revenues more than tripled as the influx of aid money made possible new spending commitments in the public sector. Ibid, p.16
 The World Bank reports that in 2004/05 only 30% of non-salary expenditures were made in the provinces, as opposed to Kabul. p.15, Managing Public Finances
 Afghanistan Farmers' Intentions Survey 2003/2004, p.16
 An example of the benefits of a broad-based approach is illustrated by a recent comment from one of our partners. They said that if more health clinics were established in rural districts, people would save money because they would not have to pay the cost of travel to the nearest city for medical treatment. With treatment available locally, they would have more funds to pay for the transportation of their fruit and vegetable crops to nearby markets, therefore offering an alternative source of income to poppy.
 An average of £45 million is being allocated annually for AL programmes.
 Taken from Rebuilding Afghanistan's Agricultural Sector: Common Recommendations Across NGOs and Governments, July 2007, Canadian Agri-Food and Trade Service
 These projects vary in nature. Some relate purely to force protection or improving the security and governance environment (e.g. establishing police posts or conducting political assessments); some relate to reconstruction (e.g. building roads, health clinics, schools and wells); and some to development (e.g. medical and veterinary services, materials for schools and small-scale community development projects). There are also hybrid QIPs that do not fit into a single category, such as 'goodwill' aid handouts by the military, which may serve both force protection and humanitarian objectives.
 A Joint Evaluation: Humanitarian and Reconstruction Assistance to Afghanistan from Denmark, Ireland, Netherlands, Sweden and UK, Danish International Development Agency (Danida), 2005
 Based in Helmand and composed of officials from MoD, DFID and FCO.
 There may be a need to strengthen certain international guidelines - such as the OECD DAC's criteria on ODA for the security sector - to make the rules for this type of spending in Afghanistan clearer.
 Cf. 2003 MCDA Guidelines and DFID's 2006 Humanitarian Policy.