- International environmental NGOs working in Madagascar assume a relatively narrow role of supporting local conservation and development in line with government strategy.
- The nature of the NGOs’ legal relationship with the Malagasy government, which has close ties to the extractive industries, and the restrictions that come with international funding make it difficult for them to take a broader role or push for systemic environmental reforms.
- The result, some critics say, is that international NGOs fail to address the country’s most serious conservation challenges.
- Homegrown civil society groups have more room to operate in Madagascar and do some of the most important conservation work.
ANTANANARIVO, Madagascar — Madagascar’s natural resources are under threat. Local people use some for food, fuel and shelter, but foreign capital drives the most intense exploitation. Gem dealers oversee the destruction of wide swaths of brush in the south and forests in the east. Multinational mining companies target nickel, ilmenite and oil. Industrial trawlers vacuum up much of the fish and shrimp that villagers along the west coast rely on for food and income. And the local activists who challenge all this are frequently imprisoned.
Yet international conservation NGOs remain largely silent about commercial resource extraction, focusing their work at the community level. For example, the Wildlife Conservation Society (WCS) works in and around the rainforests of northeastern Madagascar where precious rosewood has been heavily and illegally logged for the past decade, but aside from issuing the occasional press release and signing a few petitions, the group has barely commented on the logging in public.
“We played it safe,” Alison Clausen, WCS’s former country director in Madagascar, told Mongabay. WCS has focused on scientific research, local conservation work, and patrolling protected areas rather than lobbying the government to stop the logging, Clausen said. “We didn’t lead a strong criticism of the government.”
Engaging in such criticism would have put the New York-based conservation group at risk of being kicked out of the country. International NGOs can work in Madagascar only with the government’s permission, and the government is closely linked with the extractive industries, including the illegal trade in precious timber. This makes natural resources a touchy subject. Journalists witness the sensitivity firsthand, in Madagascar as elsewhere. Most staff members at big international NGOs, the so-called BINGOs, won’t speak on the record about extraction issues in Madagascar. Though this might be prudent in individual cases, the cumulative effect is an eerie silence.
“In a way, such BINGOs and other related structures work here without really being here (in terms of involvement) and I think things won’t really change as long as they maintain this kind of detachment (or voluntary disconnection) from local realities,” Ketakandriana Rafitoson, executive director of Transparency International–Initiative Madagascar, wrote in an email to Mongabay. “[I]f they deny themselves the right to act accordingly and really ‘fight’ for what matters to them, they are just complicit — albeit indirectly — in the perpetration of well-known environmental malpractices.”
NGO leaders respond to such criticism by pointing out that their organizations’ role is to support local conservation and development, in line with government strategy, and to provide policy expertise at the invitation of the government. They are consigned to this relatively narrow role largely because of the nature of their legal relationship with the Malagasy government and the restrictions that come with international funding. The result, some critics say, is that despite the soaring language of their public communications and the ambitious targets set out in their grant proposals, the most serious conservation challenges remain outside of their remit.
Agreeing to a straitjacket
Madagascar’s dazzling biodiversity — it has “more genetic information per surface unit” than anywhere else, as one paper put it — draws in conservation groups from across the world. Yet there’s little they can do when well-funded businesses or trafficking networks threaten the country’s environment.
The most straightforward reason that leaders of international NGOs do not speak out is that they want to keep their “seat” in the country. They are required to apply for and operate under an accord de siège, an agreement with the Ministry of Foreign Affairs that declares that the government has “a permanent right to control the progress of the various works and actions as well as the technical and financial management of all the personnel resources made available to [NGO] projects,” according to a template accord de siège obtained by Mongabay.
The language of the agreement makes the power dynamics clear. “[T]he whole spirit of the accord de siège is in general that [Madagascar’s government] controls NGOs,” Nanie Ratsifandrihamanana, country director for the international NGO WWF, told Mongabay in an email.
The accord de siège does not explicitly prevent lobbying or political activity, but it establishes NGOs as partners of the government, requiring that they “collaborate” with ministries to ensure their programs fit with government priorities. NGOs must renew their accord de siège every two years and submit regular reports on projects and expenditures.
In practice, collaborating with the government can mean partnering with resource extractors. Some bureaucrats and elected representatives benefit from business activities through official channels, such as taxes and permit fees that go to government ministries. But others benefit through bribes, kickbacks, and even sometimes direct involvement in the trade. “Madagascar has entered a phase of ‘criminalization of the state’ in which … the border between the illegal and the legal has become blurred,” wrote a researcher from the Institut Français des Relations Internationales, a Paris-based think tank, with regard to the extractive industries in Madagascar, in a 2017 report submitted to France’s ministry of defense.
The close ties between government and industry make it difficult for NGOs to critique ill-advised projects or address illicit resource extraction, said Ndranto Razakamanarina, president of Alliance Voahary Gasy (AVG), a consortium of environmental civil society groups in Madagascar. “If [NGOs] do advocacy, they are afraid of [losing] their accord de siège,” he told Mongabay. “They will be thrown out of Madagascar. We, the Malagasy, we will only be thrown in prison, but they can’t exclude us from the country.”
So far, the government has not removed any conservation groups from the country and rarely if ever makes explicit threats to do so. It usually opts to take less drastic action against NGOs, such as simply voicing displeasure or not offering them management of a desirable protected area, said WWF’s Ratsifandrihamanana. When WWF started a petition to stop rosewood logging in 2009, members of the government called the WWF office in a “very angry” mood, she told Mongabay.
The lopsided relationship is not unique to Madagascar. Many countries in the Global South require foreign organizations to sign such agreements, and Russia and China have stringent requirements for foreign NGOs. Countries in the Global North, on the other hand, often take a different approach. Within the U.S. and the European Union, foreign NGOs operate as freely as domestic NGOs, without special reporting requirements, and are allowed to engage in advocacy and lobbying. The U.S. State Department holds that this is crucial to developing a “robust civil society.”
The other global gag rule
Despite their purported interest in protecting civil society, governments in the Global North do try to influence the activities of international NGOs. For example, President Donald Trump’s much-discussed “global gag rule” prevents U.S. government funds from being disbursed to any organization that provides abortions or abortion counseling, or that advocates to decriminalize abortions, regardless of whether the money would have been used for that purpose. Last year, The Washington Post ran a long feature showing how the rule has affected health programs in Madagascar.
But a much broader global gag rule — or, more precisely, a set of rules — that predates Trump’s tenure receives far less scrutiny, despite its influence on conservation and development work in Madagascar and beyond. U.S. laws restrict lobbying by charities (including NGOs), private foundations, and government agencies. Some other countries and major international donors also have rules on lobbying and advocacy, but U.S. funds tend to be particularly restrictive — and a large portion of Madagascar’s conservation funding comes from the U.S.
NGOs registered as charities in the U.S. are subject to strict lobbying rules. They can’t make lobbying a “substantial” part of their activities — not more than 3 to 5 percent, experts say. Some NGOs file their taxes in such a way that they have hard limits of $1 million or less per year on lobbying for all of their programs in all countries combined.
The rules, which apply anywhere in the world, become even stricter when NGOs accept grant funding from private foundations, as international NGOs in Madagascar do. NGOs that accept foundation funding can’t use it to suggest, draft or take a public position on proposed or enacted legislation. They also can’t attempt to influence the Malagasy public on such legislation, and they can’t support political candidates.
The rules can prevent international NGOs from having a level playing field with the extractive industries, which face no such restrictions. For example, they made it difficult for NGOs to advocate for changes to Madagascar’s mining code, which were openly debated in recent years. Several Malagasy civil society groups regard the code, which was passed by parliament in 2005, as overly friendly to investors and lacking in social and environmental protections. But the mining industry, which faces no limits on the amount of money it can use to lobby the government, pushed back against proposed reforms. International NGOs remained silent on the matter, and in 2017 then-President Hery Rajaonarimampianina announced that there would be no change to the code.
Some experts, mindful of such cases, believe the lobbying rules, while sensible on a surface level, end up limiting NGOs’ freedom to participate in public debate. “[T]his particular set of restrictions is strikingly discriminatory. No other sector of the interest group universe is as constrained in its advocacy as are 501(c)(3)s,” Jeffrey Berry, a political scientist at Tufts University, wrote in an op-ed in The Washington Post in 2003. “This creates a huge imbalance.” (Private foundations and public charities are often called 501(c)(3)s after the U.S. tax code that applies to them.)
Pushing for change within the rules
Nevertheless, some international NGOs do their best to put pressure on Madagascar’s government. WWF is the most politically engaged BINGO in the country, at least in public. Advocacy makes up roughly one-quarter or one-third of WWF’s work in Madagascar, Ratsifandrihamanana estimated during an interview with Mongabay. She said she would like to see the figure increase, but it’s tricky “especially with funding from U.S. foundations.” Even when donors do allow advocacy, it usually isn’t a priority. “Advocacy is difficult to fund,” she said. “It’s easier to raise money for conservation on the ground with local communities.”
The rules do allow NGOs to engage in some types of advocacy, even when they receive foundation funding. For example, they can make general calls for, say, better anti-pollution laws so long as they don’t advocate for a specific law. They can address specific policy as technical advisers if their advice is sought in writing by Madagascar’s government. And they can try to influence the way laws are implemented by, for example, assisting Madagascar’s environment ministry in converting laws into regulations.
Such allowances are not always exploited. Berry, the Tufts political scientist, argues that the leaders of charities should try harder to take advantage of the types of lobbying and advocacy they can do. But the legal environment is complicated and difficult for NGOs to navigate. In practice, NGOs that receive foundation grants rarely take advantage of the fact that they can still lobby by using special safe-harbor laws or simply by using other types of funding, said Chelsey Ziegler, a lawyer for the Chicago-based MacArthur Foundation, which until recently was a major global conservation donor, funding several NGO projects in Madagascar. It can be an administrative burden on an NGO to ring-fence the funds and report on the activities separately, so most NGOs keep it simple and opt not to delve into advocacy and lobbying. Ziegler said that a conversation between funders and grantees is essential to supporting advocacy within the rules. “It makes people nervous to say, ‘yeah, we lobby,’” she told Mongabay.
A culture of caution
These constraints mean that many NGO staff members never learn to flex their advocacy muscles. Acquiescence to resource extraction becomes routine. “It becomes a habit,” Charlie Gardner, a conservation scientist at the University of Kent who worked in Madagascar for 10 years, told Mongabay. “They become self-censoring. Even if there isn’t specific legislation preventing them from advocacy work, they become used to watching what they do.”
Some NGOs not only self-censor but actively partner with extractive industries. In 2015, Conservation International (CI), which aims to “protect Africa’s ‘natural capital,’” made a deal with Ambatovy, a nickel and cobalt mining company owned by three multinational corporations that represents the largest financial investment ever in Madagascar. CI accepted $1.5 million from Ambatovy to help set up a protected area near the company’s plant in eastern Madagascar. Neither side released much information about the deal aside from a short press release. CI has never publicly criticized the company, despite some evidence of poor social and environmental practices, including its possible role in introducing an invasive toad that threatens to disrupt local ecosystems. In a recent email, Jenny Parker McCloskey, a CI spokesperson, told Mongabay that CI was a science-based organization that would not engage in advocacy whether or not the Ambatovy deal was in place.
Another reason NGOs are not more outspoken is cultural. “The Malagasy, we are not very confrontational,” Ratsifandrihamanana said. “We do it in more indirect ways. Sometimes we would be better off if we could be more straightforward with one another.”
It can be difficult for Malagasy professionals to take risks. Madagascar is a low-income country where white-collar jobs are precious, and the BINGOs offer some of the best white-collar jobs, with high salaries and good benefits.
For Malagasy or foreign staff wanting to keep working in the country, the importance of keeping a job or career advancement can lead to tunnel vision and silence on controversial topics. “There’s an incentive to keep your head down and just get on with your work,” Gardner said.
Malagasy conservationists tend to rotate between work for NGOs, industry and government. An NGO staff member may be reluctant to challenge a mining company when she might one day apply for a job with that company or a government ministry that regulates it. Some people in Madagascar are conscious of the impact this “revolving door” can have. For example, AVG’s Razakamanarina tries to protect the integrity of his civil society organization by not allowing people who leave AVG for government posts to return.
Still, the small, tightly knit professional world makes dissent difficult.
“If you [as an NGO staff member] see the minister on Monday, you’re not going to mount a campaign against him on Tuesday,” Marcus Schneider, former Madagascar country director for Friedrich-Ebert-Stiftung, a foundation affiliated with Germany’s Social Democratic Party, told Mongabay. Schneider said that he did not believe it was the role of NGOs to mount such campaigns, but he wondered if they would be better off changing their approach.
“There is a lot of money going into conservation and environmental work in Madagascar,” he said. “The question some people in the German development community ask is: would it be maybe more intelligent to fund education or political consciousness building? In the long run, the effect might be better on the environment. The degradation of the environment is caused by the difficult socio-economic and political situation.”
NGO practitioners are quick to acknowledge that economic, health and environmental outcomes are connected, and that holistic approaches are needed to improve them. But NGOs have to design their programs to match the priorities of funders and the Malagasy government. They usually opt for “capacity building” or “behavior change” at the community level rather than advocating for structural change. And so key drivers of resource degradation and biodiversity loss, including wildlife trafficking and industrial-scale exploitation, are left to others to challenge.
Because of these constraints, NGOs end up doing most of their advocacy work — if they do any at all — behind closed doors. This can be seen in the approach taken by Mihari, a network of small-scale fishers that is facilitated by NGOs. Mihari’s most ambitious goal, declared in 2017, is to establish an exclusive access zone for small-scale fishers along Madagascar’s coast. This is a sensitive political topic because it would seriously impact, if not end, industrial shrimp trawling in the country: 85 percent of the trawling takes place within 3 kilometers (2 miles) of the shore, the same area many of the fishers want designated a no-trawl zone.
Mihari was established in 2012 by several international NGOs, including the U.K.-based marine conservation group Blue Ventures, and is considered a breath of fresh air in Madagascar’s conservation circles. Many NGO leaders proudly tout their support for the group’s community organizing and advocacy work, which has received international attention. Mihari’s coordinator recently won a Whitley Award, a prestigious prize for grassroots conservation leaders in the Global South.
Mihari does have grassroots members — thousands of small-scale fishers across the country — who speak forcefully about the impact of industrial fishing on their livelihoods when given the opportunity. However, its NGO members are bound by the requirements of international funders and the Malagasy government, so Mihari, as a network, can’t speak with the same force. Mihari’s 2017 declaration [pdf] did not specify how much marine area should be reserved for local fishers — possibly to avoid advocating for specific legislation due to funding rules.
And since then, Mihari has not engaged in much public-facing advocacy. For example, Mihari and Blue Ventures chose not to speak publicly when this reporter inquired about issues that directly affect small-scale fishers. Last year, Madagascar’s government announced the sale of offshore oil blocks comprising 63,296 square kilometers (24,440 square miles) along the country’s west coast, where most small-scale fishers are based. More recently, Madagascar has negotiated for a new fisheries deal with the European Union, which has been accused of unfair exploitation of marine resources in past deals. In these cases and others, staff members at Mihari and Blue Ventures avoided on-the-record comments and expressed a preference for behind-the-scenes negotiations with members of government or industry, citing a need to maintain good relationships.
Critics caution that there are potential downsides to this approach, even if it’s effective in the short term. Such advocacy can ultimately disempower its purported beneficiaries by taking the debate out of the public sphere. Quiet, backroom advocacy is often aimed at industry or government elites who, though Madagascar is ostensibly a democracy, do not necessarily represent the interests of small-scale fishers or the broader Malagasy public. It can muffle the powerful voices of Malagasy fishers in favor of the cautious, if well-meaning, voices of NGO representatives. And without a strong popular movement to keep pressure on government and industry, any gains achieved in backroom deals could easily be rolled back in the future, observers caution.
Some gains in Madagascar have already proved fragile. International NGOs pushed the conservation agenda in Madagascar in the 2000s, working with the government to more than triple the land coverage of protected areas — the fulfillment of the so-called Durban Vision. Amid a scramble for funding, NGOs competed to manage sites across the country. Although the effort was successful in quantitative terms, the impact was not always positive or enduring. Researchers say that decision-makers were overly accommodating to foreign mining interests and, though some progress was made in establishing community management, NGOs failed to fully consult or engage local people, many of whom ended up feeling disenfranchised and still log illegally, hunt bushmeat, and engage in artisanal mining in the parks. Some protected areas have no active management and are considered “paper parks,” while others were “orphaned,” never receiving NGO support or having it withdrawn due to lack of funding.
“The lobbying work in the 2000s was too dependent on influential individuals from certain NGOs and their relationships with certain government officials,” Nadia Rabesahala Horning, a political scientist at Middlebury College in Vermont who comes from Madagascar and researched the country’s environmental aid sector during that period, told Mongabay. “The efforts were never institutionalized. When those people left their positions, they left a vacuum.”
Blue Ventures and Mihari are working to address some of these issues, starting with strengthening the dialogue between small-scale fishers and government officials. Alasdair Harris, Blue Ventures’ executive director, told Mongabay that Mihari started as a peer-to-peer network and, per the wishes of its grassroots members, has increasingly focused on policy. “We are now working with MIHARI’s members and partners to help the network gain its own independent legal status and the necessary leadership, operational systems, and governance needed to thrive as a credible national civil society organization,” he wrote in an email.
Ingredients for change
If international NGOs in Madagascar find it difficult to push for specific policy changes or government reform, homegrown groups have more scope to operate. With no need for an accord de siège, these groups do some of the most challenging and important conservation work in the country.
AVG campaigns against rosewood and other wildlife trafficking, and helps bust criminals illegally trading endangered tortoises. Just last month, groups within the network publicly called for legislation on investments that better protects the environment and strengthens the voice of local people. Razakamanarina, its president, keeps the consortium local. He has, for example, declined to integrate Mihari or WWF into the AVG network because of their foreign status, he said. Transparency International–Initiative Madagascar speaks out forcefully against corruption and environmental injustice, regularly publishing articles on these subjects in Madagascar’s newspapers. It’s locally registered as its existence predates the TI name: Transparency International allows civil society groups in countries such as Madagascar to take on its name but remain independent. CRAAD-OI, a civil society group based in Antananarivo, teaches people in rural Madagascar about land rights and acts as a watchdog against illicit activity by the extractive industries. CRAAD-OI is locally registered and deliberately avoids accepting money from the U.S. government, U.S. foundations, the World Bank, or the European Union, its coordinator told Mongabay.
Such groups are advocating for more robust environmental policies and a fairer distribution of Madagascar’s natural resource wealth. Will this be enough to protect Madagascar from large-scale resource extraction for the benefit of a select few? If there’s one thing that’s sure, it’s that the BINGOs, at least as they are currently set up, won’t have much to say about it.
Banner image: Baobab trees in western Madagascar. Image by Rhett A. Butler / Mongabay.
Disclosure: This reporter worked for Blue Ventures from 2014 to 2015.
Clarification 12/19/19: The story was amended to clarify the lobbying rules for U.S. charities and foundations.
Clarification 12/24/19: WCS sent the following response to this story: WCS has worked in partnership with the Malagasy government and local communities to protect Madagascar’s biodiversity for over 25 years. This includes landscapes such as Makira Natural Park, an area renowned for its intact forests and high biodiversity, but which has also been the target of illegal logging, including for rosewood. WCS worked to create the park and secure resource use rights for over 75 community-managed forest zones within the buffer zone of the park. By supporting local community patrols, bringing in law enforcement authorities when offenders are identified, and supporting sustainable development activities for communities, deforestation levels have been significantly reduced. Rates of deforestation today are three times lower than those that were originally predicted at the start of the project, saving an estimated 70,000 hectares of forest over the course of 15 years. At the national level, the Malagasy government also recently took the ground-breaking decision to withdraw its request to CITES to sell its rosewood stocks. These successes suggest that a constructive, pro-active approach is often the most effective way to ensure long-term conservation of some of the world’s most threatened biodiversity.
Aymoz, B. G., Randrianjafy, V. R., Randrianjafy, Z. J., & Khasa, D. P. (2013). Community management of natural resources: A case study from Ankarafantsika National Park, Madagascar. Ambio, 42(6), 767-775.
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