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How a ‘dirty gambling company’ may have set the standard for habitat destruction in Cambodia

Trekking through the Cardamom Tented Camp concession in Botum Sakor National Park. Image for Mongabay by Gerald Flynn.

Trekking through the Cardamom Tented Camp concession in Botum Sakor National Park. Image for Mongabay by Gerald Flynn.

  • Union Development Group (UDG) is a Chinese company that was granted a 36,000-hectare concession in Cambodia’s Botum Sakor National Park in 2008, followed by an additional 9,100-hectare concession granted in 2011. Much of Botum Sakor National Park’s forests have been cleared by UDG and other companies.
  • On Sep. 15, 2020, the United States Treasury Department, sanctioned UDG for “serious human rights abuses and corruption,” noting that UDG had enlisted the support of the Royal Cambodian Armed Forces to evict and harass residents, and also managed to skirt the 10,000-hectare limit on land concessions by “falsely registering as a Cambodian-owned entity.”
  • In 2021, the Cambodian government signed into law Sub-decree No. 30, which transformed some 127,000 hectares of protected land in Koh Kong province into state-private land.
  • Conservationists, researchers and local residents interviewed by Mongabay worry that the sub-decree will mean that many other parts of Koh Kong province will follow in the destruction of Botum Sakor.

This is the first article in a three-part series. Read Part Two and Part Three.

PHNOM PENH, Cambodia — “I was detained for a night, the authorities had come to tear down another house, so I went to help, but ended up getting arrested instead,” said Phal Seat, a 47-year-old resident in Koh Kong province’s Botum Sakor district. “Before, we lived near the sea, we had a livelihood there, but we were made to move for UDG’s [Union Development Group] concession. They made us move here, by this road, but now they won’t give us land titles.”

Seat lost his 5-hectare plot of land, as did the estimated 1,000 families locked in an ongoing land dispute with UDG—a Chinese enterprise—that was granted a 36,000-hectare concession in Botum Sakor National Park in 2008, followed by an additional 9,100-hectare concession granted in 2011. The $3.8 billion investment is set to consume roughly 20 percent of Cambodia’s coast, which had previously provided Seat and other Cambodians with fish, crabs and snails.

“Nobody comes to intervene, no-one can solve our problems—these days I feel like I see a lot of injustice, we cannot build houses here because we don’t have land titles, we cannot farm because we don’t have land titles and we cannot have land titles because the local authorities won’t give them to us,” Seat said.

Seat said authorities even dismantled a well that he and the other villagers had built to provide clean drinking water. In October 2021, the Koh Kong Provincial Administration announced it would be holding a lottery to provide solutions for the victims of UDG.

Sunda pangolins (Manis javanica) are found in Cambodia’s dwindling rainforests. They are listed as endangered by the IUCN. Image by user Piekfrosch via Wikimedia Commons (CC B-SA 3.0).

On Sep. 15, 2020, the United States Treasury Department sanctioned UDG for “serious human rights abuses and corruption,” noting how UDG had enlisted the support of the Royal Cambodian Armed Forces to evict and harass residents, and also managed to skirt the 10,000-hectare limit on land concessions by “falsely registering as a Cambodian-owned entity.”

But as the land dispute racks up a human cost and the environmental impact of UDG’s concession has seen much of the coast decimated, a new threat has come to the fore, one that stands to replicate the destruction of Botum Sakor in more of Koh Kong’s national parks, reserves and wildlife sanctuaries.

Signed into law in March 2021 by Prime Minister Hun Sen in his 36th year in power, Sub-decree No. 30 transformed some 127,000 hectares of protected land in Koh Kong province into state-private land, ostensibly with the view to providing land titles to communities like Seat’s. However, a Mongabay investigation found that a cabal of land brokers with links to Defense Minister Tea Banh and his brother Tea Vinh, who heads the Royal Cambodian Navy, were buying up vast swathes of land listed in Sub-decree No. 30.

This was grim vindication for conservationists who feared that the sub-decree would see Cambodia’s protected areas, which span some 7 million hectares nationally, serve as a land bank for the rich and powerful who they say have long exploited the country’s protected area scheme for their own benefit.

Botum Sakor National Park lost more than 30,000 hectares of land to Sub-decree No. 30—equivalent to roughly 18% of its total land mass. Yet, more of the park has been destroyed, cleared or otherwise degraded by UDG, with 26.34% of Botum Sakor consumed by UDG’s concessions, according to satellite data from the University of Maryland. Tree cover has already been reduced by 15.59% across both concessions since 2008, when UDG’s first concession was granted, but research published this year suggests that UDG’s destruction of Botum Sakor is set to ramp up with the development of more resort accommodation, casinos, shopping malls, entertainment centers, as well as industrial and commercial zones all slated for UDG’s concessions.

Satellite data visualized on Global Forest Watch show large swaths of rainforest in Botum Sakor National Park has been lost since 2001.

Mongabay reporters attempted to reach UDG through contact details listed on Ministry of Commerce records, and a response came from a former employee of UDG who said they no longer worked for the company.

“[I] don’t want to have any connections with this dirty gambling company,” said the person responding through the only email address listed for UDG in public Cambodian records. As such, UDG could not be reached for comment.

Now conservationists fear the sub-decree will see more of Koh Kong’s best-preserved landscapes follow the bleak trajectory of Botum Sakor, with privatization threatening to fracture one of the largest and wildest ecosystems in Cambodia.

Roughly 90% of Koh Kong was listed as protected prior to Sub-decree No. 30 due to the contiguous nature of its landscapes that saw mountains, rainforests, mangroves and seagrass trace a vast and varied range of habitats for some of Cambodia’s last remaining endangered species across the province and along its coast.

One key element of UDG’s developments along the Cambodian coast has been tourism. But while Koh Kong plays host to a range of ecotourism initiatives that aim to promote the natural beauty of the province, UDG’s mega-resorts have seen mangroves eviscerated, the coastline disfigured and land cleared for a string of roads.

UDG and the government have promised the developments will be a boon to the local economy and those seeking employment, but industry experts have raised concerns over the propensity for Chinese tour operators’ Zero Dollar schemes in Cambodia.

Such schemes see Chinese tour operators undercut local businesses by selling cheaper package tours to would-be tourists in mainland China, who then go on to stay in Chinese-run hotels, eat at Chinese-run restaurants and buy souvenirs at Chinese-run shops—many of which offer kickbacks to the tour operators in exchange—keeping tourism dollars from entering the local economy.

Furthermore, the prevalence of Chinese payment apps such as Alipay and WeChat Pay often mean that there are no dollars to be had at all, as Chinese tourists need not exchange currencies, further reducing benefits to locals.

For scale, Chinese nationals made up more than one third of Cambodia’s international arrivals in pre-pandemic years, which highlights the risks associated with such tourism infrastructure projects, according to Chhay Sivlin, president of the Cambodia Association of Travel Agents.

“The Zero Dollar scheme remains a huge concern when it comes to Chinese investment in the country, which is why the government should implement certain restrictions when it comes to authorizing licenses to foreign investors to ensure their business practices will contribute to the local economy and industry,” Sivlin said.

Instead, Sivlin said that if the government hopes to develop Koh Kong’s tourism sector—as the construction of a new international airport, also by UDG, suggests—then the focus should be on the province’s natural environments and developing sustainable tourism products.

“With that said, too much ecotourism competition could pose as a negative impact for Koh Kong in regards [to local livelihoods] and its forests,” she said, noting that there is likely a limit to the viability of ecotourism projects in the province.

One of the more successful such projects in Koh Kong is the Cardamom Tented Camp. Established in a concession owned by conservation NGO Wildlife Alliance, operated by Yaana Ventures and managed by veteran wildlife photographer Allan Michaud, the camp has helped preserve some 18,000 hectares of Botum Sakor National Park—just over of 10% of the park in total. But Michaud cautions that Chinese developments and Sub-decree No. 30 pose existential threats to his business model.

“It’s a little worrying as to what they’re planning to do,” said Michaud in reference to the sub-decree. “Botum Sakor National Park is an interesting microcosm of the whole situation—it’s 171,000 hectares, but 72 percent of it has already been leased out and most of that has been cut clear so a lot of it’s gone already.”

Wildlife Alliance’s concession in Botum Sakor houses the Cardamom Tented Camp eco-resort. Image for Mongabay by Gerald Flynn.

Neth Pheaktra, spokesperson for the Ministry of Environment, said the country had exceeded its 2020 Aichi Biodiversity Targets, which required protection of at least 17% of terrestrial and inland water and 10% of marine and coastal areas.

Cambodian law prevents protected areas from being leased out, but the government has found means through which to circumvent this—largely in the form of economic land concessions. However, Sub-decree No. 30’s transformation of protected land into state-private land means it can now be rented or sold by the Koh Kong Provincial Administration.

A lease, Michaud said, is a somewhat disingenuous term for what happens in Koh Kong since often the leased land is cleared of any and all forest.

“It’s all very well having a big resort, but if there’s nothing for anyone to do, you’re a bit screwed,” he said. “This is my concern, that very little of the national park is being protected.”

“We have staff from Tatai and a lot of people there are upset due to recent land grabs as part of the sub-decree,” Michaud said. “It’s a very popular area, a very pretty valley, but the beauty of these places soon disappears because they’re so busy developing the hell out of everything that you end up with a mess. There needs to be some care over how they develop things and this is the worry.”

That lack of care is something Michaud already seen with relocations along the road that Seat and his community live on. Unsuitable for farming, many in the community are now engaged in illegal logging and poaching.

“This worries us as it’ll probably mean more snares everywhere,” Michaud said, “and while our area’s not tiny, it can’t stand that kind of pressure if everyone moving in along that border starts snaring—they’ll kill everything.”

 

Banner image: Trekking through the Cardamom Tented Camp concession in Botum Sakor National Park. Image for Mongabay by Gerald Flynn.

Related listening: Reporter Gerald Flynn appeared on Mongabay’s podcast to discuss the conservation and land rights implications of these moves by the Cambodian government, listen here:

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