Contamination and Impact

Afghanistan remains one of the states with the highest level of contamination from landmines and explosive remnants of war (ERW), mainly the result of the 1979 Soviet invasion followed by internal armed conflict in 1992–2001, and the United States-led Coalition’s intervention in late 2001, which added considerable quantities of UXO.[1] As of mid-2010, the Mine Action Coordination Center of Afghanistan (MACCA)[2] estimated the number of hazardous areas at 6,696 affecting 654km² and 2,127 communities.[3]

Mines

Afghanistan is affected by a wide array of mine types but mostly Soviet, Iranian, and Pakistani antipersonnel mines and much smaller numbers of antivehicle mines, including Italian minimum-metal mines. Operators believe most of the densest mine belts laid along lines of confrontation in the 1980s and 1990s have been cleared[4] but estimates of the extent of mine contamination have fluctuated in recent years as a result of new finds by returning refugees, further survey, and as MACCA conducted an audit of data.

The Afghanistan Landmine Impact Survey (ALIS), completed in 2005, found 2,368 communities and more than 4 million people affected by mines, and identified some 715km² of suspected hazardous areas (SHAs).[5] However, Uruzgan and Daikundi  provinces, which were identified by the survey as the only Afghan provinces where mine contamination was not found, are now included in demining operations.[6] By the end of 2007, the estimate of total contamination had risen to 852km². MACCA reported at the end of 2009 that since January 2008, 1,289 previously unknown minefields covering some 121km² had been identified.[7]

After further clearance and data consolidation, MACCA estimated the number of sites containing explosive hazards as of the end of July 2009 at 6,502 covering 668km² but it observed this figure could rise with the results of further survey.[8] By the end of 2009, the number of contaminated sites had fallen to 6,351, covering an estimated 630km² but still affecting 2,130 communities.[9]

MACCA contamination estimates

Rising insurgency in recent years has led to some additional contamination resulting from use by the Islamic Emirate of Afghanistan (Taliban) and other non-state armed groups of antipersonnel and antivehicle mines and victim-activated improvised explosive devices (IEDs).[10] A US Department of State report in 2009, however, noted that “with the exception of reported sporadic use by the Taliban, parties to the con­flicts in Afghanistan are reportedly not using anti-personnel mines in the standard military sense.”[11]

Cluster munition remnants

Afghanistan has a continuing threat from cluster munition remnants. Soviet forces and the government of Afghanistan used air-dropped and rocket-delivered submunitions in the 1979–1992 conflict, and US aircraft dropped 1,228 cluster munitions containing some 248,056 submunitions between October 2001 and early 2002.[12] However, clearance operations followed in 2002–2003 guided by US cluster strike data are thought to have removed most of the resulting contamination. Demining operators say they still encounter both NATO and Soviet unexploded submunitions but only in small numbers.[13] MACCA reports that since 2002 operators have cleared or cancelled 157 submunition sites covering a total of 15.2km². A further 23 sites covering 6.98km² are still open.[14] The ALIS found that 89% of affected communities reported only antipersonnel and/or antivehicle mines.[15]

Other explosive remnants of war

Afghanistan contends with extensive ERW, including unexploded aircraft bombs, artillery shells, mortars, rockets, and grenades, as well as abandoned explosive ordnance. Increased insurgency in the past three years has resulted in additional ERW contamination, including remotely detonated and victim-activated IEDs or booby-traps, although the precise extent is unknown.[16] The US military reported the number of IED incidents rose sharply to 6,440 in 2009 from 4,169 in 2008, 2,718 in 2007, and 326 in 2004. It said the rise was accompanied by a dramatic increase in 2009 in the size of IEDs’ typical explosive charge.[17] Military logs published by Wikileaks in July 2010 recorded 7,155 IED finds in 2009, up from 308 in 2004.[18]

Security forces, the government, and the UN have continued to uncover large caches of weapons and munitions, including landmines; more than 2,900 tons (2.9 million kg) of munitions were discovered in northern Afghanistan by the joint Afghan-UNDP Afghanistan New Beginnings Project.[19]

MACCA observed in 2009 that “BAC [battle area clearance] work will essentially be the end state for the Afghan government and—like Europe after the world wars—Afghanistan can anticipate conducting BAC operations for a significant time period.” [20]

Mine Action Program

Key institutions and operators

The Mine Action Programme of Afghanistan (MAPA), set up by the UN in 1989, is coordinated by MACCA, a project of the UN Mine Action Service implemented by UNOPS. Before 2009, MACCA was responsible for managing, planning, and coordinating all aspects of mine action undertaken by MAPA, including database management, oversight of all funds supporting MAPA, and resource mobilization.[21]

Plans to nationalize MAPA have led to changes in its management structure and MACCA’s role. Until 2008, the Ministry of Foreign Affairs provided the government focal point on mine action.[22] A Ministry of Foreign Affairs-sponsored symposium in December 2007 decided an interministerial board should provide guidance to MACCA and that existing institutions should continue to provide support to the government on mine action until 2013,[23] when responsibility for mine action is to be handed over to national ownership.[24] The Interministerial Board (IMB) has reportedly met three times since its creation but did not meet in the first half of 2010.[25]

An interministerial meeting convened by the Ministry of Foreign Affairs on 16 January 2008 assigned the lead role in mine action to the Department of Mine Clearance (DMC), a department of the Afghanistan National Disaster Management Authority, which reports to the Office of the President. The DMC was also assigned to act as the IMB’s secretariat.[26] In May 2008, the DMC, with 15 staff, set up its offices in MACCA’s Kabul headquarters but has continued to be funded through the national budget.[27]

In 2010, MACCA appointed a staff member to work on plans for transition and the DMC and UNMAS were also drawing up a roadmap for transition expected to be completed by the end of the year.[28] MACCA also pointed out that “the IMB did not designate DMC as the eventual coordination structure therefore transitions of actions to DMC should themselves be understood as first steps.”[29]

A European Union (EU) evaluation of mine action in 2009 expressed concern over the lack of clarity in plans for transition, MACCA’s role, and its relationship with the DMC. It said the “key stumbling block” to transition was that the government “has little or no interest in owning either the problem of, or solution to, ERW contamination in Afghanistan.” It added MACCA’s Afghan implementing partners also expressed no interest in changing the status quo. It concluded: “Until these issues are resolved talk of transition is largely meaningless.”[30]

In response, MACCA stated that: “MACCA provided feedback to the EU on this evaluation which they had funded, specifically that it had a number of substantive errors leading to poor analysis. Although finding aspects of the report constructive and useful, the MACCA found other parts grossly in error and intellectually loose. It is notable that the evaluation made recommendations that were not subsequently acted on by the EU.”[31]

Under plans for the Afghan year 1388 (1 April 2009–31 March 2010), the DMC was to assume responsibility for accrediting mine action organizations, coordinating external quality assurance, acting as lead coordinator for risk education (RE) with the Ministry of Education, and preparation of Afghanistan’s Article 7 reports, working with existing MACCA staff.[32] By mid-2010, the DMC reported that the process was incomplete. It was participating in the MACCA management committees while also focusing on capacity-building. Three staff underwent training in India and the DMC was preparing to send four for training in Azerbaijan. The DMC’s plans to appoint more than 20 new staff were awaiting government approval.[33]

MACCA’s seven Area Mine Action Centers (AMACs)[34] liaise with other UN and international agencies, government departments, and the International Security Assistance Force (ISAF) Provincial Reconstruction Teams. To try to promote coordination with government ministries and increase integration of mine action into development plans, MACCA also appointed a staff member in 2010 to try to improve knowledge of the mine/UXO problem in government departments and support planning of clearance.[35] MACCA has already passed the lead role in mine/ERW risk education to the Ministry of Education.[36]

In 2009, MACCA sought to shift away from its former role assigning clearance tasks to implementing partners and to concentrate more on oversight, strategic planning, and coordinating operations while encouraging implementing partners to plan and manage clearance tasks within the strategic framework.[37] MACCA issued a list of planning criteria, priorities, and a dataset of hazards to provide the basis for implementing partners to draw up “aspirational plans.” MACCA assessed and where necessary negotiated amendments to these plans with implementing partners to ensure they addressed MACCA priorities, achieved a geographic balance, and avoided duplication or overlap.[38]

Priorities for action under the Afghan year 1389 (1 April 2010–31 March 2011) workplan included:[39]

·         “killing zones” (communities that have recorded casualties every year since 2003);

·         high-impact districts and communities (victims, blockages);

·         hazards causing victims recorded in the ALIS (but less than in previous categories);

·         small hazards (less than 5,000m²);

·         all hazards within 500m of the center of a community;

·         hazards classified according to terrain that did not fit the categories above;

·         donor priorities, including areas with cultural or other benefits; and

·         demining organization priorities (funded bilaterally).[40]

MACCA’s operational framework for Afghan year 1389 noted the need for “a balancing act” between the wish to complete clearance of some areas and uphold priorities. It noted that 17 districts each had more than 70 hazards and 85 districts had five mined areas or less and observed that “considerable progress can be made towards reaching an end state by seeking to coordinate the focusing of some clearance into districts with fewer hazards.”^[41]

MACCA also identified six large projects for consideration by donors, including a US$5 million project to clear all known hazards within Kabul municipality covering an area of 7km², a $7 million, three-year project for clearance of Ghazni city, a $38 million, four-year project to clear all high- and medium-priority as well as a range of other hazards in Kandahar province, and a $40 million, two-year project to clear all of four eastern provinces, for which estimated contamination covered 17km².[42]

Mine action, however, has faced increasing constraints from the spread and intensification of insurgency. MACCA observed that funding is more of a challenge than insurgency[43] but the operational framework for Afghan year 1389 points out 42% of all known hazards covering 68% of the known hazardous area lies in areas classified by the UN as extreme risk and high-risk environments. “This is a significant figure that will have a major impact on programme delivery,” it said.[44]

In June 2010, MACCA and the Geneva International Centre for Humanitarian Demining (GICHD), embarked on a “Landmines and livelihoods” survey, conducting a post-clearance analysis in 25 communities to test the planning criteria applied in recent years. It also planned to conduct a follow-up survey in one area assessing community priorities for clearance against known hazards with a view to producing a prioritization model. The results were expected to be published towards the end of 2010.[45]

Until March 2009, MACCA used a decentralized data entry system in which staff at the AMACs entered clearance data and completion reports provided by operators into the database, and MACCA was responsible for quality control, updating of information, and sending updates to the AMACs. From April 2009, the AMACs continued collecting and verifying clearance data but data entry was undertaken by MACCA staff in Kabul.[46] RE activity reports are also provided to MACCA and entered into the Information Management System for Mine Action (IMSMA).[47]

MACCA embarked on a trial of IMSMA New Generation (NG) in June 2009 with a view to upgrading its database but encountered problems with the new system and decided in 2010 to revert to its existing IMSMA 3 version. MACCA said it would continue to work with GICHD to “ensure continuous improvement” of IMSMA NG and it anticipated trying again to transition to NG in 2011.[48]

Recent program evaluations

A 2009 EU evaluation judged MAPA to be “highly successful” and recommended the EU “substantially increase funding” for mine action, “perhaps by 100%.”[49] The evaluation said MACCA was “adding more value to the MAPA by better analysis of the mines problem as recorded in the national database, and is co-ordinating a more intelligently crafted solution that is driven far more by qualitative factors than ever before.”[50]

The evaluation found mine action “much improved” by operational reforms since 2006 but observed that many national operators lacked the ability and confidence to fulfill the role of full service providers under the new concept of operations[51] and suggested that this could affect safety. The evaluation also found it “unacceptable” that at least 48 demining accidents occurred among Afghan implementing partners in 2008.[52] It also drew attention to problems of missed mines and incidents on previously cleared land.[53] The evaluation recommended quality assurance should be outsourced to a technically competent agency not operating in Afghanistan.[54]

An assessment of humanitarian demining conducted in 2009 by the US Department of State’s Office of the Inspector General (OIG) said the six demining organizations the US supported in 2009 “merit further support” and noted demining NGOs had achieved “impressive increases in productivity. The 82,000 antipersonnel and 900 antitank mines cleared in 2008 represent over 20 percent of all mines cleared since 1989.”^[55]

The report described as “promising” efforts to promote community-based demining initiatives (see Mine clearance in 2009 section below) but also drew attention to a number of potential problems. It noted that much of the success of the program to date may have been due to community expectations that clearance of mines would lead to development funding to help the community make better use of the land. However, this had not occurred so far and called for “far greater coordination than currently exists.”[56]

The OIG also cautioned against pushing community-based demining too aggressively in insecure areas, warning that this might “eventually place the NGO management/training staff and even the community deminers at risk, and not only from insurgents or criminals. Allied pilots, for example, will want to take care not to mistake deminers for insurgents. There is also the risk of shifting mine action resources to areas where there is actually less immediate economic return.”[57]

Land Release

MAPA released or cancelled a total of 219.5km² of suspected hazardous areas (SHAs) in 2009, a marginal increase on the 216.95km² released or cancelled in 2008 despite the increasingly difficult operating environment created by an expanding insurgency. The area reduced or cancelled accounted for more of the total (28.5%) in 2009 than the previous year (17.8%). The total included 52.6km² of mined area released through clearance and 39.3km² reduced or cancelled, together with 104.3km² of battle areas that were cleared, and 23.3km² that was cancelled.[58] In the process, MACCA reported demining organizations destroyed a total of 52,105 antipersonnel mines, 789 antivehicle mines, and 1.02 million items of ERW.[59]

Afghanistan has the oldest and biggest mine action program with some 8,000 deminers working for seven implementing partners coordinated by MACCA. Most mine clearance is conducted by five long-established national and two international NGOs. The Afghan NGOs are: Afghan Technical Consultants (ATC); Demining Agency for Afghanistan (DAFA); Mine Clearance Planning Agency (MCPA); Mine Detection and Dog Centre (MDC); and Organization for Mine Clearance and Afghan Rehabilitation (OMAR); with two international NGOs: Danish Demining Group (DDG) and HALO.

In addition, 16 commercial companies operated in 2009. These included nine Afghan companies: Afghan Campaign for Landmines, Asda Brothers Demining Company, Country Mine Clearance Company, Hemayatbrothers Demining International (HDI), Kabul Mine Clearance Company, Kardan Demining Group, National Demining Support Services, OMAR International, and Trust Demining Company. Seven international companies active in 2009 were: G4S Ordnance Management (formerly ArmorGroup), DynCorp International, EOD [Explosive Ordnance Disposal] Technology, MineTech International, RONCO Consulting Corporation, The Development Initiative (TDI), and UXB International. MACCA accredited eight more commercial companies (including seven Afghan companies) in 2009 and two more (one Afghan) in the first half of 2010.[60]

Five-year summary of land cancellation and release[61]

Survey in 2009

Before 2007, only one Afghan organization, MCPA, conducted survey. Under the new concept of operations put into practice in 2007 to increase operational flexibility, all Afghan implementing partners undertake survey.[62]

HALO and MCPA completed a polygon survey of SHAs in 2009 which resulted in cancellation of some 60km² of SHA but also identified 52km² of previously unidentified contamination, for a net reduction of 8km² in the estimate of overall contamination.[63] HALO surveyed 33.6km² of suspected mined areas in 2009 of which 14.9km² was previously unidentified.[64]

Mine clearance in 2009

Demining organizations marginally increased the amount of land manually cleared in 2009 compared to the previous year helped by a revival of funding which allowed many of MACCA’s implementing partners to rehire staff laid off in 2008 and even expand capacity. Operations faced increasing constraints imposed by deteriorating security conditions.

Deteriorating security in much of Afghanistan gave added impetus to MACCA’s program of community-based demining (CBD) initiated in 2008. The Afghan year 1389 operating framework noted that “mine action is considered by most Afghans of all persuasions to be a task that transcends political or ethnic differences.”[65] In areas where insecurity prevents normal operations, Afghan implementing partners, after consulting and gaining explicit approval of local elders, recruit and train local people to clear hazards in their area, providing employment and skills training for the duration of the task. Implementing partners provide equipment and team leaders direct clearance at least until local recruits have sufficient experience to assume the role.[66]

The number of CBD projects rose from three in 2008 to 10 in 2009, when they resulted in clearance of 5.8km² with the destruction of 1,179 antipersonnel mines, 39 antivehicle mines, and 21,423 ERW. A further nine CBD projects had started by early June 2010.[67] A total of $8.8 million was allocated to CBD in 2009, representing 11.4% of total funding. A further $10 million had been allocated for CBD in 2010 as of June, also representing 11% of funding.[68]

Mine clearance in 2009[69]

*HALO reported clearing 12.83km² in 2009 and destroying 33,700 antipersonnel mines and 188 antivehicle mines.[70]

Compliance with Article 5 of the Mine Ban Treaty

Under Article 5 of the Mine Ban Treaty, Afghanistan is required to destroy all antipersonnel mines in mined areas under its jurisdiction or control as soon as possible, but not later than 1 March 2013 (which falls within Afghan year 1391). This obligation is a key influence in Afghanistan’s strategic planning. The Afghan Compact of 2006 set the target of clearing 70% of hazards and contaminated areas by 1 March 2011, and The Way Ahead draft strategy for mine action released in 2006 set the target of completing clearance of all known mined areas by 2013.[71]

At the Second Review Conference of the Mine Ban Treaty, Afghanistan said its mine action strategy was based on “the government’s vision of a country free of landmines.”[72] At the June 2010 intersessional Standing Committee meetings, however, it claimed that “the programme is chronically under-funded to meet the goals of the Ottawa Treaty.”[73] MACCA’s Afghan year 1389 workplan observed that “the programme has the general capacity to remove 90km² of hazard from the database per annum therefore, quite clearly, unless the programme triples in size before April 2010 the Compact target will not be achieved.”[74]

Progress towards completion is hampered by continuing new discoveries of mined areas as a result of new information produced by the return of refugees and by further survey. By the end of 2009, Afghanistan had cleared 41% of its known hazards and 39% of the estimated contaminated area, although by the end of March 2010 the progress towards those targets was 43% and 47% respectively.

Progress towards mine action benchmarks[75]

In the past nine years, demining organizations have cleared 317.34km² of mined areas[76] but in June 2010 MACCA estimated 654km² still remained to be released.[77]

Compliance with Article 4 of the Convention on Cluster Munitions

Afghanistan has signed the Convention on Cluster Munitions but as of 1 September 2010 had not ratified it.

Clearance of cluster munition contaminated areas in 2009

MACCA has recorded clearance of 43 cluster munition sites since 2004 covering a total area of 3.2km², all by HALO and MCPA. Of these, six sites covering a total of 670,276m² were reportedly cleared in 2009.[78]

HALO cleared a total of 2,607 unexploded submunitions in 2009, of which 331 were NATO items and 2,276 Soviet submunitions.[79] G4S also reported clearing areas contaminated with remnants of US M-42 submunitions close to Camp Hero, near Kandahar, in 2009.[80] However, most of the submunitions dropped by US aircraft in 2001–2002 were destroyed in clearance operations conducted in 2002–2003 that were guided by US strike data and demining organizations say they do not encounter many.[81]

Demining organizations continue to find unexploded submunitions used by Soviet forces, also usually in small numbers. HDI, working on a US Army Corps of Engineers contract at Bagram airbase reported finding substantial numbers of abandoned submunitions, many of them still in packing cases. OMAR also reported finding unexploded Russian submunitions on the border with Pakistan which was bombed by Soviet and Afghan forces.[82]

Battle area clearance in 2009[83]

A total of 20 operators, including MACCA’s implementing partners and commercial companies, reported clearing 104.83km² of battle area in 2009 and more than 1 million items of UXO.

Much of the BAC undertaken by commercial companies involved contracts to clear sites for construction or expansion of military bases and police posts as well as checking areas designated for construction of buildings or infrastructure. RONCO, G4S, Explosive Ordnance Disposal Technology (EODT), and UXB International undertook contracts for the US Army Corps of Engineers.[84]

DynCorp International, working under contract to the US State Department’s Office of Weapons Removal and Abatement, operated seven 12-person teams doing village-by-village clearance of UXO, tasked by MACCA’s AMACs and responding to local calls.[85]

Battle area clearance and explosive ordnance disposal in 2009[86]

Quality management

MACCA provides quality management through a three person unit in Kabul and 50 staff in seven AMACs who conduct demining site visits.[87] In 2009, MACCA put out an expression of interest for an international agency to undertake quality assurance, a measure recommended in the 2009 EU evaluation.[88] After an internal review, MACCA instead initiated transition to a new system of quality assurance (QA) to be implemented over the ensuing two years focusing less on routine site visits and more on an audit of implementing partners’ systems and procedures. MACCA also brought in an Afghan organization, the Afghan Institute of Management, Training and Enhancement of Indigenous Capacities, formerly Monitoring, Evaluation and Training Agency to work with the DMC on a QA needs assessment.[89]

MACCA introduced in 2009 a “balanced scorecard” to monitor the activities of implementing partners and provide a benchmark for raising standards. The scorecard, welcomed by Afghan implementing partners,[90] measures their performance on a quarterly basis against a set of five indicators for assessing demining operations (operations, quality management, demining accidents, cost, and reporting) and four indicators for RE (the same but not including accidents). MACCA and demining operators gave the scorecard a trial run in July through September 2009 and put it into practice with amendments in the final quarter of the year. Data on performance drawn from the IMSMA database is shared with implementing partners who then confirm the score.[91]

The operations indicator (40% of the total score) included sub-indicators for the number of hazards started and completed and asset productivity. Quality management (15%) measured major breaches of mine action standards, and reporting (15%) measured the accuracy and timeliness of progress reports, mine and battle area clearance completion reports, quarterly operational plans, and response to demining investigations. The cost indicator (10%) is under review.[92]

MACCA reported that out of 380 quality checks it conducted in March 2010, 19 found minor non-conformities or breaches of standards and six serious non-conformities.[93]

Safety of demining personnel

One deminer from ATC was killed in Bamyan city and 31 deminers were injured in demining accidents in 2009, a drop of more than one-third from the 48 accidents MACCA reported in 2008. In the first half of 2010, one deminer was killed and seven were injured.^[94]

MACCA states that since demining started in Afghanistan in 1989, IMSMA records show 120 deminers have died as a result of accidents and 792 were injured. MACCA said that it takes accidents very seriously but commented that “when this is viewed against the number of deminers at work in any given year, the percentage of the workforce affected by accidents is very small.”[95] A US Department of State OIG evaluation cited an unconfirmed report from July 2008 that 371 civilian deminers had been killed since the start of demining and noted “some media reports place the figure far higher.”[96]

Demining operators are arguably more at risk from deteriorating and unpredictable security than from the more manageable hazard posed by the mines and ERW they clear. MACCA’s integrated operating framework for Afghan year 1389 noted that “in the past year, deminers have been attacked, forcing plans to change and projects to be adapted.”^[97]

DDG experienced two attacks in 2009, the first on 15 July and the second five days later on 20 July in Balkh province, which resulted in the death of a group supervisor.^[98] Seven people working for MineTech International were killed in armed violence in 2009, including three armed security guards killed in an ambush in April, and four other MineTech staff killed in an ambush the next month as they transported equipment. In addition, a total of 30 deminers were abducted in six separate incidents in 2009, although all were subsequently released. A total of 18 other attacks on deminers resulted in loss of, or damage to, equipment and/or vehicles.^[99]

Casualties, abduction, and seizure of vehicles and equipment also occurred in the first half of 2010. Five DAFA deminers were killed and 15 injured when insurgents identified as Taliban detonated two remote-controlled improvised explosive devices (IEDs) near the parking area of a demining site in Kandahar province, setting off the second IED as those injured by the first were brought to agency vehicles for evacuation. DAFA said Taliban sources contacted by the local community described the attack as a misunderstanding and it resumed operations after a one-month suspension.^[100]

Other Risk Reduction Measures

RE is coordinated by MACCA and implemented by 75 teams drawn from the Afghan Red Crescent Society (44 teams), Handicap International (10 teams), DDG (seven teams), and the Association for Aid and Relief Japan as well as by the Mobile Mini Children’s Circus.[101] These agencies reportedly delivered RE to a total of 994,870 people in 2009.[102]

MACCA analysis in 2009 showed that 108 communities categorized as “highly impacted” or “highly impacted with victims” had received no RE and that a high proportion of these were in the central area of Afghanistan.[103] Armed conflict has also hampered RE delivery, particularly in the south and remote areas.[104]

However, MACCA hoped to expand coverage through a series of agreements with government ministries. It had already worked with the Ministry of Education to train child protection officers to deliver RE in schools and in 2009 started an initiative to set up school mine action committees with the participation of parents and community elders. In addition, it reached agreement in 2009 to provide training for up to 70 staff in NGOs working with the Ministry of Rural Rehabilitation and Development’s National Solidarity Program who would then serve as focal points for further RE training through the ministry’s network of community development councils. MACCA also reached agreement with the Ministry of Religious Affairs to incorporate RE messages into speeches broadcast nationally on Fridays as well as into its publications.[105]

The EU’s 2009 evaluation concluded that, “Mine risk education (MRE) is conceptually weak” and stated that, “MACCA’s MRE department needs to improve its understanding of the problem, and its solution, by investing time in analyzing victim data within the IMSMA database, and trends that this contains.”[106] In response, MACCA stated that it “did not agree with this statement of the evaluation and provided this feedback to the EC.”[107]