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International donors and humanitarian agencies provided generous assistance to build houses for Rwandans who had none-and who were grateful for the help-but some of their aid was used to create imidugudu to which rural-dwellers were forced to move against their will. In an ironic twist, the program which donors supported in hopes of ending homelessness covered another which caused tens of thousands of Rwandans to lose their homes. Praise for the generosity and promptness with which donors responded to the housing program must be tempered by criticism of their readiness to ignore the human rights abuses occasioned by the rural reorganization program that operated under its cover.

In late 1996 international actors had several reasons to feel guilty about their behavior towards Rwandans. Not only had they failed to end the 1994 genocide, they had also refused to halt the rearming and reorganizing of genocidal forces in the refugee camps in Zaire. Once the Rwandan army and their allies in Zaire began attacking the camps, international actors made a feeble, short-lived effort to organize a military force to assist civilians. But they rapidly backed down when the Rwandan troops destroyed the camps and then stood by-largely in silence-while the Rwandan and allied forces chased down and slaughtered refugees who did not return promptly to Rwanda. The U.S., among others, blocked efforts by UNHCR to protect the refugees and contested their reports about the numbers who had fled into the Zairean forests. Other governments less closely identified with the Rwandan government understood that the slaughter of tens of thousands of persons was being covered up, but took no effective action to challenge the pretense that all real refugees-those not associated with genocidal militia or soldiers-had returned to Rwanda.41


With the return of the refugees, the need for housing was clear. Meeting that need allowed international actors to demonstrate their support for the Arusha Accords while also assuaging the guilt they felt-whether towards Tutsi or Hutu, or both. As the UNDP representative wrote in a discussion paper in January 1997:

The current shelter construction programme is important, not only in itself but
also as a tangible symbol of international assistance which is important both
for the Government and for donors. The physical construction of housing will
become a visible benchmark of the effectiveness of international assistance,
and as such will assume an importance over and beyond the meeting of
housing needs. 42

When Rwandan officials decided to reorganize rural residence patterns and to use new housing programs to that end, they did not immediately inform the donors who were funding the programs. Nor did national authorities tell all of the agencies doing the construction about the new requirements to build only in government-designated sites. They left it to local officials to deliver the orders to some of them. When agencies which had been repairing or building houses outside imidugudu found their programs halted, they then carried the word back to the donors.43

The Dutch and the German representatives who had been discussing large contributions to housing programs in December 1996 were disconcerted to learn a month later that the government had initiated the imidugudu policy without even mentioning it to them. The U.S., which had $25 million earmarked for housing rehabilitation, found implementing agencies blocked in the field when they tried to rebuild houses.44

Donors were annoyed at not having been informed about the habitat policy. But beyond that many reacted negatively because they doubted that moving people into imidugudu would deliver the anticipated economic benefits. The representative of UNDP, for example, wrote that the dispersed habitat in Rwanda was not just a cultural preference but a rational strategy for survival given the current economic conditions.45

Donors raised other objections in terms of practical politics: they feared that dictating such a drastic change in living patterns from the top down could arouse popular animosity against the government and they worried that beginning such a major program without legislation could lead to legal complications.46

It seems that donors did not include possible human rights violations among their objections to rural reorganization even though they apparently understood very quickly that some rural-dwellers had been or might be forced to leave their homes against their will. In

early February 1997, just weeks after the implementation of the policy began, the representative of the European Community Humanitarian Office, a funding agency of the European Union (E.U.), was so concerned about forcible relocation that he stated twice in a brief note that only programs of "voluntary settlement"could secure funding from the European Commission.47 At a meeting a week later between representatives of embassies and humanitarian agencies, one participant reported that "in some parts of the country,everybody is asked to pack and settle at new sites." Several participants doubted official assurances that coercion would not be used to force rural-dwellers to relocate.48

In early 1997 donors were already concerned enough about imidugudu to commission a study of the program which was completed in May 1997. In a generally negative assessment, the report summarized the experience of government-directed villagization efforts in other countries, all of which had failed. Drawing on the opinion of agricultural experts, it raised questions whether land consolidation would necessarily raise yields, particularly if cultivators lived at greater distances from their fields. It expressed concern too at the likelihood of crops or livestock being stolen from distant fields and at the probability that farmers would raise fewer head of livestock in the imidugudu. It deplored the waste of resources involved in destroying existing houses and abandoning near-by infrastructure like roads, wells, and latrines.49

The report went further to repeat the suspicions of some observers that the Rwandan government was seeking to undo that part of the Arusha Accords which effectively consigned Tutsi returnees to settlements in previously unoccupied-and largely undesirable-lands. These observers speculated that the government intended to move other rural-dwellers from their holdings and into imidugudu so that it could more easily redistribute desirable lands to the returnees.50 The author of the study pointed out that such redistribution would violate both customary users' rights to the land and the guarantee given to Hutu refugees in the September 1996 ministerial order. The author also remarked that ". . .the choice of how to live and farm under the precondition that one does not harm the common interest is a fundamental human right."51 He raised concerns that the government had decided a matter of "fundamental" interest to the 95 percent of the population who were cultivators without consulting them.52 He concluded with some foresight that a program with so little popular backing could be executed only through the use of considerable coercion.53 After extensive interviews with representatives of donors, multilateral agencies, and NGOs, the author of the study concluded, "Donors and implementing partners are unhappy with the plans. . . ."54 Despite this general opposition to the policy, international actors mounted no coordinated, effective effort to deal with it.

In August 1997, the Ministry of Interior and Communal Development answered some of the criticisms formulated in the donor-sponsored report. It asserted that the culturalcontext of Rwanda was different from that of other countries where government-directed villagization had failed and hence that their experience was not relevant. It affirmed once more that resettlement was to be voluntary, encouraged by economic incentives.55

Donors heard the official rhetoric of Kigali better than they heard complaints from the hills. Even representatives of donor countries or agencies responsible for contributing millions of dollars to housing programs apparently made little effort to inform themselves about life outside the capital and relied for information on subordinates and humanitarian workers who themselves learned to filter out information that did not conform to the official Rwandan description of the situation. One agricultural expert employed by an embassy said that Rwandan officials let him understand that continued public opposition to rural reorganization might result in a request for him to be withdrawn from Rwanda. He then fell silent on the topic.56

From mid-1997 through 1998, donors seem to have dropped criticism of rural reorganization while they poured large amounts of money into housing programs.57 The U.S. was one of the few to end its bilateral aid to housing construction programs during this period. According to a U.S. AID employee, it did so because the programs were "messy," meaning troublesome to administer, not because they involved human rights abuses.58 And, as noted below, the U.S. did continue to contribute through U.N. agencies.

When the Rwandan government moved more than 650,000 people into camps during the insurgency in the northwest, the donor community accepted the argument that security concerns made the displacement necessary and contributed $22 million to support the camps. But when the government found the situation sufficiently under control in late 1998 to begin disbanding the camps and moving the displaced into imidugudu, the donors began to balk at further contributions for housing programs. Perhaps because Rwanda that year launched its second war in the DRC-once more claiming the demands of security as justification-donors were increasingly sceptical that security in the ravaged northwest necessitated a complete reorganization of rural life. They also found it difficult to ignore the use of force and coercion in Ruhengeri and Gisenyi, prefectures where much attention had been focused because of the insurgency. That local officials oversaw the destruction of some houses while at the very same time the government was asking money to construct others contributed to disillusionment among the donors. In addition, some data seemed to indicate that rural reorganization might actually cut agricultural production instead of increasing it.

The E.U., whose representative was one of the first in 1997 to caution about the importance of resettlement being "voluntary," expressed the newly critical mood in July 1999. Its Council of Ministers urged "careful planning, prior impact studies and pilotprojects in order to avoid villagisation that brings about human rights violations." Yet in the face of mounting evidence that "villagisation" was in fact resulting in human rights violations, the E.U. provided some $6 million that year to finance imidugudu.59

It is difficult to compute how much international aid was used to build houses in imidugudu. Assistance was sometimes funneled through budget lines that did not indicate exact use of the funds; aid from several donors sometimes paid for a single project; support for houses in imidugudu was not always distinguished from aid for houses built outside the sites. In addition, some bilateral aid was contributed through U.N. agencies.

Even with incomplete data, however, it is clear that international donors contributed tens of millions of dollars, most of which paid for construction in imidugudu.60 UNHCR served as the major conduit of funds to building programs between 1996 and 1998 when it spent at least $30.7 million dollars to build houses or to provide materials to build houses. Of this amount, $20.6 million paid for houses in imidugudu and another $10 million paid for construction materials for houses, the majority of which were also built in imidugudu.61 The Canadian Development Agency, the second most important donor after UNHCR, gave $16.3 million, at least $14.7 of which paid for houses built in imidugudu.62 The Netherlands, one of the first to give, contributed $10 million, most of which went for housing, and the U.S. spent $6.1 million in the course of 1997 for housing. Japan was also a major donor. The European Union contributed some $6 million to build 6,000 houses in 1997 and another nearly $6 million in 1999. France built houses in five imidugudu for a cost of $1.2 million. Germany also paid for housing programs.63 According to the Rwandan government, the Dutch, Japanese, Canadian and American governments were the largest donors through U.N. agencies.64

Difficult as it is to evaluate the total international contribution to housing programs, it is even more difficult to know how much of that money contributed to housing people who were homeless and how much contributed to housing people relocated against their will to imidugudu. And it is more difficult still to assess the extent to which the financial support of the housing programs betokened a political support which encouraged the Rwandan government to implement rural reorganization faster and more unconditionally than it might otherwise have done.

At the start international donors saw the imidugudu program as part of a long-term economic development effort and they discussed it in those terms. But as they realized that their criticism of rural reorganization created difficulties with the Rwandan government-which for many reasons they wanted to avoid-they accepted the official interpretation that imidugudu were necessary as an "emergency" response to an overwhelming housing crisis caused by the return of the refugees. By accepting this pretext, donors and representatives of international agencies relinquished the opportunity to examine rural reorganization in its appropriate context, as an undertaking for economic development. They failed to insist upon the usual requirements for planning, prior consultation with the target population, and enforcement of standards. And they failed to even consider, far less apply, international cautions against funding development projects that involve forced displacement. The U.N. Committee on Economic, Social and Cultural Rights stated in 1990, for example, that international agencies should "scrupulously" avoid involvement in projects which "involve large-scale evictions or displacement of persons without the provision of all appropriate protection and compensation."65

U.N. Agencies

U.N. agencies assisted enormously in implementing the resettlement program. Although aware of the abuses it entailed, they continued their support and failed to influence Rwandan authorities to end forcible displacement of rural-dwellers.

The most important international agency to participate in the imidugudu program was UNHCR which had been involved ever since the planning phase of the Arusha Accords. From its initial role as provider of emergency shelter for returnees it was drawn into the role of leading facilitator of the rural reorganization program. It provided about 80 percent of the funding channeled through U.N. agencies for housing construction.

At least one important UNHCR representative in Rwanda at the start of the imidugudu program disapproved of it and provided much of the critical analysis for the generally negative assessment sponsored by the donors, mentioned above. That document quoted a UNHCR representative as saying, "U.N. organizations do what governments want them to do in general, but they are fully sensitive to back-donors [i.e., the donors who support them]closing funding pipelines in rejection of governments [sic] policy."66 The official continued that UNHCR favored a common strategy by donors and NGOs to deal with the imidugudu policy but stressed that UNDP-not UNHCR- should take the lead in creating this joint effort.

It is true that UNDP was charged with coordinating the efforts of all U.N. agencies and in this sense might have had responsibility for assuming leadership on this question, but it was UNHCR which had an explicit mandate to protect refugees, including those recently returned to their home country.

Given the situation in early 1997 when the habitat policy was launched, however, it is easy to suppose why UNHCR preferred not to lead opposition to the imidugudu program. It had been blamed for "feeding the genocidaires," the perpetrators of genocide, in the Zairean camps for two years and it had just endured several weeks of bitter conflict with the Rwandan government and its chief foreign backers, particularly the U.S., over the question of how many refugees were in the Zairean forests and how best to rescue them. Taking a firm stand against abuses in the resettlement program would have set UNHCR once more against the Rwandan government and might have entailed being forced out of the country.

Once UNHCR launched building programs, they grew rapidly and the critical voice inside the agency was apparently not heard again. Despite its intimate connection with the imidugudu program and the opportunity to witness abuses involved in its implementation, UNHCR never denounced such practices as the forcible displacement of rural-dwellers and the order to destroy houses.67 Asked to comment on rural reorganization, one UNHCR staff member refused to make any assessment. "UNHCR is concerned only with shelter," she said, "not with government policy."68

UNDP, charged with long-term economic development programs, played a less important role in assisting resettlement, supplying perhaps 20 percent of the funding that came through U.N. agencies. According to one participant in UNDP meetings, abuses related to resettlement were never discussed within UNDP, even after the agency created a special unit for human rights issues.69

The two agencies differed in their approaches to resettlement programs: UNHCR focused on building houses as fast as possible, while UNDP favored more integrated projects involving infrastructure, services, and income-producing plans. The two agencies agreed to work together in 1997 and established the Joint Reintegration Programming Unit (JRPU) to facilitate this collaboration, yet they continued to have trouble coordinating their efforts, perhaps because they were similarly intent on using housing programs to maximize theamount of resources that came to their agencies.70 Concern for human rights apparently dropped from view in this competition.

In late 1999 UNHCR sent a team of external evaluators to assess the imidugudu program.71 Throughout the inquiry, local UNHCR agents stressed their role in providing "shelter," a term which suggested a short-term emergency response to the housing crisis provoked by the return of the refugees. But the evaluators concluded that UNHCR had done much more:

In the case of the SP[shelter program], UNHCR has embarked in an operation that is much wider than just building shelter. It is directly responsible for participating in theimplementation of a settlement policy, which will have long-term consequencesaltogether socially, economically and physically, and for which, up to now,sustainability has not been ensured.

Several paragraphs later, the report continues:

In four years, the "imidugudu" policy has modified drastically the aspect of the
rural landscape. The country is now covered with groups of tiny houses, all
alike, whether in size, shape, or type of materials; and UNHCR has heavily
contributed to this change by providing the materials or building 98,447 houses
in 252 settlement sites and in scattered locations all over Rwanda.72

In contacts with the evaluators and others, UNHCR minimized its role in the imidugudu by stating that only some 25 percent of its resources went to building houses in the settlements. This refers to construction programs done under its direct supervision. The rest apparently paid for housing materials, primarily roofs, doors, and windows, that were distributed through local authorities. UNHCR says these materials built houses that were "scattered," implying that these houses were not in imidgudu. But the data, includinginterviews with imidugudu residents presented in the report, indicates that some-and probably the majority-of these materials were used to build houses in imidugudu.73

Although the evaluators criticized UNHCR involvement in the imidugudu program from several points of view, including the possibility that the settlements would not be economically sustainable, they failed to address the human rights abuses which had taken place during its implementation. They said only that the "absence of specific indicators" made it impossible for them to evaluate how well the program fulfilled the protection component of the UNHCR mandate, the component which includes questions of human rights.74

After reviewing their records, UNHCR officials in Geneva told a Human Rights Watch researcher that they could find no UNHCR report about or denunciation of human rights abuses in connection with the resettlement policy. One remarked, "We decided to keep our mouths shut and help those whom we could help." Another judged UNHCR conduct more severely, saying, "We were complicit. . . but so were all the U.N. agencies."75

The World Food Program provided food that was used to pay workers who built houses in many imidugudu. Although their agents frequently had contact with local people and witnessed the abuses to which they were subject, there is no indication that they protested against them or reported them systematically to their superiors.

The special representative for Rwanda of the U.N. Commission on Human Rights is charged with technical assistance in the field of human rights rather than with monitoring abuses. Nonetheless his opinion was sought-probably by donors-on issues related to the habitat policy. He visited three imidugudu after having heard allegations of the use of coercion to get rural-dwellers to move. After learning, as noted above, that twenty families in one umudugudu had been told to destroy their homes and relocate, he concluded that some coercion had occurred, often for reasons of security. He remarked that with security improving in the country, this justification would have declining relevance as a reason for obliging people to leave their homes. He added that the Guiding Principles on Internal Displacement require that persons displaced for security reasons be allowed to return home when the emergency is over.

But the special representative did not address the situation of persons coerced to move for other than security reasons-certainly the case for many-nor did he discuss their right to return to their former homes. He noted the reassurance given by a presidential adviser that "no Rwandans will be forced into villages against their will" and expressed the hope that this would become formal government policy. It is hard to understand such optimism, unless perhaps he had not known that government officials had first made the same guarantee in1997 and had repeatedly violated it since. Aware of the importance of land to subsistence cultivators, the special representative encouraged greater debate on the habitat policy. But rather than clearly denouncing its abuses and insisting that those already displaced be permitted to return home, he recommended merely that the conditions of life be improved in existing settlements. He suggested that if services were provided before people were asked to move, rural-dwellers "would be clamouring for admission" to imidugudu.76

As noted below, the special representative endorsed the need for more funds in 2000 to build houses in imidugudu.

Nongovernmental Organizations

Of all the foreign parties involved in establishing imidugudu, the staff of NGOs were closest to the people suffering the abuses. By and large, they too kept silent about the hardships they witnessed. As resources flooded in to pay for the construction of houses, the Rwandan government informed many NGOs new to Rwanda-and new to housing construction-that they must start building programs. Rwandan authorities also set the terms under which the projects were to be carried out. Inexperienced NGOs quickly caved in to the pressure, many of them well aware that the government had expelled some two dozen NGOs more than a year before when they had failed to meet its expectations.

Some saw the well-funded housing contracts as a way to sustain their own presence in Rwanda and did not question the potentially negative effects of their work on some rural residents. Just as one UNHCR staff member shifted all responsibility for rural reorganization to the government, so one NGO employee put the burden on UNHCR as well as the government. He said: "If UNHCR offers you a job, you are happy to accept it. We are only invited [to do this work], the government and UNHCR set the policy."77

The staff of more scrupulous organizations worked harder to protect the interests of rural-dwellers. Those best established in Rwanda and most familiar with local politics sometimes managed to continue the programs they had begun, even if they did not conform to the imidugudu policy.78

In Kibungo, Umutara, and Kigali-rural, however, even the strongest NGOs found it difficult to implement their own policies and maintain their standards. The Lutheran World Federation (LWF), one of the best established NGOs in Rwanda, had staff who foresaw potential abuses in the imidugudu program. In March 1997, the head of its Kigali office informed other staff that: "People have the right to choose the manner in which they build and locate their houses, subject to the overriding concerns of a society as determined by its laws." Under the heading "policy," he noted:

LWF will only assist with new villages in already settled areas when it is absolutely
clear that those being resettled:

Do not destroy the houses they are leaving, but vacate them for others

Are moving of their own free will

Will have a reasonable level of service in the sites to which they are moving.79

According to one senior staff member speaking in October 2000, "LWF still applies the principle" spelled out in 1997.80

The difficulty in upholding such principles emerge from the case of Ndego, an umudugudu in Kibungo where LWF assisted in building the houses. Land at the new site is infertile and dry and the new settlement lies in the former game park, distant from other population centers. According to the UNHCR evaluation report, some 166 families from the neighboring commune of Nyarubuye were forced to come to the umudugudu against their will, leaving behind lands that were then turned over to a single person, reportedly a military officer. When asked about the case, the senior LWF staff member said the agency was responsible only for building the houses, not for choosing who would occupy them. She added that when some 400 to 500 families returned from Tanzania in 1997, authorities declared that the returnees could not go back to their homes because the region was insecure and that they had to settle instead in the umudugudu.The security threat is long since finished, but the families remain in the settlement site while the land around their former homes is used to pasture cattle. As a result of the visit of the UNHCR evaluation team, this case was reported to the authorities and has received some attention which might help remedy this abuse.81

41 See Human Rights Watch, "What Kabila is Hiding: Civilian Killings and Impunity in Congo," October 1997, Vol. 9, No. 5 (A).

42 Discussion Paper, "Shelter, Settlement and Beyond. . ." enclosed in Omar Bakhet, UNDP Resident Representative and U.N. Resident Coordinator, to Ambassadors and Charge d'Affaires, Heads of U.N. Agencies, January 23, 1997. Emphasis in the original.

43 Minutes, Meeting of diplomats regarding housing polcies, February 12, 1997.

44 Human Rights Watch interview, Kigali, May 26, 2000; Minutes,meeting of diplomats regarding housing policies, February 12, 1997; Minutes, Meeting of diplomats regarding housing policies, February 21, 1997; Anonymous, "Imidugudu," pp. 6-8.

45 Omar Bakhet, UNDP Resident Representative and U.N. Resident Coordinator to Ambassadors and Heads of U.N. agencies, January 23, 1997.

46 Minutes, Meeting of diplomats regarding housing policies, February 12, 1997; Minutes, Meeting of diplomats regarding housing policies, February 21, 1997.

47 European Community Humanitarian Office-Rwanda, Note for the File, Shelter funding criteria, February 5, 1997.

48 Minutes, Meeting of diplomats regarding housing policies, February 12, 1997.

49 Anonymous, "Imidugudu," pp. 25-29.

50 Anonymous, "Imidugudu," p. 6. As noted above, Human Rights Watch documented several cases of persons who moved to imidugudu after ceding all their land to returnees.

51 Ibid., p. 27.

52 Anonymous, "Imidugudu," draft working paper, pp. 11, 14.

53 Anonymous, "Imidugudu," p. 25.

54 Anonymous, "Imidugudu," p. 26.

55 Dorothea Hilhorst and Mathijs van Leeuwen, "Villagisation in Rwanda," Wageningen Disaster Studies, no. 2, 1999, Rural Development Sociology Group, Wageningen University, The Netherlands, p. 16.

56 Human Rights Watch interview, Kigali, May 23, 2000.

57 Human Rights Watch interviews, Kigali, May 23 and October 23, 2000.

58 Human Rights Watch interview, Washington, by telephone, September 14, 2000.

59 United Nations. Economic and Social Council. Commission on Human Rights. "Report . . . by the Special Representative, Mr. Michel Moussalli," p. 32; Laurent and Bugnion, "External Evaluation of the UNHCR Shelter Program," p. 19.

60 Houses built by the ECHO program averaged $1232 per unit between 1996 and 1998 and $794 per unit in 1999; those built by the French averaged $1,130 per unit; and those built by various Canadian-funded agencies cost some $1439, not including an expensive set of 100 houses built at a cost of $3900 by the city of Kigali. In some cases, donors provided only roofing materials, which ordinarily cost less than $200. Laurent and Bugnion, "External Evaluation of the UNHCR Shelter Program," pp. 19-21, 105-107.

61 Laurent and Bugnion, "External Evaluation of the UNHCR Shelter Program," pp. 4, 19.

62 Ibid., pp. 105-07.

63 Ibid., pp. 18-21; Anonymous, "Imidugudu," pp. 6,8; Human Rights Watch interviews, Kigali, May 26, August 11 and 13, and by telephone, September 14, 2000.

64 Government of Rwanda, "Thematic Consultation, pp. 8-9.

65 U.N. Committee on Economic, Social and Cultural Rights, General Comment No. 2 on the Right to Adequate Housing (Art. 11.1) Forced Evictions, 1990, paragraphs 6 and 8(d). See also Human Rights Watch, Written statement submitted to the Commission on Human Rights, E/CN.4/1996/NGO/41, 23 March 1996.

66 Anonymous, "Imidugudu," p. 5.

67 Human Rights Watch interview, Geneva, October 6, 2000.

68 Human Rights Watch interview, Kigali, January 17, 2000.

69 Human Rights Watch interview, Kigali, August 15, 2000.

70 CCA Working Paper, no. 3, p. 6; Laurent and Bugnion, "External Evaluation of the UNHCR Shelter Program," pp. 25-6; Hilhorst and van Leeuwen, "Villagisation in Rwanda," pp. 23-24. The World Food Program joined the JRPU in 1998 and representatives of other U.N. agencies collaborated with it occasionally.

71 In order to assure maximum transparency, the investigators included a Rwandan government official and another Rwandan consultant to the Swiss embassy in their work team. Their presence in interviews may have considerably altered the quality and quantity of information provided by imidugudu residents.

72 Laurent and Bugnion, "External Evaluation of the UNHCR Shelter Program," pp. xi-xiii.

73 Laurent and Bugnion, "External Evaluation of the UNHCR Shelter Program," pp. xi, 4, 19, 63, 65. But some 13,000 of the 98,447 houses were repaired rather than built new and hence were likely not in imidugudu.

74 Laurent and Bugnion, "External Evaluation of the UNHCR Shelter Program," p. x.

75 Human Rights Watch interviews, Geneva, October 12 ,13, and 26, 2000.

76 United Nations, Economic and Social Council, Commission on Human Rights, "Report . . . by the Special Representative, Mr. Michel Moussalli," pp. 32-33.

77 Hilhorst and van Leeuwen, "Villagisation in Rwanda," p. 24.

78 Human Rights Watch interview, by telephone, Washington, September 14, 2000.

79 John Cosgrave to Project Coordinators, Lutheran World Federation, March 4, 1997.

80 Human Rights Watch interview by telephone, Geneva, October 13, 2000.

81 Ibid; Laurent and Bugnion, "External Evaluation of the UNHCR Shelter Program," pp. 44, 96.

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