described it as “scrambled-together,” and noted, “The lesson plans are meant to be temporary. They’re not being piloted, they’re supposed to fade away. It’s in English only, and teachers are asking for Burmese.”124 Another NGO official involved in the process of developing the curriculum said, “it’s not super-basic, but it’s basic. It’s an interim measure. In the longer term we will need to have something more. OK, so many Rohingya kids never got much education. You need to not disincentivize the ones who are more advanced.”?25 UNHCR had voiced concerns about the informal curriculum as early as April 2018, at an education sector meeting: “LCFA [the informal education program] is not a curricula, and should be treated as transitional as it is not robust enough to be used as a curricula.”*6 The informal curriculum and the education sector’s plans do not adhere to key guidance and policies on education in emergencies that have been adopted by humanitarian agencies and NGOs. For example, UNHCR’s “Education in emergency standard,” intended to guide the agency’s response to humanitarian emergencies globally provides, among other things: e “All children have access to primary, secondary or context-appropriate preparatory or accelerated education of good quality during the first phase of an emergency.” e “Refugee children and youth are able to participate in accredited national education systems and programmes under similar conditions to local children.” e “The same standards apply to long term and emergency situations.”127 Delays in Approval and Implementation The project led by UNICEF to design the informal education program (the LCFA/GIEP) avoided crossing the government’s red lines on formal education, the use of the Bangladesh curriculum, and instruction in Bengali language. Despite these precautions, it took the government one full year to approve the first two “levels” of the informal education program, in April 2019.*28 At the time of writing, it had still not approved the rest 124 Human Rights Watch interview, international NGO education official, Cox’s Bazar, February 18, 2019. 125 Human Rights Watch interview, international NGO official, Cox’s Bazar, February 19, 2019. 126 Cox’s Bazar Education Sector Meeting Notes, April 11, 2018. 127 UNHCR, “Education emergency standard,” https://emergency.unhcr.org/entry/53852/education-emergency-standard, accessed September 3, 2019. Bullet points in original. 128 1SCG Cox’s Bazar, Situation Report Rohingya Refugee Crisis, April 2019 p. 4, https://reliefweb.int/sites/reliefweb.int/files/resources/sitrep_april_2019.pdf (accessed July 25, 2019). “ARE WE HUMAN?” 40