kind.”**3 Nonetheless, because of government restrictions it is a workaround that meets neither the minimal requirements of access to quality education without discrimination under international law, nor humanitarian education standards.™4 “The objective in 2018 was to ramp up the number of learning centers, but now the priority is the quality of education,” a humanitarian official said in February 2019."5 To address the “lack of standardized and relevant teaching and learning materials,”*** among other problems, UNICEF spearheaded the creation ofa new informal education program, initially named the Learning Competency Framework and Approach (LCFA), to which the government eventually responded with a policy document it called Guidelines for Informal Education Programming (GIEP). Developed for UNICEF by Dhaka University and BRAC University, the British Council, and members of the humanitarian education sector, the informal education program will comprise five “levels,” which are intended to provide informal education from pre-primary to the rough equivalent of secondary school.” Although it is not officially recognized as or equivalent to a curriculum, the informal education program is structured as one: it includes lesson plans, Burmese language textbooks, and for older children, increased numbers of subjects and hours of instruction. For children who advance to levels three and four of the informal program — which have not yet been approved by the government — the number of subjects should increase to include science and history. If Bangladesh approves these levels, the increase in subjects will also necessarily require the number of “contact hours” between students and instructors to increase as well. This change would limit the learning centers offering these levels to two shifts per day rather than three and as a result each center will be able to accommodate fewer students.*8 The humanitarian groups in the education sector plan to cluster learning centers together to compensate. 113 UNICEF, Beyond Survival: Rohingya Refugee Children in Bangladesh Want to Learn, p. 11. 114 See, e.g., Inter-Agency Network on Education in Emergencies, “Minimum Standards for Education: Preparedness, Response, Recovery,” 2012, p. 78, https://inee.org/system/files/resources/INEE_Minimum_Standards_Handbook_2010%28HSP%29_EN.pdf (accessed September 4, 2019). 145 Human Rights Watch interview, senior humanitarian agency official, Cox’s Bazar, February 16, 2019. 116 3019 Joint Response Plan for the Rohingya Humanitarian Emergency, January-December, p. 35. “17 The first four levels are meant to be equivalent to pre-primary through grade 8. UNICEF, “Humanitarian Action for Children: Bangladesh,” January 2019, p. 3, https://www.unicef.org/appeals/files/2019-HAC-Bangladesh(2).pdf (accessed June 3, 2019). 118 Human Rights Watch interviews, senior humanitarian agency official, February 16, 2019; Bangladeshi INGO education specialist, Cox’s Bazar, February 18, 2019. “ARE WE HUMAN?” 38