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Abstract

Over the past three decades, the Association of Southeast Asian Nations (ASEAN) has sought to address transboundary haze pollution resulting from land and forest fires in Southeast Asia. While ASEAN has served as the primary platform for regional discussions on haze, private initiatives have played an increasingly important role in governing land and forest fires across the region. This study aims to provide empirical insights into the roles and involvement of civil society organisations (CSOs) in managing haze in Indonesia, Singapore, and Thailand. It argues that CSOs have functioned as decision-making centres and have undertaken a range of indispensable roles. Their power and strategies are determined by various factors, including broader institutions and considerations related to collaborative partners. Despite certain limitations and shortcomings, their efforts have contributed to the advancement of polycentric environmental governance – a development that diverges from the prevailing trend of democratic regression in Southeast Asia.

Keywords

Haze land and forest fires polycentric governance civil society organisations ASEAN democratisation

Introduction

Over the past three decades, the Association of Southeast Asian Nations (ASEAN) has sought to address transboundary smoke pollution, commonly known as “haze,” in Southeast Asia. Primarily caused by land and forest fires, haze is one of the region's most severe environmental challenges, resulting in billions of dollars in economic, environmental, and social losses annually. The transboundary nature of haze has rendered ASEAN – the first and still the most significant regional organisation in Southeast Asia – the central platform for addressing the problem.

Since the early 1990s, ASEAN has introduced a series of regional initiatives and policies, including the 1995 ASEAN Cooperation Plan on Transboundary Pollution, the 1997 Regional Haze Action Plan, the 2002 ASEAN Agreement on Transboundary Haze Pollution (AATHP), and the 2016 Roadmap on ASEAN Cooperation towards Transboundary Haze Pollution Control with Means of Implementation (ASEAN Haze Roadmap). These regional frameworks have arguably contributed to the development of an evolving international regime for governing haze as well as land and forest fires in Southeast Asia (Heilmann, 2015; Nguitragool, 2011).

Despite regional commitments and concentrated efforts, significant challenges persist. Scholars and observers have emphasised the link between the weakening of environmental protection and the decline of democratic institutions – manifested in persistent corruption, the expansion of regulatory controls, the manipulation of electoral outcomes, and the increasing polarisation of civil society throughout the region (Bangkok Tribune, 2024; Bünte and Weiss, 2023; Gomez, 2025; Tomsa and Bax, 2023). Furthermore, regional bodies such as ASEAN have struggled to effectively address transboundary environmental issues, such as haze pollution, further exacerbating frustration and concern among both domestic and international stakeholders.

This study employs an actor-oriented approach, which has been largely overlooked in conventional governance analyses (Heikkila et al., 2018; Morrison et al., 2019), to investigate the strategies and involvement of CSOs in managing haze in Southeast Asia. It argues that CSOs have functioned as decision-making centres and undertaken a range of indispensable supporting roles. Their power and strategies are determined by various factors, including broader institutions and considerations related to collaborative partners. Despite certain limitations and shortcomings, their actions have contributed to the development of polycentric environmental governance – a development that diverges from the prevailing trend of democratic regression in Southeast Asia.

Adopting a qualitative methodology, the study investigates the roles and engagement of CSOs in in Indonesia, Singapore, and Thailand – countries where such organisations have played critical roles in managing transboundary haze pollution within the ASEAN region. One CSO from each country is selected based on its relevance and impact on haze governance: the Indonesian Forum for the Environment (Wahana Lingkungan Hidup Indonesia, or WALHI, also known as Friends of the Earth Indonesia), the Singapore-based People's Movement to Stop Haze (PM Haze), and the Chiang Mai Breathe Council (CMBC) from Thailand. These organisations represent different types of CSOs: an established environmental advocacy group, non-governmental organisation, and issue-specific civil movement respectively. The data were collected primarily through interviews and documentary research between 2021 and 2024, and were supplemented by participant observation between 2023 and 2025.

While the analysis of these cases may involve some degree of comparisons, it must be noted that this is not a comparative study. Rather, by unpacking the function of civil society within polycentric governance frameworks, the cases provide valuable insights into collaboration and conflict, legitimacy and accountability of non-state actors, and resource mobilisation across various levels of governance. Polycentric governance frameworks in the ASEAN environmental space may inform the evolution of governance frameworks in other ASEAN issue-areas. These findings not only contribute to a broader understanding of environmental governance within the context of uneven democratisation and ASEAN regionalism, but also offer a meaningful addition to the theoretical literature – particularly the expanding scholarship on the power dynamics within polycentric governance.

The article is divided into five parts. Following the introduction, it examines the concept of polycentric governance within the context of ASEAN regionalism and offers a brief overview of haze governance in Southeast Asia. It then focuses on the engagement of the three CSOs. The final section summarises the main findings.

Polycentric Governance and Environmental Management in the ASEAN Region

The Concept of Polycentric Governance

Building upon the work of Ostrom et al. (1961), the concept of polycentric governance has gained significant attention from both scholars and policy practitioners as a potential solution to governance failures arising from problems at opposite ends of the continuum. One issue is over-centralisation, which, at least in theory, renders governance policies rigid and less responsive to local needs, thereby reducing overall effectiveness. Another issue is fragmentation, which arises when coordination among governance arrangements and actors is insufficient or entirely lacking (Heikkila et al., 2018; Pahl-Wostl and Knieper, 2014). As several scholars have rightly pointed out, fragmentation is particularly prevalent at the global level due to the complexity of international problems and the involvement of numerous actors, institutional arrangements, and mechanisms (Biermann et al., 2009).

Acknowledging the roles of diverse actors and institutions, which exist at different levels, in different sectors, and for different purposes (Araral and Hartley, 2013), polycentric governance emphasises the existence and interaction of multiple relatively autonomous governmental or non-governmental units, each capable of making and enforcing rules and functioning as a decision-making centre (Schröder, 2018). Private standards organisations (PSOs), for instance, may develop and implement mandatory requirements and standards to regulate the social and environmental impacts of business activities. Despite the emphasis on the ability to create and enforce formal rules, citizens and local communities, who are capable of self-organising their own resource management systems through the creation of norms and non-mandatory regulations, may also be seen as decision-making centres (Carlisle and Gruby, 2019).

Characterised by the distribution of decision-making power and effective coordination (Pahl-Wostl and Knieper, 2014: 140), polycentric governance can be perceived as ‘a complex combination of multiple levels and diverse types of organisations drawn from the public, private, and voluntary sectors that have overlapping realms of responsibility and functional capacities’ (McGinnis and Ostrom, 2011: 15). Even without formally assigned public roles, non-state actors such as private corporations, voluntary associations, and community-based organisations can play indispensable supporting roles in polycentric governance (McGinnis and Ostrom, 2011). They may also compete, collaborate, or form alliances with one another or with state actors (Stephan et al., 2019).

The complex relationships among these actors offer numerous opportunities. As its advocates contend, if competition over distributional issues and conflict regarding values can be kept under control and resolved, polycentric systems are likely to enhance innovation, adaptability, responsiveness to local needs, institutional appropriateness for natural resource systems, and risk mitigation through the concurrent operation of diverse units (Carlisle and Gruby, 2019; Ostrom, 2010). According to Morrison et al. (2017), as individual actors consider one another, mutual adjustment is likely to occur. Self-organisation and mutual adjustment are the defining features that differentiate polycentric systems from over-centralised or fragmented systems (Morrison et al., 2017: 3).

The ASEAN Context and Power Typology

For Southeast Asia, the idea of polycentric governance has been applied infrequently by policy practitioners, despite calls to expand it beyond established regional institutions, which remain largely state-centric (Hirsch, 2020: 200). Scholarly attempts to employ a polycentric approach as an analytical tool for examining governance in the region have also been relatively scarce (Amaruzaman et al., 2022; Fasting et al., 2021). Implementing this approach at the regional level presents particular challenges for at least two reasons. First, as Heikkila et al. (2018: 207) observe, the diversity of polycentric governance in design and function, combined with the fact that no governance systems are entirely centralised or decentralised in practice, has made the concept somewhat nebulous and difficult to operationalise or quantify. Furthermore, regional governance in Southeast Asia is deeply intertwined with ASEAN regionalism, which is especially elitist, state-centric, and institutionally shallow due to mutual distrust and adherence to principles of non-intervention/non-interference, consultation, consensus, closed-door diplomacy, state sovereignty, and sovereign equality – collectively known as the ‘ASEAN Way’ (Weinrich, 2021). Consequently, regional bodies such as the ASEAN Secretariat, which are responsible for coordinating common efforts, remain institutionally weak. Mechanisms enabling domestic stakeholders, especially CSOs, to communicate and interact with ASEAN and other stakeholders also highly limited (Elliott, 2011; Tadem, 2017).

Despite conceptual and theoretical limitations, polycentric governance retains both normative and practical value, inspiring efforts to study and develop governance systems across various regions and at the global level (Amaruzaman et al., 2022; Burns, 2021; Koinova, 2022). Moreover, as Fortnam et al. (2022) observe, polycentricity can emerge and evolve through multiple pathways in different contexts. One such pathway involves the transformation of a classic international regime into a polycentric system, as seen in the case of climate change (Pattberg et al., 2018). Transnational polycentric governance may also develop through collaborative relationships that lack formal negotiations, resulting in the development, promulgation, and institutionalisation of rule sets and practices that extend beyond national borders (Gallemore, 2017).

Thus, although ASEAN has been criticised for relying on soft-law instruments that are imprecisely worded and contain weak enforcement provisions (Leviter, 2010: 169), these mechanisms are not entirely ineffectual. Indeed, the mechanisms and arrangements constituting the ASEAN haze regime have institutionalised and formalised certain collaborative relationships. In practice, their flexibility may even allow key decision-making centres to experiment and seek solutions tailored to the specific contexts of their respective states.

Central to this study are CSOs, whose roles and initiatives have been instrumental in shaping the region's evolving haze governance. Following the Organisation for Economic Co-operation and Development's definition (OECD), CSOs encompass non-governmental organisations (NGOs) as a distinct sub-category (OECD 2010, 26). Since the roles of CSOs can only be fully understood by examining their capacity to influence the goals, processes, and outcomes of polycentric governance (Morrison et al., 2019: 2), this study adopts an actor-oriented approach that incorporates a typology of power. Morrison et al. (2019) identify three interrelated forms of power in polycentric environmental governance: power by design, pragmatic power, and framing power.

In brief, power by design refers to an authoritative power conferred by law, making it legitimate and allowing actors to set rules and design incentives (Morrison et al., 2019: 3). Shaped by broader institutional arrangements, it may entail coercive power and grant access to material resources crucial to the legal enforcement and implementation of governance activities. In contrast, pragmatic power derives from local recognition. It emphasises the abilities to interpret, accept, or reject norms and rules (either formal or informal) established by other authorities. It also involves the ability to connect and build networks with other governance actors (Moon, 2019). This type of power influences policy implementation and decision-making effectiveness and can be observed from actors’ innovation and experimentation (Moon, 2019: 3–4). Finally, framing power is the ability to shape perceptions and influence discourse through strategic narrative construction (Moon, 2019: 4–5). As a power to (re)construct a subjective reality, it directly affects perception and prioritisation, (de)legitimising certain bodies of knowledge and policy options while shaping social structures in environmental governance (Koch et al., 2021).

Although the three types of power highlight actors’ agency and can be analysed separately, they are not entirely independent of one another. Indeed, actors’ capacity to exert power and formulate strategies is influenced by the broader institutional contexts, prevailing power constellations, and existing authority structures that enable or constrain particular actions. Within these settings, different types of power often interact and intersect. Moreover, the literature on policy networks and advocacy coalitions suggest a significant interdependence among advocacy strategies, collaborative relationships, and underlying beliefs. According to Wagner et al. (2023: 63), actors carefully consider both their collaborative partners and those who share similar beliefs. Within policy networks, actors connected through collaborative ties are likely to adopt comparable strategies, such as direct engagement with decision-makers and participation in policy making (insider strategies), or mobilisation and public advocacy (outsider strategies). Additionally, beyond their immediate advocacy networks, they observe and learn from strategic choices made by others they perceive as like-minded.

A Brief Overview of Haze Governance in Southeast Asia

Like many other environmental issues, haze governance in Southeast Asia is highly complex, involving a diverse range of stakeholders and institutions across various sectors, including agriculture, forestry, environment, public health, provincial and local administrations, local communities, and private companies. In Indonesia alone, 96 national and provincial government agencies are responsible for controlling fires (Purnomo et al., 2021). Additionally, haze governance is characterised by ASEAN's intergovernmentalism and the absence of strong legal institutions at the regional level for regulating environmental issues. The lack of a centralised authority means that member states retain a high degree of autonomy in managing their natural resources. However, under AATHP, they are obligated to develop effective means and measures to prevent and monitor fires and haze. Decision-making also occurs within other regional and sub-regional bodies such as the Committee (COM) for the Conference of the Parties under the framework of AATHP, the Technical Working Group of the Sub-regional Ministerial Steering Committee (MSC) on Transboundary Haze Pollution, and the Sub-regional MSC on Transboundary Haze Pollution in the Mekong Sub-region (MSC Mekong), which have devised action plans and monitored the implementation of the AATHP and regional programmes. However, rulemaking and enforcement are carried out by governmental agencies, including those at the national and sub-national levels, as well as relevant ministries in each member state.

In Indonesia, dozens of Presidential Directives and ministerial regulations were issued between 2016 and 2023. In Thailand, significant steps were taken in 2019 when dust particles – including those from open burning and forest fires – became a national priority. Major laws, such as the National Parks Act and the Community Forest Act, were respectively amended and enacted to improve, among other things, forest governance and forest fire management. In a country like Singapore, where forest and agricultural burning are rarely significant concerns, market-based instruments such as the Singapore Green Labelling Scheme have been adopted and enhanced to ensure effective peatland management, strict compliance with a zero-burning policy, and a commitment to early fire detection and suppression. In 2014, the Singaporean government also passed the Transboundary Haze Pollution Act (THPA). By establishing extra-territorial liability for activities that cause or contribute to haze in Singapore, the law has become a model for other ASEAN countries, setting the stage for stricter regional haze governance.

Certification schemes initiated by both the public and private sectors are also noteworthy. Examples include the private led and voluntary Roundtable for Sustainable Palm Oil (RSPO), the WWF Palm Oil Buyers Scorecard, and the government-initiated Indonesian Sustainable Palm Oil and Malaysian Sustainable Palm Oil standards. These initiatives have been created to curb unsustainable practices, including peatland drainage and the slash-and-burn agriculture, which have been identified as the main causes of fires and transboundary haze pollution in the region. They can also be viewed as indicators of the dissemination of ideas such as sustainability, which has played a fundamental role in environmental governance over the past decades.

While market-based instruments and certification schemes are growing in sectors such as palm oil in Malaysia and Indonesia, critics argue that some of these instruments serve as attempts to “greenwash” and legitimise the expanding and inherently damaging palm oil industry (Isenhour, 2014: 261). Equally concerning is the rising frequency and severity of fires and haze in mainland Southeast Asia, where millions of hectares of forest have been burned and converted into agricultural land for the cultivation of rice, maize, and sugarcane over the last two decades. Although slash-and-burn agriculture has been blamed for the region's annual haze, fires in forest and protected areas remain a serious concern in some countries. In Thailand, for instance, about 80 per cent of fire hotspots in northern provinces are reportedly located within forest areas, while the remaining 20 per cent occur on agricultural land (Thai News Network Online, 2023). Despite the Ministry of Agriculture and Cooperatives’ introduction of agricultural standards and good agricultural practices, which prohibit the use of fire for crop cultivation, burning continues to be widely practiced as a cost-effective method for land clearing. According to Sereenonchai and Arunrat (2022), the adoption of non-burning alternatives remains unpopular among small-scale Thai farmers due to a lack of financial incentives.

The CSOs in Southeast Asian Haze Governance

CSOs have long been key actors in regional haze politics and governance, despite their lack of formal authority. Along with private enterprises and local communities, CSOs are recognised as stakeholders who can engage in efforts to address regional haze under the AATHP. While some transnational NGOs are able to act as “functional equivalents” of official authorities due to their ability to initiate and enforce private standards (Nesadurai, 2016), others have played different roles in recent years. This section examines the mobilisation efforts and strategies of three major CSOs that act as key decision-making centres in haze governance: WALHI, CMBC, and PM Haze.

WALHI – Supporting Law Enforcement and Promoting Accountability

WALHI is one of the largest, most established, and most vocal environmental NGOs in Southeast Asia. At the meeting where it was founded in 1980, representatives from seventy-nine NGOs with diverse areas of expertise and backgrounds were present (Kalmirah et al., 2023). In 1989, it joined Friends of the Earth International (FoEI), which shaped WALHI's role as a forum and strategic alliance within local and international networks. Through its regional offices in 28 provinces, it has exercised pragmatic power in forging collaborations and partnerships with local communities, academic institutions, and more than 400 NGOs, such as University Airlangga's SDGs Centre, the Indonesian National Student Movement (Gerakan Mahasiswa Nasional Indonesia), and the Sumatran Elephant Foundation (Yayasan Gajah Sumatra – Yagasu). Internationally, it receives support from FoEI. It also holds regular dialogues with the government, especially the Indonesian Ministry of Environment and Forestry and the Ministry of Agriculture (WALHI interview, 2023). Although WALHI has engaged in dialogues with the government since the 1980s (Nomura, 2007), its relationship with government authorities have often been strained due to strong criticisms and opposing views – for instance, regarding the recent expansion of oil palm plantations, priority measures, and several policy drafts that fail to democratically address the demands of CSOs. This lack of trust and confidence led WALHI and several CSOs to decline invitations to meetings with the President in 2020 – opportunities that could have significantly strengthened collaboration with the government. Opting to remain aligned with their non-governmental counterparts, who largely relied on outsider strategies, WALHI's Executive Director at that time, Nur Hidayati, stated that participating in the meetings could potentially “split and divide” the advocacy alliance (Kompas, 2020).

With the vision of creating a just and democratic order that guarantees rights to natural resources and a sustainable environment, WALHI has employed various strategies to achieve its goals. These strategies include policy advocacy and lobbying with like-minded groups; monitoring and reporting; litigation; discursive framing; capacity-building and training for community empowerment; research, fundraising, and resource mobilisation; collaboration and partnership; and the proposal and initiation of alternative solutions. In addressing land and forest fires and haze governance, WALHI has focused on issues related to land use, forest conservation, and palm oil plantations. Since 2000, it has advocated for various national policy measures, including several moratoriums on the issuance or renewal of licences for logging and forest conversion activities (such as oil palm and wood fibre plantations) that deprive local communities of their rights and access to forests and contribute to land and forest fires (WALHI, 2003). WALHI's approach exemplifies a polycentric governance model, as it fosters collaboration among diverse stakeholders, including local communities, NGOs, and governmental bodies, to address complex environmental challenges effectively.

In collaboration with the Indigenous Peoples Alliance of the Archipelago (Aliansi Masyarakat Adat Nusantara) and the Consortium for Agrarian Reform (Konsorsium Pembaruan Agraria), WALHI helped establish the Nusantara Fund (Dana Nusantara), which has received contributions from both the government and philanthropic organisations, including the Ford Foundation. This fund provides direct financial assistance to indigenous and local communities to protect their lands and territories, many of which are highly susceptible to fire, thereby mitigating emissions from deforestation and forest degradation (WALHI, 2023). The initiative aligns with WALHI's longstanding advocacy for social forestry and community-based area management (Wilayah Kelola Rakyat). Unlike government officials and mainstream media, who frequently attribute forest fires in Indonesia to slash-and-burn practices, WALHI defends swidden agriculture, which has been practiced sustainably for generations by indigenous communities (WALHI, 2022a). Its WKR model is currently gaining recognition as a “blueprint for action” to strengthen local community participation in resource management and governance in neighbouring countries such as Thailand (The Nation, 2024). By supporting traditional practices, WALHI directly challenges the prevailing narrative of resource nationalism – a doctrine of state sovereignty strongly upheld by the Indonesian government (Kadir and Murray, 2019).

Notwithstanding the lack of authoritative power, WALHI (like NGOs such as Pantau Gambut and Greenpeace) has leveraged its extensive network and close ties with local communities, both of which have been instrumental to its campaigning and monitoring strategies. With access to the National Aeronautics and Space Administration's Fire Information for Resource Management System, WALHI has been able to report fire hotspots in plantation concessions and contribute to checks and balances, as well as law enforcement – arguably one of the weakest links in Indonesia's forest governance (Purnomo et al., 2019). In 2015, it co-founded Eyes on the Forest (EoF, 2016) with the Forest Rescue Network Riau (Jaringan Kerja Penyelamat Hutan Riau – Jikalahari) and WWF to monitor fires in concession areas on Sumatra Island. Despite WALHI's strong alliances and success in exposing corporate wrongdoers through publications and press releases, the impact of its lobbying for transparency and more stringent measures against lawbreakers remains limited. For instance, administrative sanctions against plantation companies responsible for land licences and forest fires often involve only fines, rarely leading to the evaluation or revocation of licenses.

WALHI's strategic litigation is among its most notable initiatives, which began in the late 1980s. This strategy represents an exercise of pragmatic power with a profound impact. As Winarni (2013) notes, the litigation established a legal precedent, empowering environmental organisations to file lawsuits for “the sake of sustainable functions of the environment” under Article 92 of Law No. 32 of 2009 on the Protection and Management of the Environment. Following democratic reforms in the post-Suharto era, Indonesia's legal frameworks redefined the distribution of power in environmental governance. Consequently, environmental organisations have become increasingly empowered, assuming the role of “guardians” of the environment, with the legal standing to initiate lawsuits (Bachtiar and Safira, 2022). Following the 2015 fire and haze disasters, WALHI actively employed this strategy, collaborating with local communities to bring legal action against government officials, including the Indonesian president, the Minister of Environment and Forestry, the Minister of Health, and several governors for their failures in preventing and mitigating land and forest fires, as well as addressing the haze disaster in fire-stricken provinces such as Jambi, Riau, and Central Kalimantan.

By 2019, the Indonesian government, despite having the power by design, had lost a lawsuit before Indonesia's Supreme Court, which ruled that the government was responsible for disaster mitigation (Kahfi, 2019). That same year, WALHI, alongside Greenpeace and Legal Aid Institute Jakarta, formed a coalition, filing another lawsuit against the Indonesian president and six other officials. The central Jakarta District Court ruled that the officials “have been negligent in fulfilling the rights of citizens to a good and healthy environment” (Karmini, 2021). WALHI described the successful legal battles that held the government accountable as “historic.” These cases not only set legal precedents but also demonstrated civil society's growing ability to exert power and pressure the state to uphold its responsibilities. According to WALHI's Head of Campaign and Network development, they “build momentum for the government to protect human rights, especially of vulnerable groups such as children, whose health is threatened by haze pollution from forest fires” (WALHI, 2017).

Although WALHI's coordination with the Indonesian government has been limited, the organisation has managed to leverage its network, especially through Sahabat Alam Malaysia (SAM or Friends of the Earth Malaysia), to foster cross-border dialogue and coordination on fire and haze governance. Meetings with SAM, the Chairperson of the ASEAN Parliamentarians for Human Rights (APHR), and other Malaysian and Indonesian CSOs in 2019 resulted in agreements to strengthen partnerships among ASEAN, CSOs, and parliamentarians (FoEAP, 2019). Strategic actions, including mapping the activities and interests of participating organisations, were undertaken to enhance mutual adjustment and coordination (FoEAP, 2019). To date, although the partnership between ASEAN and CSOs, including WALHI, remains highly limited, APHR has collaborated with these organisations in urging ASEAN governments to uphold their citizens’ right to clean air through the enactment of the THPA in their respective countries (Greenpeace, 2023).

CMBC – Local Multi-Stakeholder Venture

Transboundary haze pollution became a serious environmental concern in the Mekong Sub-Region during the 2010s. It primarily arises from forest fires and biomass burning activities linked to the rapid expansion of large-scale maize and sugarcane cultivation. In 2019, the CMBC was established as a social movement network and a self-organised platform that facilitates consultation, collaboration, and coordination between public and private actors, including academic institutions, businesses, CSOs, local governmental officials, and individuals in the province and beyond. The multi-stakeholder partnership has placed the movement in quite a unique position to employ both insider and outsider strategies. For instance, CSOs and academic institutions within the CMBC, in collaboration with local government, have exercised pragmatic and framing power in pioneering new ideas and activities related to various aspects of sustainable agriculture, forest management, and mobilisation (MGR Online, 2022).

Beginning with an awareness campaign strategy, the CMBC advocated for a more stringent air pollution standard, as well as the public disclosure of the air quality index based on particulate matter (especially PM 2.5), which was declared a national agenda in 2019. The haze, known in Thai as “หมอกควัน” (or “smoke-haze”), was reframed as measurable “dust-smoke” (‘ฝุ่นควัน’ in Thai) (BangkokBizNews, 2020). By 2021, this term quickly gained mainstream traction, appearing in reports by local media and government agencies, including the Provincial Office of Natural Resources and Environment in Chiang Mai.

Another key strategy was to introduce flexibility into the rigid regulations and existing governance structures led by the central government. This involved empowering local administrations, which should act as key decision-making centres with clear authority and designated budgets for self-governance (Lanner, 2024). This approach reflects principles of polycentric governance, where multiple governing bodies at different scales work collaboratively to address complex issues. Furthermore, CMBC advocates for forest stewardship to reduce conflict and enhance cooperation between the state and forest communities. This is implemented alongside other strategies, including promoting zero-burning agriculture and best practices, raising public awareness to sustain anti-haze momentum through both short-term and long-term campaigns, fostering mutual understanding between urban dwellers and forest communities, mobilising financial support for the construction of firebreaks, and seeking alternative agricultural waste management projects.

The multitude of individuals, projects, and working groups involved, however, posed a significant coordination challenge in the first year after CMBC's inception. As a CMBC member admitted, “we were all working in different directions and at different paces and were not as effective as we could have been” (quoted in Kemasingki, 2021). This resulted in an effort to create a mechanism that facilitates coordination and mutual adjustment, including a multi-stakeholder committee and regular meetings (Lanner, 2024). A more inclusive deliberation and learning process occurs annually at the After-Action Review, where a diverse range of individuals and decision-making centres gather to share their experiences, exchange information, and potentially frame policies and strategies for the next dry season. At the national level, CMBC, alongside Chiang Mai University, the Thai Health Promotion Foundation, Thailand Science Research and Innovation, and the Academic Center to Drive Prevention and Solve Air Pollution Problems, organised the Thailand National PM2.5 Forum in December 2023. This event was the country's largest public deliberation, attended by more than a thousand individuals and organisations nationwide.

Increasing dialogue and cooperation among various stakeholders has led to a significant change in how land and forest fires, as well as haze, are addressed in the province. Through collaboration and partnership, the Chiang Mai Model action plan was launched in 2021 as a policy experiment. According to the then-governor of Chiang Mai, Charoenrit Sanguansat, the largely reactive and heavily top-down Single Command system that the Thai military government had relied on was increasingly decentralised, with local administrative organisations acting as key coordinators, supported by the provincial administration and CSOs. Their new role entailed facilitating consultations and creating comprehensive plans for fuel management, controlled burning, fire prevention, and fire suppression at the sub-district and village levels (The North, 2021). Local communities also assumed a central role in fire and haze prevention and management (Sriwattana, 2021). This effort was complemented by a series of experimental projects initiated by NGOs and academic institutions. These initiatives include zero-burning mushroom farming, locally made firefighter drones, the Fire-D (which literally means “good fire” in Thai) and Burn Check applications, which facilitate the registration and management of necessary open burning, as well as the conversion of fuels such as dry leaves and agricultural waste into marketable products (e.g. fertilisers, degradable utensils, charcoal, detergents, soap, and bags).

In 2023, the Department of National Parks (DNP, 2023) reported that the burned forest area in Chiang Mai declined from 8595.28 hectares in 2020 to 5339.152 hectares in 2021 and 1798.58 hectares in 2022. Despite the spread of uncontrollable fires in many areas that year (MGR Online, 2023), CMBC has played a critical role in the creation and adoption of the more bottom-up Chiang Mai Model, which has had a positive impact and is now being replicated in neighbouring provinces, where new Breathe Councils have emerged. In September 2022, the Breathe Councils from nine northern provinces collectively submitted a blueprint to address the issues of fires and haze. Among other things, they asserted that “access to clean air is a fundamental right the state must protect” (Prachachart, 2022). This reinforces the call for the implementation of the Clean Air Act, which the CMBC and its allies have advocated for in response to particulate matter pollution.

While collaboration with local administrations has steadily increased over the years, engagement with the national government remains comparatively limited. Moreover, there is a broad consensus among the CMBC, local authorities, and academics that significant structural challenges persist, including restrictive financial regulations that hinder the transfer of budgetary resources from the central administration to the provinces (Poapongsakorn et al., 2023). To increase pressure on the national government, the CMBC has transcended its traditional watchdog role and evolved into a litigant, similar to WALHI. This institutional shift was facilitated by the 2017 Thai Constitution enacted during the military rule under the National Council for Peace and Order. Article 51 of the Constitution grants individuals and communities the right to initiate legal proceedings against relevant state agencies to ensure actions are taken in the public interest. In collaboration with the Environmental Law Foundation, Greenpeace Thailand, and other organisations, the CMBC filed a lawsuit against the National Environmental Board, the Ministry of Natural Resources and Environment, and the Ministry of Industry in March 2022, accusing them of failing to fulfil their statutory obligations in addressing air pollution caused by PM2.5 dust, and of neglecting their duty to safeguard the public's right to live in a safe environment (Isranews, 2023).

In April 2023, it led another high-profile legal action against the Prime Minister Prayut Chan-o-Cha, accusing him of failing to fulfil his mandate to compel individual government and state-owned agencies to address the haze under the 1992 Enhancement and Conservation of National Environmental Quality Act and 2007 Disaster Prevention and Mitigation Act. This legal action, which occurred approximately a month before the general election in May 2023, was also strategically intended to urge Thai political parties to prioritise the issue and develop concrete policies (Matichon, 2023). By January 2024, seven legislative drafts had been proposed by activists and major political parties. The CMBC maintains that any new law must include transboundary aspects as well as economic measures, citing Singapore's enactment of the THPA in 2014 (The Active, 2024).

The creation of the Clean Air Act as a proactive law to regulate air quality has been a cornerstone of long-term strategy for the CMBC and other stakeholders. According to the CMBC's president, this new legislation would help address the limitations of the reactive Disaster Prevention and Mitigation Act, which has underpinned Thailand's haze governance for decades (MGR Online, 2022). Advocates further argue that implementing the Clean Air Act would allow Thailand to ban agricultural products whose production contributes to domestic air pollution without violating trade agreements signed previously under the World Trade Organization (Bangkok Post, 2024). Recognising the importance of partnerships and cooperation with the private sector, civil society and neighbouring countries, the Thai government initiated the “CLEAR Sky Strategy” in 2024. This strategic action plan is meant to strengthen inclusive cross-border collaboration to combat regional haze (Green Network, 2024). As part of these efforts, Thailand's northern Breathe Councils, along with local governments such as those in Chiang Rai province, have begun discussing joint initiatives to tackle haze pollution along the Thai-Laos border (Radio Chiang Rai, 2024). However, progress remains uneven. While dialogue with regional bodies such as ASEAN remains underdeveloped, collaboration with Myanmar has been particularly challenging due to ongoing conflicts in the country.

PM Haze – Collaboration and Division of Labour

Several prominent civil society groups in Singapore address haze issues, including the Singapore Institute of International Affairs (SIIA), the Singapore Environment Council, and the Haze Elimination Action Team (Varkkey, 2022b). Among them, PM Haze, a non-profit organisation with charitable status, founded in 2014, plays a particularly significant role in the haze governance network. Recognising that the widespread deforestation and peatland clearing for palm oil and paper plantations are “fueled by money from consumers and investors, including people in Singapore,” the organisation's founders sought to redirect financial support towards haze-free initiatives, such as promoting sustainable palm oil and paper production (PM Haze, n.d.a). In collaboration with SIIA, an independent think tank, PM Haze organised Singapore's first public exhibition on haze in November 2014. This effort laid the groundwork for subsequent campaigns such as “We Breathe What We Buy: XtheHaze,” launched in partnership with WWF in 2015 and the ‘#gohazefree’ campaign in 2017.

The campaigns created a new discursive framework, reshaping perceptions of responsibility in addressing regional haze. Rather than following the dominant narratives, which typically attribute profit-driven palm oil and pulp companies with causing fires and haze, or the Indonesian government and ASEAN for failing to prevent these environmental disasters, the campaigns reframed Singaporeans not as passive victims, but as conscious consumers capable of making informed choices and taking responsibility. Through activities, such as research, public education, awareness-building roadshows, workshops, and public talks, these initiatives empowered Singaporean consumers with the knowledge and tools to make “haze-free” choices. This approach encouraged active participation in the growing “haze-free” movement. In parallel, PM Haze extended its outreach to local eateries, a crucial part of the food supply chain. By the end of 2017, the organisation had conducted more than 2000 outreach activities, which contributed to a rising domestic demand for sustainable palm oil and an increasing number of “haze-free” partners (PM Haze, n.d.b). Consequently, the number of food and beverage outlets in Singapore using haze-free palm oil grew from just two in 2015 to over 200 by 2017 (PM Haze, 2019).

PM Haze further advanced the “haze free” movement by encouraging local businesses to switch to sustainably sourced palm oil certified by RSPO, which it joined as a member in 2019. This initiative was implemented through the “Haze-Free Foodstand” campaign, launched in 2020. By offering complementary marketing support to businesses that joined the campaign, PM Haze established “haze-free” as a brand synonymous with sustainable palm oil. This branding not only promoted environmental responsibility but also enhanced the sustainable image and commercial appeal of participating local eateries (PM Haze, n.d.c). The campaign was complemented by a “naming” (not shaming) strategy, which included creating a Supermarket Guide to identify cooking oils and food products carrying the RSPO label. Without strong consumer awareness about palm oil certification and greater eco-labelling by companies, consumers are unlikely to recognise and purchase certified sustainable palm oil (WWF-Singapore and SASPO, 2021).

Additionally, PM Haze engaged with multi-stakeholder platforms such as the Southeast Asia Alliance for Sustainable Palm Oil and the Fire Free Alliance, which bring together leading palm oil companies including Asian Agri and Wilmar International alongside local communities to collaborate on sustainable practices. Recognising the importance of youth in driving effective grassroots movements, PM Haze co-organised the inaugural Asian Youths for Sustainable Palm Oil Summit in Bangkok in 2019. Partnering with RSPO and the German International Cooperation Society (Deutsche Gesellschaft für Internationale Zusammenarbeit) Thailand (PM Haze, 2020), the summit brought together youth delegates from China, India, Indonesia, Malaysia, Singapore and Thailand to urge palm oil businesses to commit to sustainability (RSPO, 2019).

PM haze has also established collaborative networks with CSOs to identify sites for public engagement and develop community-focused protocols aimed at empowering communities to restore peatland areas in Indonesia and Malaysia. In 2016, PM Haze partnered with Sahabat Hutan Gambut Selangor Utara and the Global Environment Centre to construct a canal block in Malaysia's Raja Musa Forest Reserve (MalayMail, 2016). A similar project was undertaken in Sungai Tohor, Tebing Tinggi, Riau Province, Indonesia. For this initiative, PM Haze collaborated with WALHI Riau and Jikalahari Riau – provincial chapters of national environmental NGOs – and engaged extensively with the local community. Recognising that local communities faced resource constraints and lacked the necessary knowledge to maintain canal blocks for managing peat water levels, PM Haze partnered with the local NGO Ekonomi Kreatif Andalan, the Tebing Tinggi District Government, and the Sungai Tohor Village Government to repair and improve existing structures. Additionally, the organisation facilitated community capacity-building programmes to enhance peatland protection efforts. These collaborative initiatives laid the foundation for sustainable livelihood programmes in the village, focusing on green economic initiatives that support agricultural livelihoods while conserving peatlands (PM Haze, 2018a, 2019).

PM Haze's success in establishing a collaborative network that includes governmental agencies, businesses and peatland communities demonstrates the organisation's political sensitivity and pragmatic power. As Varkkey (2022b) observes, its non-confrontational and “not anti-palm oil” stance has enabled PM Haze to participate in emerging “transboundary publics” that address policy gaps without threatening existing institutions at both the national and regional levels. Furthermore, its buyer-focused and market-based strategies align with the “green” developmentalist worldview embraced by some ASEAN states, particularly Singapore. The Singaporean government has long recognised the city-state's vulnerability to environmental challenges and has encouraged the participation of “green volunteers” as part of its policy aimed at ensuring sustainable Singapore (MEWR and MND, 2014).

Given the specific context of Singapore – particularly the economy's heavy reliance on business enterprises, the limited scope of civil lawsuit against the government, and the courts’ tendency to adopt a facilitative and collaborative, rather than adversarial, stance towards other branches of government (Chng, 2021: 2) – PM Haze's strategies may have represented the most viable approach. Aligned with the government's position, PM Haze’s initiatives help stimulate demand for sustainable products, which can, in turn, reduce the frequency of fires and haze in Southeast Asia. Consequently, its efforts have been well received (NEA email communication, 2022). At the United Nations Environment Assembly in 2017, Singapore's then Minister for the Environment and Water Resources, Masagos Zulkifli spoke favourably about PM Haze and comparable civil society organisations. As he acknowledged, the government required “the support of citizens and businesses for sound environmental policies” (Today, 2017).

The coalition between PM Haze and the Singaporean government is particularly significant given the Singaporean state's limited “power by design” within the ASEAN institutional framework and organisational culture, as well as the reluctance of corporate actors in Singapore to exert pressure on their Indonesian partners responsible for the haze. In this context, PM Haze – while still largely operating as an outsider in the policy-making process – “can potentially play comparatively more powerful roles” in addressing transboundary haze (Varkkey, 2022a: 352). Despite the government's dominant authority, the alliance and division of labour between non-state actors such as PM Haze and the Singaporean government constitute one of the most notable features of the polycentric haze governance model currently emerging in the region.

Conclusion

Southeast Asia's haze governance involves a complex web of interconnected institutions, mechanisms and initiatives established by a diverse range of actors. While ASEAN has played a central role in the development of regional haze regime, non-state actors have become increasingly key players. Their initiatives now form a crucial part of the overall governance structure in the region. An examination of the roles and engagement of WALHI, CMBC, and PM Haze within the context of haze governance reveals that these three CSOs have, to varying degrees, successfully self-organised and operate as relatively autonomous decision-making entities in an increasingly polycentric governance system. Using various strategies, they have compensated for their lack of formal authority to create and enforce laws by exercising pragmatic and framing power. This is evident in the national and international networks and alliances they have formed, their success in establishing legal precedents, and their ability to shape normative discourses. These efforts have encouraged active citizen participation, transforming what was once state-led governance into a more inclusive and polycentric system.

Notably, CSOs such as CMBC and PM Haze, which emerged in response to the persistent haze problem in the 2010s, appear to have cultivated closer coordination with their respective governments compared to the more established WALHI, which remains highly concerned with maintaining alignment with like-minded advocacy partners within civil society. This is partly due to the two organisations’ less confrontational approach and their dedicated focus on haze-related issues and the underlying causes of land and forest fires. Their approach has helped minimised conflict and tension stemming from competing values – such as state sovereignty and resource nationalism, on the one hand, and Indigenous rights, on the other.

Furthermore, the adaptive capacity of the Singaporean and Thai governments to transcend ASEAN's traditional top-down governance is particularly noteworthy. This dynamic, combined with the strategic advocacy for environmental rights by WALHI's and CMBC, alongside their utilisation of litigation enabled by recent legal reforms, highlights a growing convergence between human rights and environmental norms. Additionally, the persistent haze problem, coupled with questions regarding the legitimacy of the new laws, has significantly constrained the Indonesian and Thai governments’ ability to mount substantial backlash. As part of a growing trend of environmental litigation in the region (Schulte, 2022), this development signals a significant shift towards the democratisation of environmental governance – one that contrasts with the ongoing pattern of democratic decline in Southeast Asia.

The recognition of the human right to a healthy environment holds the potential to further empower non-state actors, thereby fostering greater inclusivity and strengthening governmental accountability over time. What remains uncertain, however, is whether, and to what extent, future political developments will shape environmental governance, as well as whether polycentric haze governance will generate spill-over effects in related policy domains. These uncertainties present valuable opportunities for future research. Currently, the transboundary haze issue is particularly well-suited to a polycentric governance framework, as its enduring and complex nature underscores the necessity of engaging a wide range of actors beyond the state. This approach also aligns with global trends that emphasise sustainability, climate action, and cross-sector partnerships – principles that ASEAN states have, at least nominally, incorporated into their sustainable development agendas. Nonetheless, significant challenges persist. The absence of an effective regional body and institutionalised coordination mechanisms has resulted in collaboration among CSOs, and between CSOs and other stakeholders, being heavily dependent on the political will and institutional capacity of ASEAN governments to support inclusive governance processes.

Footnotes

Declaration of Conflicting Interests

The authors declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.

Funding

The author(s) disclosed receipt of the following financial support for the research, authorship, and/ or publication of this article: This work was supported by Faculty of Political Science and Public Administration, Chiang Mai University (Grant No. 7/2565).

ORCID iD

Paruedee Nguitragool

Helena Varkkey

Author Biographies

Paruedee Nguitragool is an associate professor at the School of International Affairs, Faculty of Political Science and Public Administration, Chiang Mai University, Thailand. Educated at Chulalongkorn University, University of KwaZulu-Natal, Jawaharlal Nehru University and University of Freiburg, she was a research associate at the Department of Political Science, University of Freiburg, Germany between 2008 and 2013. Over the past years, she has explored the feasibility to synergise cooperation frameworks in the Mekong sub-region. Her main research interests include ASEAN, environmental politics and international relations in Southeast Asia.

Helena Varkkey is an associate professor of environmental politics at the Department of International and Strategic Studies, Universiti Malaya. Her areas of expertise include transboundary haze governance in Southeast Asia and global palm oil politics. Her monograph on “The Haze Problem in Southeast Asia: Palm Oil and Politics” was published by Routledge in 2016. Dr. Varkkey has almost two decades of experience in qualitative research, and has built up extensive research networks in countries across ASEAN. She has edited and produced reports for the Academy of Sciences Malaysia, UNICEF, and the ASEAN Secretariat.

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CSOs and Polycentric Haze Governance in Southeast Asia

Abstract

Keywords

Introduction

Polycentric Governance and Environmental Management in the ASEAN Region

The Concept of Polycentric Governance

The ASEAN Context and Power Typology

A Brief Overview of Haze Governance in Southeast Asia

The CSOs in Southeast Asian Haze Governance

WALHI – Supporting Law Enforcement and Promoting Accountability

CMBC – Local Multi-Stakeholder Venture

PM Haze – Collaboration and Division of Labour

Conclusion

Footnotes

Declaration of Conflicting Interests

Funding

ORCID iD

Author Biographies

References