Kabeer's social relations approach examines gender dynamics through scrutinizing de facto rules and practices of social and formal institutions based on actors' core values and assumptions. It recognizes there are structural causes that reproduce social inequalities; that institutions are not independent from one another; where changes in policy or practice from one level can cause changes in the rules and norms of another level; and that institutions evolve (Kabeer, 1994). Beyond focusing on the separate roles and capabilities of different genders, the social relations approach underscores development as increased human well-being. Access theory complements the social relations approach when examining local institutions and gendered access to land resources. Some gender studies have conceptualized access as "the opportunity to make use of a resource", whereas control depicts "the power to decide how a resource is used, and who has access to it" (March et al., 1999, p. 19). Ribot and Peluso (2003) broaden the definition of access from the usufructary right to benefit from resources to "the ability to benefit" from resources (p. 153). Recognizing the majority of semi-subsistence women do not have formal ownership of land in Kenya (Nyamu-Musembi, 2008), we use access theory to examine the alternative strategies that Kamba women use. Ribot and Peluso theorize that "access is about all possible means" (p. 157) to benefit from resources. Besides women's right-based mechanisms, access theory considers strategies that occur among "a larger array of institutions, social and political-economic relations, and discursive strategies that shape benefit flows" (Ribot and Peluso, 2003, p. 157).