UN Peacekeeping doctrine in a new era

 © 2017 – Routledge (http://bit.ly/2peaceopsdoctrine) Amazon (http://amzn.to/2kYXzAL)

CIC interview on this book: http://peaceoperationsreview.org/interviews/cedric-de-coning-adapting-the-un-peacekeeping-doctrine-to-stabilization-missions-protection-of-civilians-mandates-and-new-threats/

Video and report from book launch seminar at IPI on 23 March: https://www.ipinst.org/2017/03/towards-un-stabilization-doctrine#4


Recent UN peacekeeping experiences have challenged the traditional peacekeeping principles of consent, impartiality and the minimum use of force. The pace and scope of these changes have now reached a tipping point, as several new mandates are fundamentally challenging the continued validity of the UN peacekeeping’s core principles and identity.

This book analyses the growing gap between these actual practices and existing UN peacekeeping doctrine. It considers how the distance between the two undermines the effectiveness of UN operations, and endangers lives. The book argues that a common doctrine is a critical starting point for effective multi-national operations. In order to determine the degree to which this general principle applies to the current state of UN peacekeeping, this book:

  • Provides a review of conceptual and doctrinal developments in UN peacekeeping operations through a historical perspective;
  • Examines the debate related to peace operations doctrine and concepts among the P5 members of the Security Council and the top Troop Contributing Countries;
  • Focuses on the actual practice of peacekeeping by conducting case studies of several recent UN peacekeeping missions in order to identify gaps between practice and doctrine, including;
  • Critically analyses gaps between emerging peacekeeping practice and existing doctrine; and
  • Recommends that the UN moves beyond the peacekeeping principles and doctrine of the past.

Table of Contents

Introduction: Addressing the Emerging Gap between Concepts, Doctrine and Practice in UN Peacekeeping Operations

[Chiyuki Aoi, Cedric de Coning and John Karlsrud]

Part I: Doctrinal Debates

    1. U.S. Doctrine and the Challenge of Peace Operations

[William Flavin & Chiyuki Aoi]

    1. The United Kingdom and UN Peacekeeping

[David Curran and Paul D. Williams]

    1. France and the Evolution of UN Peacekeeping Doctrine

[Alexandra Novosseloff and Thierry Tardy]

    1. China’s Evolving Doctrine on UN Peacekeeping

[He Yin] 

    1. The Russian Perspective on UN Peacekeeping: Today and Tomorrow

[Maxim Bratersky and Alexander Lukin]

    1. The Large Contributors and UN Peacekeeping Doctrine

[Seun Abiola, Cedric de Coning, Eduarda Hamann and Chander Prakash] 

Part II: UN Peacekeeping Practice

    1. Supporting the Formation of New States and Administrations: South Sudan, Kosovo and Timor Leste 

[Mateja Peter and Diana Felix da Costa]

    1. Protection of Civilians in Absence of Peace Agreements: Darfur, Chad/CAR, Haiti & Cote d’Ivoire

[John Karlsrud and Ingvild M. Gjelsvik]

    1. Protecting Governments from Insurgencies: The Democratic Republic of the Congo and Mali

[Stian Kjeksrud and Lotte Vermeij]

Part III: Emerging Issues

    1. Exploiting the Sea: Naval Involvement in UN Peacekeeping: Prospects and Difficulties

[Ian Bowers]

  1. New Technologies and UN Peacekeeping Operations

[John Karlsrud]

Conclusion: Towards a United Nations Stabilization Doctrine: Stabilization as an Emerging UN Practice

[Chiyuki Aoi & Cedric de Coning]

The co-editors:

Cedric de Coning is a Senior Research Fellow with the Peace and Conflict Research Group at the Norwegian Institute of International Affairs and is a Senior Advisor on Peacekeeping and Peacebuilding for ACCORD, South Africa.

Chiyuki Aoi is Professor of International Security and Strategic Studies, Graduate School of Public Policy (GraSPP), University of Tokyo, Japan.

John Karlsrud is Senior Research Fellow and Manager of the Training for Peace programme at the Norwegian Institute of International Affairs.


‘Peacekeeping is a creation of practice rather than law, and it has gone through many transformations since its creation. As conflicts go through a profound mutation, so should peacekeeping. This volume offers important recommendations that should help peacekeeping reinvent itself, going beyond principles that are no more adapted to the realities of contemporary conflict.’ – Jean-Marie Guehenno, the former UN Under Secretary-General for Peacekeeping and currently the President & CEO of the International Crisis Group (ICG)

‘Aoi, Karlsrud and De Coning have produced a timely and relevant study on the changing nature of UN Peacekeeping, focusing on the widening gap between principles and practice, and the need to upgrade doctrine to include key concepts such as stabilization. The authors not only focus on the current challenges posed by the latest generation of lethal non-state actors, but they also offer direction for how UN Peacekeeping doctrine and political realties can be reconciled.’ – Dr. Karin von Hippel, Director General, Royal United Service Institute

‘Realistic. Timely. objective. Extremely necessary. Touch the key point: principles, doctrine and practice; the most important question in UN peacekeeping. All the peacekeepers, from New York to the field should read this book, fundamental to protect civilians and UN itself.’ –Lt.Gen. Carlos Alberto Santos Cruz, former Force Commander of the UN mission in the Congo (MONUSCO)

‘At a time when peace operations are confronting increasingly complex and dangerous challenges, the United Nations’ High Level Panel could only begin a much-needed attempt to bring doctrine and practice closer together. This thoughtful volume significantly advances this essential task: both practitioners and analysts should read it and be provoked to engage in a debate which is vital for the UN and its partners.’ – Ian Martin, Executive Director, Security Council Report and member of the UN High Level Panel on Peace Operations

‘The security architecture of the 21st century places an increasing reliance on the use of force in peacekeeping. The Security Council has crafted mandates, which in some cases go beyond the existing norms of peacekeeping and this has resulted in situations where existing physical and doctrinal deficiencies leaves peacekeepers vulnerable and unsuitable for the task. This book works towards identifying the gaps between international ambitions, present doctrine, principles, operational procedures and actual practice, reappraises the doctrinal deficit and presents options for a UN doctrine for future missions. Undoubtedly a valuable literary addition to the UN Peacekeeping reform process that is presently underway.’ – Lt.Gen. Abhijit Guha, former Deputy Military Advisor to the UN and member of the UN High-level Independent Panel on Peace Operations

Chapter 12 Conclusion: Towards a United Nations stabilization doctrine—stabilization as an emerging UN practice (pre-proofs draft)

Chiyuki Aoi & Cedric de Coning

After the end of the Cold War, United Nations (UN) peace operations took on new tasks, mainly as a result of the new focus on resolving internal conflicts, and expanded to take on multidimensional mandates and tasks. During the first decade of this century, in response to the lessons learned from the failures in Somalia, Rwanda, and Bosnia-Herzegovina, the traditional principles of peacekeeping were re-visited and a more flexible interpretation emerged that allowed the use of force, not only in self-defense, but also in defense of the mandate. This new interpretation of the use of force principle, combined with an emerging practice of deploying peacekeeping missions with a Chapter VII (enforcement) mandate, was meant to enable peacekeeping operations to better protect civilians.

The 9/11 attacks and the ensuing “War on Terror” also brought significant pressure to bear on the good offices role of the UN—to impartially arbitrate between all parties in a conflict, even those “beyond the pale.” In the area of peace operations, this pressure has surfaced with the increased tendency of the UN Security Council to list terrorist groups and task UN peace operations with helping to protect a government and its people from these aggressors. The increasing trend of mandating missions to support the extension of state authority has also highlighted some of the inherent tensions that emerge when UN peacekeeping missions have to balance a protection of civilians mandate with a state-building mandate, especially when government security forces are implicated in acts of violence against the civilian population.

Furthermore, the Security Council is increasingly mandating bridging operations. The British intervention in Sierra Leone in 2000 showed that the combination of an external force mandated by the Security Council and a UN presence could stabilize a situation in the longer term. In recent years we have seen bridging operations being staged in the Central African Republic (CAR), the Democratic Republic of the Congo (DRC) and Mali, where European Union (EU), French, and African Union (AU) troops were able to stabilize the situation, with a subsequent transfer of authority to a UN operation. Often, the transfer of authority has preceded any peace agreement between the parties on the ground, but has mandated the UN to support the state in extending state authority, in practice making the UN a party to the conflicts that linger on.

UN peace operations are thus again in a period of flux that is testing its doctrinal limits. The Security Council is not directed by the UN Secretariat’s peacekeeping doctrine. In reality, the peacekeeping mandates issued by the Security Council precede and inform new doctrinal developments. The mandates given for the peacekeeping missions in the CAR, DRC, and Mali may, for instance, require a doctrinal change that clarifies where stabilization fits into UN peacekeeping doctrine. As a result of these developments and pressures on the existing UN peacekeeping doctrine, the UN secretary-general in October 2014 nominated a high-level independent panel to review UN peace operations. The panel, led by the former president of Timor-Leste (East Timor), José Ramos-Horta, submitted its report to the secretary-general in June 2015.[1] The secretary-general subsequently provided his own implementation report to the 2015 session of the General Assembly and Security Council.

The Ramos-Horta panel notes that UN peace operations have been increasingly called upon to deploy “in the midst of conflict as a crisis response tool to deter escalation, to contain conflict while protecting civilians and, at the same time, to attempt to restart or revive peace processes.”[2] The panel characterizes these as “conflict management” missions, and differentiates them from ceasefire monitoring missions and peace implementation missions. The panel recognizes, however, that the Security Council and Secretariat have used the term stabilization for a number of missions, and it “believes the usage of this term by the United Nations requires clarification.”[3]

As the panel observers, the UN has not yet formally defined the notion of “stabilization” in its official doctrine or terminology. However, there are now four UN missions that have the word in the name of the mission and that have such tasks in their mandate: those in the CAR, the DRC, Haiti, and Mali. Furthermore, the history of UN peacekeeping—from the Congo in the 1960s to the Balkans in the 1990s and contemporary operations—suggests that, in hindsight, there have indeed been other UN operations that we could now more properly re-interpret as stabilization rather than peacekeeping operations.

The analyses of contemporary cases in this book indicate that some of them may also be considered UN stabilization missions. However, we would warn against a conflation between the concepts of peacekeeping, stabilization, and counterinsurgency, and we will give a more detailed view of our understanding of the stabilization concept in a UN context later in this chapter. The purpose of this chapter is hence to consider how recent developments in stabilization concepts and practices may relate to current UN peace operations, and how they inform the discussion to develop better doctrines and guidelines for UN action. The chapter first identifies key features of stabilization, based upon a qualitative review of already-developed concepts and doctrine of stabilization, building upon key representative historical cases. It then reviews those UN peace operations that currently have stabilization in their names and mandates to identify to what extent these could indeed be considered stabilization in contemporary doctrinal terms. Finally, the chapter considers how UN peace operations concepts and practice might merit from a conceptualization and definition of stabilization and a clearer demarcation between peacekeeping, stabilization, and counterinsurgency operations, and concludes with a recommendation that the UN should not just include stabilization into existing peacekeeping doctrine, but rather add a new standalone UN stabilization doctrine that provides for the possibility of offensive mandates, where deemed necessary.

Stabilization as a concept: Key features

Stabilization is a main task for many international missions today, including those conducted by the North Atlantic Treaty Organization (NATO) and its member governments, the EU, the AU, and as this chapter argues, by the UN.[4] Indeed, the practice of stabilization is burgeoning but to date there has been no common definition of either stability tasks or stabilization. As indicated in the review of national approaches to emergent peace operations issues in Part I of this volume, there is no common definition of stabilization shared among the permanent members of the Security Council or large troop-contributing countries (TCCs). As discussed in Chapters 1 and 2, the United States and the United Kingdom lead in the doctrinal debates in the area of stabilization, but these two countries define and approach stabilization quite differently. Most other nations, notably the large UN TCCs, have not invested similar efforts in conceptualizing stabilization. Furthermore, none of the international or regional organizations mentioned above possess a formal doctrine on stabilization at the time of writing, although NATO is apparently in the process of developing one.[5] Nor have these organizations defined specific stabilization-related tasks and mandates.[6]

Given the fact that there is no universally accepted definition of stabilization, this chapter starts with examining some of the most-influential national doctrines that have had impact internationally in NATO, the AU, the EU, the UN and other international and regional organizations, by virtue of their member governments sending troops or influencing their decision-making (for example, at the Security Council).[7] While it is possible and often helpful to perceive stabilization as a set of capabilities requiring resources, rosters, and integrated approaches,[8] for the purpose of this book, it is more useful to try to identify key qualitative features that characterize and at times distinguish stabilization from other forms of contemporary operations, including UN peacekeeping operations and peace support operations with its full spectrum.[9]

Key feature 1: Stabilization is essentially political (the primacy of a political purpose)

First of all, it should be noted that stabilization is essentially a political endeavor, where the end-state of stabilization assistance is the creation of a stable and legitimate state that institutionalizes paths towards political settlement of conflict.[10] As such, it is a form of state-building, without the pre-existing condition of a stable political settlement. It hence involves by necessity a mix of civil-military and diplomatic actors, where the integration of these different actors, processes, and projects is essential. In order to ensure coherence among these different actors and processes, it is increasingly recognized that, as a key lesson learned from the past decade of engaging in various stabilization missions, assistance and projects must drive towards the achievement of the common goal—that is, to assist emerging or fragile states to achieve stability and legitimacy, with the ability to resolve disputes without resorting to violence, and the acceptance and buy-in of formal structures by local populations through building human and national security; fostering host government capacity and legitimacy; and stimulating economic and infrastructure development.[11] From this perspective, the liberal template of state-building assistance where a large number of projects across humanitarian, social, economic, and political sectors are accorded simultaneous focus is rather problematic; rather, prioritization of assistance needs to be made on the basis of the end-state, i.e., the creation of the stable and legitimate political order, which makes the state-building process essentially a political one.

It is often recognized, however, that the “end-state” or stable political order is something that is indefinable a priori; rather, the aim is to create a space or condition for a locally-determined political arrangement to emerge and sustain itself. Hence stabilization differs from cases of peacebuilding assistance, where an agreed political process is in place; or peacekeeping, where a ceasefire or peace agreement is in place and where the parties to the agreement consent to the role of the peacekeeping mission (see below for further discussion).

Key feature 2: The lack of, or divided and fluid nature of consent by strategic actors 

One of the key characteristics that distinguishes stabilization from peacekeeping is the lack of, or divided and changeable nature of consent from the local parties at the strategic level. Moreover, in stabilization, consent must be negotiated constantly in order to acquire or maintain it as the basis of the operation. It is often the case also that in stabilization, local parties—the population, societal actors, and the elites often linked with armed groups—are fragmented and are likely to be multifaceted in terms of allegiances to, and relations with, the state and governing authorities of concern. The complex nature of relations between the local population and elites to the state hence make the issue of consent for stabilization force even more complex.

As confirmed in both the reports of the Brahimi and Ramos-Horta panels on peace operations and defined in the 2008 Capstone Doctrine, the UN has an institutional preference for peacekeeping operations where consent at the strategic level is clearly given by all parties to the conflict. Indeed, the UN considers operations without such consent as “peace enforcement,” and whilst the UN Security Council may authorize enforcement operations, the UN peacekeeping doctrine and both the Brahimi and Ramos-Horta panels reaffirm that such enforcement operations reside outside the purview of its peacekeeping functions and should ideally be undertaken by regional organizations like the African Union or coalitions of the willing that form ad-hoc multinational forces for this purpose, such as the Australian-led International Force for East Timor (INTERFET), which began operating in 1999. The Ramos-Horta panel goes further to recommend that “extreme caution must guide any call for a UN peacekeeping operation to undertake enforcement tasks and that any such mandate task should be a time-limited, exceptional measure.”[12] The Ramos-Horta panel is also at pains to specify that UN peacekeeping operations are not suited to engage in military counter-terrorism operations.[13]

The UN considers consent a pre-condition for effective peacekeeping operations, while acknowledging its fluctuating nature, and the 2008 Capstone Doctrine hence declares that the UN is not in the business of “creating” consent.[14] The tactical-level use of force, to protect civilians or to defend the mandate, however, is sanctioned, as long as such use of force is linked to an existing framework of political settlements and peace agreements.

This formulation is linear as peacekeeping is essentially linked to extant peace agreements. The Brahimi reform was very much about how to bring peacekeeping back from murky, grey-zone operations between war and peace to operations with a firm basis in existing peace agreements. The Ramos-Horta panel also re-affirms the crucial link between peacekeeping operations and peace agreements, but at the same time it recognizes that the UN will continue to find itself in conflict management situations. The panel notes that the “concepts, tools, mission structures and doctrine originally developed for peace implementation tasks may not be well suited for these settings.”[15] UN peacekeeping doctrine is thus deeply linked to the notion that a pre-agreed ceasefire or peace agreement needs to be in place. The role of the mission is to help the parties to the conflict, that has now come together in a peace process, to “keep” the peace by facilitating the implementation of the agreement and acting as an impartial observer and guarantor of the process. The symbolism of UN peacekeeping—blue helmets and white vehicles—further reinforce the image of a non-fighting, transparent, and impartial force that is not a party to the conflict.

Stabilization, by contrast, operates in a context where a political settlement is lacking, hence neither peace agreements nor consent from the parties to the conflict can be assumed as a pre-existing condition for operations. However, in most stabilization contexts the host government agrees to, if not welcomes, the stabilization mission and there is thus some form of consent from one party to the conflict, albeit often extremely fragile.

Stabilization usually entails close cooperation with government forces, for example, when training and supporting local security forces. Consent, however, is never a clear-cut issue in stabilization; rather, in stabilization, consent is negotiated, and given by local parties who see merit in involving the international community in their attempts to consolidate or expand their power base. At times, the possibility cannot be denied that consent is acquired or maintained through a combination of diplomacy and coercion, if necessary. In addition, stabilization forces necessarily have to renegotiate and adapt their position when the population and key elites renegotiate their own positions vis-à-vis the state, shifting the conditions for political arrangements which the stabilization force is expected to support. If stabilization forces support government security forces, the relationship between stabilization forces and local elites and the populace necessarily becomes more complicated as allegiances among local power holders shift.


Key feature 3: Approaches to campaign authority

As a result of a stabilization force’s complex relations with local consent, the campaign authority of stabilization missions differs from that in peacekeeping operations. In peacekeeping, consent is the legal foundation and backbone of the deployment of the operation, hence of its authority, and formal consent is complemented by other aspects of campaign authority such as the mandate, the way in which the mandate is implemented, and the way in which local expectations are met by peacekeepers.[16] In stabilization, campaign authority derived from the consent of the host government is not sufficient, as consent from the other parties to the conflict is likely to be lacking, divided, or fluid. Whilst all stabilization operations must necessarily have a clear basis in international law (in the form of Security Council authorization or by invitation from the host state), non-UN missions draw only the main parameters of their mandates from UN resolutions. The additional, often more important, direction is provided by those that undertake the operation. But a stabilization force’s authority may be compromised or enhanced by the way it implements its mandates and the way it deals with local expectations, even to a greater degree than in UN peacekeeping contexts, for the overall political arrangement is either still being negotiated or non-existent. Moreover, a stabilization force’s relations with the host state also influence the way campaign authority is exercised.

Stabilization missions’ campaign authority has implications most notably for the use of force. Just as the use of force in UN peace operations is dependent upon, and linked to, strategic level consent, the use of force in stabilization is also linked to the campaign authority and the overall political arrangement that drives the mission. In the UN context, one important consideration is whether a mission is authorized to use force for “offensive” or “defensive” operations.[17] In UN peacekeeping operations, the use of force is authorized for self-defense, and since the 2008 Capstone Doctrine also in defense of the mandate. In addition, the Security Council may authorize the use of force to, for instance, protect civilians. These are all examples of defensive or protection tasks. However, in the case of the Force Intervention Brigade (FIB) in the DRC, as discussed in Chapter 9, the Security Council authorized the offensive use of force to forcefully disarm and neutralize the M23 and other rebel groups. This has raised the question as to the outer limits of peacekeeping, i.e., how far down the spectrum of use of force can a UN peacekeeping mission go before it is no longer peacekeeping, before it has crossed the threshold into enforcement and offensive operations? As we argue below, one way in which to address this question is to place UN missions that are authorized to use offensive force in a new category of UN peace operations, namely “UN stabilization missions.”

In stabilization, the use of force is aimed at influencing the behavior of aggressors, so that they are deterred, contained, or even rendered unable to use violence, with the larger goal of encouraging them to pursue their grievances and interests as part of a peaceful negotiated political process. The use of offensive force in a stabilization context, however, still needs to be linked to the overall stabilization effort and the political end-state goal that entails. Very often this is expressed in the constraining principles of proportional or minimal necessary force, as excessive force is likely to have undesirable consequences on the perception by the parties to the conflict or the local population in general regarding the legitimacy of those who employ such force. Inability to project enough force, however, also lowers the credibility of the stabilization force, so there is an emphasis on projecting a credible capacity and will to use force, if stability should be challenged.

Key Feature 4: Stabilization is a process, not activities

There is a lack of clarity concerning whether stabilization refers to a “process”[18] towards a political goal, or a set of “activities” that are understood to be “non-traditional” by the military.[19] For example, in the US thinking, “stability tasks” are defined, and stability refers to, a building block of “full-spectrum operation.” Hence stability becomes part of counterinsurgency and other operational themes. By contrast, the UK thinking denotes stabilization as a context, or an approach in its own right. Although stabilization is often interpreted to provide for a familiar platform on which to understand the specific tasks the military performs in stabilization, this approach is inherently problematic unless these tasks are clearly linked to the political goal of the stabilization effort.

In our view, stabilization is essentially a strategy, where the theory of change is to contain aggressors and spoilers and enforce stability so as to create a political space that is more conducive to moderates on all sides finding a political path out of the conflict. Stabilization is thus a means towards a political end-goal, hence it needs to be managed flexibly, with the understanding also that the process actually could go backwards and is likely to be fraught with uncertainty and unintended consequences. The reliance on the idea that stabilization is part of a set of linear activities also tends to put operations into rigid conceptual “boxes,” thus reducing the room for adaptation and innovation.
Stabilization as a concept may share these common tenets, but the concept is essentially still ill-defined and fraught with disputes. Because it is simply unrealistic to expect that all differences in interpretations will be resolved, each agency or organization may have to continue to adopt its own concepts and methodologies for stabilization as needed. For instance, a UN stabilization concept will need to be contextualized and positioned with reference to existing UN concepts and doctrines on peacekeeping, peace enforcement, use of force, and so forth.

One serious issue when examining the stabilization terminology and concept is that there is a lack of clarity about the boundaries between counterinsurgency and stabilization, and stabilization and peacekeeping.[20] As regards the former, questions are asked whether or not stabilization presupposes the existence of insurgency, or merely a state of destabilization and insecurity that threatens the viability of the state. A related issue is determining, in cases where a counterinsurgency doctrine already exists, whether a standalone stabilization doctrine is needed as well, as a counterinsurgency doctrine, by nature, covers operational-level or operational-strategic level guidance for practitioners. Principles are also similar in existing stabilization and counterinsurgency doctrines.[21] The standard interpretation is that where the threat to stability is an insurgency and a decision is made to counter it, stabilization then becomes counterinsurgency: hence counterinsurgency is a subset of a broader stabilization concept. We contend that both stabilization and counterinsurgency, if implemented comprehensively, will necessarily address a larger set of issues and dimensions that determine the political viability of the state and the sustainability of a political settlement. Stabilization will, however, imply broader political contingencies and will not always involve attempts to defeat insurgencies by isolating and neutralizing them.

In a similar vein, when the threat to stability is terrorism, stabilization could include elements of counter-terrorism. However, stabilization is not the same as counter-terrorism—which the Ramos-Horta panel excludes from the UN’s tasks. Stabilization is rarely what counter-terrorism would imply, i.e., attempts to target terrorists.

Furthermore, there is confusion about the relationship or boundary between stabilization and peacekeeping. Although many governments formally take stabilization and peacekeeping as quite separate and distinct tasks, the issue arises because non-UN stabilization operations often overlap with peacekeeping operations in terms of tactical-level activities, phases, and at times narratives, despite differences in campaign authority. In the UN context, as discussed in more detail in the next session, the Security Council and Secretariat have started to use the stabilization concept and have introduced stabilization tasks in several UN peacekeeping missions, such as in the CAR, the DRC, and Mali. We are of the opinion, however, that to equate UN peacekeeping with stabilization where there is no political settlement, hence requiring different approach to force and campaign authority, appears especially misplaced.

To further complicate the confusion, some employ the term “stabilization” in the UN context as an overarching concept for “late peacekeeping” or “early peacebuilding,” which integrates peacekeeping, peacebuilding, state-building, and peace consolidation in a post-conflict setting.[22] This interpretation may offer a clearly divergent understanding from the above-discussed key features of stabilization, and differs from the interpretation that places stabilization as an overarching umbrella term that may include offensive tactics at the higher end of the force spectrum. For example, the Ramos-Horta panel situates what it terms conflict management missions at the opposite end of the spectrum, amidst ongoing conflicts, to help: “(i) deter escalation; (ii) contain conflict; (iii) protect civilians, and; (iv) attempt to start or revive a peace process.”[23]

Such disagreements in interpretation and understanding are significant because differing interpretations will result in different preferences for the timing of engagement and the actual content of operations, as well as the way in which they are carried out. These differing interpretations can be identified between the mandate given by the Security Council and how the mandate is operationalized into tasks by the mission on the ground. At the field level, differing interpretations can emerge between the civilian and military components or even between different TCCs.[24]

In our view, stabilization has a range, which could cover, at the higher end of the spectrum, proactive protection of civilians, and protecting governments and political processes from aggressors, including with the offensive use of force where necessary to proactively degrade the capacity of the aggressors to use violence. At the lower end of the spectrum, stabilization can include defensive actions to protect civilians, governments, and political processes, which could transition into peacekeeping when a peace settlement is in place and stability has been sufficiently restored.

UN stabilization missions

The UN Multidimensional Integrated Stabilization Mission in the Central African Republic (MINUSCA), the UN Stabilization Mission in the Democratic Republic of the Congo (MONUSCO), and the UN Multidimensional Integrated Stabilization Mission in Mali (MINUSMA) reflect a new trend in all having stabilization in their names and mandated tasks. Whilst each of these missions have their own unique features, taken together they represent a new category of UN operations, which has to do with protecting civilians and governments, or governance structures, against an aggressor(s) or general destabilization, amidst ongoing violence, while at the same time being part of a larger process that seeks a political settlement for the conflict. The UN Stabilization Mission in Haiti (MINUSTAH) similarly has stabilization in its name and tasks, but seems to reflect a broader use of the term that does not fit well with how the concept is used in the other three UN missions mentioned above.

If we analyze the CAR, DRC, and Mali missions we can identify that the characteristics they have in common—which in essence match the key features of stabilization analyzed earlier—are as follows:

  • that they operate in the midst of an on-going conflict, and without a political solution or settlement that is sufficiently comprehensive to bring the conflict to an end;
  • that the aspired end-state of the intervention is the emergence of a stable and secure political settlement;
  • that their core tasks are to contribute to restoring and maintaining stability and security by helping to protect a government and its people from identified aggressors;
  • that they work in support of and alongside the local authorities and security forces who have the primary responsibility for protecting the government and its people; and
  • that they are expected to use force, including offensively when mandated and where necessary, to contain and degrade the capacity of the aggressors to pose a threat to the people, government, and international actors.

On the basis of these characteristics we define UN stabilization missions as operations that aim to help states in crisis to restore order and stability in the absence of a peace settlement, by using force and other means to help national and local authorities to contain aggressors (as identified in relevant Security Council resolutions) and to protect civilians, in the context of a larger peace process that seeks a lasting political solution to the crisis.

The central tension between the established UN peacekeeping principles of consent, impartiality, and the limited use of force, and these UN stabilization missions is that the theory of change of the stabilization missions is to contribute to stability and security by containing identified aggressors and spoilers, while protecting the general population. In each of these missions the Security Council has identified specific aggressors that need to be contained—the M23 and others in the DRC, Al-Qaeda in the Islamic Maghreb (AQIM) and others in Mali, and Seleka and anti-Balaka in the CAR. Depending on the exact language of the mandate, containing these aggressors can include proactively degrading their capacity to use violence, and in the case of the mandate of the FIB in the DRC, the UN mission was authorized to neutralize the threat.

As analyzed in Chapter 9 by Kjeksrud and Vermeij, in the case of the FIB the mandate to undertake offensive operations goes beyond the established use of force principle, which has up to now always been framed in defensive terms. The UN Peacekeeping Capstone Doctrine of 2008 opened the door for the tactical use of force to contain spoilers and to defend the mandate. The use of force against pre-identified aggressors, and the use of offensive force, both mean that the Security Council has, in these stabilization missions, authorized the strategic use of force. Hence the authors of Chapter 9 argued that the mandate of the FIB crossed the boundary between peacekeeping and stabilization (or even “peace enforcement” in their parlance).

It should be noted also that these military operations went alongside assistance to promote political processes and governance structures that is aimed at preventing and managing further violent conflict, leading to peace consolidation. Whilst these stabilization missions are tasked with containing aggressors and creating a general climate of safety and stability, other initiatives are pursuing the political track, with what is regarded as the legitimate political actors. In most of these cases, the aggressors use long-standing tensions between those at the center of power and those on the periphery that feel marginalized and excluded, to mobilize opposition against the central government. There is thus a linkage with legitimate political debates, but the Security Council has singled out the identified aggressors because it sanctions the use of force to pursue political objectives. These stabilization missions are thus tasked to contain those aggressors that use violence to pursue their political objectives, whilst the UN more broadly, together with regional actors, supports and encourages the parties to the conflict to seek peaceful political solutions.

UN stabilization missions should thus not be misunderstood as seeking military or security solutions to these conflicts. They should rather be seen as part of a larger strategy to proactively shape the security environment, by containing the aggressors and improving the security situation for the civilian population, in order to create space for the political and peacebuilding actions that are aimed at seeking medium- to long-term political solutions. At the same time, increased security also enables humanitarian assistance to reach those in need and allows early recovery actions that can help to restore and improve the provision of basic services and civil administration.

Whilst the UN has developed comprehensive guidance on the issue of protection of civilians, it lacks any doctrinal thinking about stabilization, including guidance on how force can be proportionally applied to contain or degrade aggressors. Such a doctrine should cover the spectrum of operations, from defensive tactics to the use of proactive and offensive tactics (but that is usually carried out simultaneously). It should also consider what implications of stabilization operations, and especially the use of offensive tactics, may have for civilian and humanitarian counterparts, both in the UN mission and engaged elsewhere in the UN or broader international assistance community. Furthermore, there have not been attempts at sufficiently considering the doctrinal implications of incorporating various capabilities, such as naval assets, as considered in this volume in Chapter 10, or technologies that allow for enhanced surveillance, intelligence gathering, and information sharing, as addressed in Chapter 11.

As the Ramos-Horta panel also urged, the UN has to clarify and define what it means when using the term stabilization in a UN peace operation context. It is the contention of this book that stabilization is distinct from peacekeeping, and also at times from peace enforcement. The UN also needs to make it explicit that stabilization itself is a broad concept that goes beyond the employment of military force to contain aggressors, and that requires a comprehensive and integrated approach to achieving stability. On that basis, the UN can start defining its own approach and role in stabilization.

Given the risks and costs associated with stabilization, it is natural for some to question whether the UN should be doing this kind of mission at all. The doctrine has consistently been that when enforcement or stabilization is necessary the Security Council should authorize a coalition of the willing or a multinational force (MNF) to secure and stabilize the situation, and once a peace agreement is in place and the violence has stopped, the UN can replace the MNF with a UN peacekeeping mission. A gap has now emerged between this established doctrine and the recent precedents in the CAR, the DRC, and Mali where the UN has deployed “peacekeeping” missions amidst ongoing conflicts with a stabilization mandate.

The AU and French missions that were first deployed in Mali and the CAR followed the MNF model, but these forces needed to be relieved because they were not self-sustainable. The UN ended up—as a last resort—being deployed into these situations, even though they were not yet sufficiently stable to warrant a peacekeeping mandate. Deploying missions into Mali and CAR with a stabilization mandate was thus not the result of a strategic choice based on UN doctrinal assessment of the comparative advantage of deploying stabilization vs. peacekeeping forces. In reality, the Security Council had no other option but to deploy UN operations, because the countries that would otherwise have had to fund these missions, i.e., France and those that would have funded the AU missions, deemed the costs too high. As these countries are also members of the Security Council and major financial contributors to UN peacekeeping, they were able to convince the UN that it should take the responsibility for these missions, regardless of the doctrinal concerns that the Secretariat and major TCCs may have had. As the Ramos-Horta panel recognized, the Security Council has the prerogative to authorize UN operations to undertake offensive operations, as it did in Somalia in 1993 and in the DRC in 2013.[26]

We believe this trend is likely to continue because in Africa the AU and sub-regions do not currently have access to predictable funding, and there are few other regional organizations that have the legitimacy and credibility take on such a role, and in a changing and uncertain global order the UN is one of the few institutions that have the credibility and legitimacy to undertake such missions. Long-term conflict trends also suggest that there will continue to be a need for this kind of stability mission for the foreseeable future. It thus looks highly likely that the Security Council will find it necessary to mandate such missions again. If so, there is a glaring need to provide doctrinal guidance on how the UN should, and should not, act when given such mandates.

We thus agree with the Ramos-Horta panel that the UN is likely to continue to find itself facing these conflict management situations. In fact, we are of the view that these stabilization missions reflect a larger shift in the orientation of UN peacekeeping from conflict resolution to conflict management. In the early post-Cold War era UN peacekeeping was typically used to implement comprehensive peace agreements aimed at resolving civil wars. Over the last decade this has changed and UN peacekeeping has been increasingly used to manage conflicts, i.e., to contain aggressors and spoilers, and to protect civilians. Simultaneously, other UN tools and capacities, such as special envoys and Special Political Missions, or similar capacities of regional and sub-regional organizations, such as the African Union, the League of Arab States, the Economic Community of West African States (ECOWAS), or the Intergovernmental Authority on Development (IGAD), have been increasingly used to pursue the political track. In addition to the three UN stabilization missions discussed earlier, other UN peacekeeping missions, such as the AU/UN Hybrid Operation in Darfur (UNAMID) and, post-December 2013, the UN Mission in South Sudan (UNMISS), also reflect this broader trend where UN peacekeeping is limited to conflict management whilst others inside and outside the UN (IGAD in South Sudan, Algeria in Mali, etc.) are leading the effort to resolve the political conflict.

The Ramos-Horta panel has asked the UN to clarify its usage of the term stabilization, but it is our view that the UN needs to go further and doctrinally clarify the distinction between UN peacekeeping and UN stabilization missions. In the next section we argue that stabilization is not a form of peacekeeping, and thus cannot be accommodated within the UN peacekeeping doctrine. On this basis we argue that the UN should develop a UN stabilization doctrine that is distinct from and complimentary to the UN peacekeeping doctrine.

Demarcating and distinguishing peace operations and stabilization: Towards a new UN stabilization doctrine

If the UN is mandated to undertake stabilization operations, what are some of the key considerations that need to be taken into account? As the Ramos-Horta panel also noted, the typical UN peacekeeping mission, and the units, trained, prepared, and equipped to do consensual peacekeeping, are not suitable for the kind of conflict management tasks that stabilization missions require. When the UN is mandated to undertake stabilization missions, some of the following factors need to be taken into account:

  • Under the understanding that stabilization is a long-term and comprehensive endeavor, a UN stabilization mission needs to be given a clear mandate that distinguishes it from others inside and outside the UN that may have complimentary responsibilities. The stabilization mission’s tasks need to be linked to clear milestones and an overall comprehensive strategy. Such a focus generates the kind of political attention and strategic coherence that stabilization missions require to succeed. The Ramos-Horta panel notes that in situations where a UN operation is deployed “in parallel with a non-UN force … a clear division of labour and distinction of roles must guide their respective operations.”[27]
  • Not all TCCs have the will or capability to do offensive operations, which in the stabilization context might include actions aimed at degrading or even neutralizing aggressors. It may thus be better to work with a few TCCs that do have the capabilities and are willing to use it. This means that the FIB-model, where a special brigade or battle-group is created for a limited period around a specific objective, is a more realistic way to generate the kind of forces needed for stabilization operations. Mali presents another complimentary model, where nations with advanced technological capabilities can provide tactical intelligence and support capabilities to those forces that have the capacity to undertake offensive operations.
  • If we associate UN peacekeeping with blue helmets and white vehicles, which symbolize the impartiality and transparency of an inter-positional force, then stabilization operations can be said to require a green posture. If your task is to degrade or even neutralize the capabilities of identified aggressors, then stabilization operations must be able to use stealth, attack with surprise, and may need special forces that can operate behind the lines to gather tactical intelligence.
  • In most cases, only TCCs that have a direct interest at stake will be willing to deploy units to a mission where active combat is likely, because only they will be able to justify the increased cost in casualties and loss and damage to equipment, etc. However, using countries with a national interest at stake has both positive and negative consequences, and more effort would need to be devoted to monitor and manage the negative consequences, both at mission and higher political and strategic levels.

These factors, which are not meant to constitute an exhaustive list, remind us why stabilization operations, especially those with an authority to engage in offensive tactics, requires a different mind-set, approach, and set of capabilities than those employed in UN peacekeeping. A business-as-usual approach is likely to result in a serious mismatch between supply (UN peacekeeping) and demand (stabilization context), as the 2014/15 experiences of the UN mission in Mali shows. The mission’s high casualty rate—with 68 fatalities from hostile action as of 31 May 2016—reflects that there is indeed a mismatch between the mandate, the operationalization of the mandate, and the resources made available to the mission in this process.

Stabilization operations that are deployed amidst conflict, and that are tasked with containing aggressors, should anticipate that the aggressors will test their resolve, and the mission should thus be ready to protect itself and other international actors associated with it. When the Security Council mandates a stabilization operation, such missions must be sufficiently resourced with troops, enablers, and appropriate support, as well as with leadership and decision-making processes, to enable them to successfully implement their mandate. There is a considerable risk, however, that the trend of the Security Council to mandate increasingly robust stabilization mandates will not be matched by the requisite resources or capabilities, nor doctrinal developments, to enable these operations to achieve their goals.

Whilst UN stabilization missions should be deployed as part of a larger comprehensive political strategy, the UN will need to take into account that the mission will be constrained in its ability to play a leading or prominent role in mediation and reconciliation, as its actions to contain aggressors may make it more likely to be seen as a party to the conflict by those actors and sectors of the population that are associated with the aggressors. Here we disagree with the Ramos-Horta panel that when a UN mission finds itself in a conflict management posture “it is indispensable that the United Nations play the lead or a leading role in the peace process.”[28]

To some degree, the UN missions in Darfur and South Sudan, because their protection of civilians mandates are perceived by their host governments as partial, are already indicative of this implication, and as a result in both cases the missions themselves cannot play a prominent role in resolving the larger political disputes. However, they do both play important roles in creating the conditions that enable the political process.

We are of the opinion that all stabilization operations, because of their alignment with the government of the day that represents the state, are likely to be considered partial to some extent by some of the political actors and parts of the population, until a political settlement is in place and stability has been restored. Whilst UN stabilization operations should strive to present themselves as impartial when it comes to the political settlement, their mandate to act against certain identified aggressors implies that they cannot expect to be perceived as impartial by all the actors in the conflict. This has important consequences for the role the mission can play in political negotiations. It also has to be carefully considered in the support the mission provides to national authorities in state-building and the extension of state authority, including in security-sector reform, strengthening the rule of law, enhancing state-society relations, supporting elections, and strengthening governance and government services. We believe there is an inverse relationship between the level of force that needs to be used to achieve and maintain stability and the degree to which a UN stabilization mission will be perceived as an impartial mediator in a peace process. As stabilization operations slide towards the more robust end of the scale, the ability to provide good offices and mediate in the crisis will decrease as the UN is increasingly considered, and effectively is, a party to the conflict.

Therefore, we argue that stabilization operations require a new UN doctrine that distinguishes it from the existing peacekeeping doctrine and its core principles, identity, and approach. We do not believe that stabilization operations that meet the characteristics discussed earlier can be accommodated within UN peacekeeping doctrine. When the Security Council mandates the secretary-general to undertake stabilization operations, the UN should not have to do so using the existing peacekeeping doctrine and its blue helmet identity.

A new UN stabilization doctrine with a separate identity should be developed that provides guidance on the conditions that require stabilization and the criteria and benchmarks the UN should consider when deciding whether to deploy a stabilization or peacekeeping mission. Such a new doctrine should define clearly what stabilization means in the UN context, and how it differs from peacekeeping. It should also provide guidance on the kind of leadership tools, command and control, capabilities, mission support and logistics, and rules of engagement and equipment that would be required should the UN be tasked with a stabilization mandate.

A separate stabilization doctrine will help to protect the existing peacekeeping doctrine and identity it from being misapplied in contexts where it is not fit for purpose. It will also help the UN maintain credibility and legitimacy by ensuring that it has appropriate doctrine, equipment, and soldiers that are prepared for the type of task assigned to it by the Security Council.

In terms of core principles for stabilization missions, the UN needs to clarify what consent and impartiality mean in a stabilization context and how they may differ from the way these principles are applied in UN peacekeeping. Consent by the host government is likely to be a requirement for the UN in most cases, bar extreme mass atrocity crime scenarios, but consent from the other parties to the conflict is likely not to be a pre-requisite, especially not from those associated with the aggressors such missions will be tasked to contain. However, wide consent is of course desirable and gaining consent, including through an impartial posture towards all the peaceful political entities, will be a benchmark for a transition to a UN peacekeeping operation, and should thus be embedded in the idea of “campaign authority.”

The principles regarding the use of force will be important elements for a UN stabilization doctrine. As the proactive and offensive use of force concepts are new elements not previously dealt with in UN doctrine, they will need to be unpacked in detail, together with associated principles of proportionality and minimum necessary use of force. Such a doctrine will also need to provide guidance to UN forces acting in support of national security forces, including principles and procedures for vetting, accountability, and monitoring.

In addition to military action, the UN stabilization doctrine should also identify the role and contribution of the UN police as well as civilian components in stabilization contexts. Individual UN police officers and formed police units can play a significant role in building national capacity and in supporting and bolstering national police capacity. The “civil affairs” component can play an important role in support of enhancing state-society relations and extending state authority. The “public information” component will have an important role to play in providing information and countering the propaganda of the aggressors and their associates. The “political affairs” component will be central in analyzing the motives and behaviors of the identified aggressors and keeping the stabilization operations politically aligned with the larger political strategy of the UN and international community. More intense military action increases the risk of misconduct, and negative consequences for the civilian and humanitarian community, and units that have the competencies to monitor, mitigate, and advise the mission leadership on these aspects, and that can manage the liaison with the humanitarian community, will also be crucial for the success of such missions.

The adoption of a stabilization doctrine does not imply that the UN should seek to play an expanded role in stabilization contexts. The UN should maintain its preference not to do stabilization operations, and thus make it clear that it should only be tasked to undertake stabilization operations in exceptional cases and as a last resort. In order to avoid the exception becoming the rule, the UN should take steps to help ensure that others that are willing, such as the AU, are better able to do so in future: for instance, by funding AU operations, or helping to find more predictable sources of funding for AU operations, so that the UN is not forced into taking over stabilization operations from the AU for lack of resources, as it had to do in the CAR.

Another important aspect relates to the larger strategic coherence of the international effort. If a UN stabilization mission is only one element in a larger UN and international engagement, how is the larger UN and international effort coordinated? Who ensures overall coherence and alignment? What processes are in place to ensure that the different parts of the UN and internal system pull in the same direction, and are aligned to local political developments? Recent experiences in Afghanistan, Somalia, and elsewhere have demonstrated how difficult it is to achieve coherence among international and regional organizations such as the UN, the AU, NATO, the EU, and the World Bank, and how challenging it is to align their goals with the priorities and objectives of the national and local authorities.


The Ramos-Horta panel pointed to the need to better clarify what stabilization entails in a UN context. In this chapter we have made a first attempt to contribute to a deeper reflection on what stabilization means in the UN peace operations context, and have considered the diverging understandings that currently exist. We have argued that stabilization needs to be clearly defined to make sure that the UN and its partners are on the same page when future UN stabilization missions are mandated and deployed.

If we zoom further out, our modest ambition has been to contribute to a deeper discussion on UN doctrinal development by way of bringing to light and discussing key member states’ positions on UN peacekeeping, as well as emerging practices from the field. Together with the Ramos-Horta report, we hope that this book can contribute to and stimulate further debate on UN doctrine for peace operations.

This debate is becoming increasingly important and relevant. After many years’ decline, the number of conflicts has been on the rise over the last few years, so the relevance and need for UN peace operations will grow. At the same time, and in a period of turbulence in global governance, UN peace operations remain the most credible and legitimate international mechanism for conflict management and resolution. In addition, we are in a period characterized by financial austerity since the global financial crisis in 2008-9. In this larger context, UN peace operations will continue to be the preferred (and most cost-efficient) choice of the international community when it comes to dealing with conflicts and increasing transnational asymmetrical threats.

[1] UN, “Uniting our Strengths for Peace: Politics, Partnerships and People,” Report of the High-Level Independent Panel on Peace Operations, New York, 16 June 2015.

[2] Ibid, 28.

[3] Ibid, 29.

[4] Sian Herbert notes that out of the 49 missions examined in his report, 30 use the words “stability” or “stabilization.” See Sian Herbert, “Stability and Stabilisation Approaches in Multinational Interventions,” Helpdesk GSDRC Research Report, Applied Knowledge Services, http://www.gsdrc.org/docs/open/HDQ966.pdf.

[5] NATO, “Political Guidance on Ways to Improve NATO’s Involvement in Stabilisation and Reconstruction,” Brussels, 2011.

[6] For an academic review of such stabilization tasks, see Christian Dennys, Military Intervention, Stabilisation and Peace: The Search for Stability (London: Routledge, 2014).

[7] The so-called P3 in the Security Council (France, the United Kingdom, and the United States) has through precedent taken responsibility for drafting most of the Security Council resolutions, and it is thus reasonable to link the emergence of the term “stabilization” in UN mandates to its prominence in the domestic doctrines and usage in these countries over the last decade.

[8] NATO, “Political Guidance”; and Chiyuki Aoi and Yee-Kuang Heng, Asia-Pacific Nations in International Peace Support and Stability Missions (New York: Palgrave, 2014).

[9] For an earlier academic attempt as such, see Chiyuki Aoi, Legitimacy and the Use of Armed Force: Stability Missions in the Post-Cold War Era (London: Routledge, 2011).

[10] Note, as a prominent example, UK Ministry of Defence, Development, Concepts and Doctrine Center (DCDC), “Security and Stabilisation: The Military Contribution,” Joint Doctrine Publication (JDP) 3-40, November 2009. This states that “stabilisation is the process that supports states which are entering, enduring or emerging from conflict in order to: prevent or reduce violence; protect the population and key infrastructure; promote political processes and governance structures which lead to a political settlement that institutionalises non-violent contests for power; and prepares for sustainable social and economic development,” ibid, xv. See also Stabilisation Unit (a British cross- government unit), “The UK Government’s Approach to Stabilisation (2014),” London, 2014, http://www.sclr.stabilisationunit.gov.uk/attachments/article/520/TheUKApproachtoStabilisationMay2014.pdf.

[11] Ibid, 24.

[12] UN, “Uniting our Strengths for Peace,” 32.

[13] Ibid, 31.

[14] DPKO/DFS, “United Nations Peacekeeping Operations: Principles and Guidelines” (so-called “Capstone Doctrine”), United Nations, New York, 2008, http://www.un.org/en/peacekeeping/documents/capstone_eng.pdf.

[15] UN, “Uniting our Strengths for Peace,” 30.

[16] UK Ministry of Defence, “Security and Stabilisation,” 2-13; see also US Department of the Army, “Stability” doc. no. FM 3-07, 2014.

[17] Cedric de Coning, “Do we need a UN Stabilisation Doctrine?” in What Needs to Change in UN Peace Operations? An Expert Briefing Book Prepared for the High-Level Independent Panel on Peace Operations, ed. Richard Gowan and Adam C. Smith (New York: New York University and International Peace Institute, 2014), 31-2.

[18] Interview with official at UK Ministry of Defense, DCDC, 2009.

[19] Note the US military definition of stability operation: Stability operations encompass “various military missions, tasks, and activities conducted outside the United States in coordination with other instruments of national power to maintain or reestablish a safe and secure environment, provide essential governmental services, emergency infrastructure reconstruction, and humanitarian relief (JP 3-0),” as cited in US Department of the Army, “Stability” and the subsequent passages on pages vi-vii of the same document.

[20] See Samuel Griffin for a discussion about doctrinal boundaries: Samuel Griffin, “Iraq, Afghanistan and the Future of British Military Doctrine: from Counterinsurgency to Stabilisation,” International Affairs 87, no. 2 (2011): 317-33.

[21] See, for example, AFM; and Ministry of Defence, “Security and Stabilisation.”

[22] Robert Muggah, “The UN Turns to Stabilisation,” Global Observatory, 5 December 2014.

[23] UN, “Uniting our Strengths for Peace,” 30.

[24] John Karlsrud and Adam C. Smith (2015) European Military Participation in MINUSMA: Experiences and Lessons-Learned. New York: International Peace Institute.

[25] DPKO/DFS, “United Nations Peacekeeping Operations” (Capstone Doctrine), 16-19.

[26] UN, “Uniting our Strengths for Peace,” 31.

[27] Ibid, 32.

[28] Ibid, 31.

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