How Aid Negatively Impacts Conflict: The Moral and Practical Dilemmas Faced by Humanitarian Organizations

Transcription

1 How Aid Negatively Impacts Conflict: The Moral and Practical Dilemmas Faced by Humanitarian Organizations Randi L.S. Lassiter In the post-cold War period, humanitarian operations of NGOs and UN organizations find themselves in a position of unprecedented involvement in civil wars and internal conflict. Modern conflicts are largely internal and are characterized by an overall tendency toward increased brutality. No one is spared as warring groups violate some of the most austere laws of war by targeting civilian populations. Inevitably, the poorest and most vulnerable members of society, namely the sick, elderly, women, and children, fall victim to the onslaught. A fundamental aspiration of all humanitarian organizations is the alleviation of human suffering. In such situations, the capacity for humanitarian aid to do good by saving lives is undeniable. However, there is a darker side to humanitarian assistance, for the same aid intended to alleviate suffering caused by conflict has the capacity to exacerbate and prolong conflict, further compromising the safety of those individuals to whom they aim to deliver assistance. Relief agencies, long beholden to the principle of neutrality, along with impartiality and independence, have been confronted with the idea that, although well intended, aid can often have a non-neutral effect on war. Amid rising criticism of the negative effects of aid, relief agencies have been forced to reflect on their harmful capabilities and reassess the ethics of their work. Simply doing good may not be good enough. This paper seeks to explore how aid can directly and indirectly fuel conflict drawing upon lessons learned in Sudan and Rwandan refugee camps in Zaire. It also analyzes the practical and moral dilemmas faced by relief agencies and possible courses of action they can take to minimize their contribution to conflict. The resources aid agencies provide in the context of war can exacerbate conflict in one of three ways. These include direct and indirect impacts on conflict and implicit ethical messages which encourage existing conflict mentalities. Humanitarian assistance directly feeds the war effort when aid is inadvertently or intentionally distributed to combatants who are thus relieved from having to find RANDI L.S. LASSITER is a senior at the College of William and Mary majoring in Neuroscience and minoring in Anthropology. As an aspiring physician, Randi s interests include community service, global health, and promoting medicine as a basic human right. She would like to thank Professor Anne Edgerton for lending her expertise on humanitarian aid as well as her support throughout the development of this paper.

2 How Aid Negatively Impacts Conflict 51 food for themselves. As seen in Rwandan refugee camps in Zaire, when militants hide among refugees, aid can be inadvertently diverted to combatants. Combatants may also steal food, medicine, and equipment, or exaggerate populations needs to humanitarian organizations and pocket the excess aid. 1 Although it is not necessarily the most important way in which aid feeds conflict, theft is the most widely acknowledged means by which aid contributes to conflict. 2 In addition to diverting food and medical supplies intended for civilians, militants may also steal vehicles, communication systems, and other essential resources to be used or resold for profit. The latter practice corroborates the notion that aid not only provides sustenance to militants, but also sustains the war economy. Relief resources can further finance conflicts when militant groups levy war taxes on refugee populations or exact fees for services such as import-export services, hired guards, and loaned use of vehicles. 3 In addition to impacting war directly by feeding troops and sustaining the war economy, resource transfers may also have indirect negative impacts on conflict. Aid also sustains and protects militants families and civilian supporters, relieving militants of their responsibility to do so. In her book, Do No Harm: How Aid Can Support Peace-Or War, Mary B. Anderson phrases it most definitively: When external aid agencies assume responsibility for civilian survival, warlords tend to define their responsibility and accountability only in terms of military control. 4 Furthermore, as aid assumes the role of the government to provide infrastructure during wartime, warriors become increasing dependent upon aid and ill-prepared to assume responsible leadership roles in the postwar period. 5 Aid also indirectly impacts conflict by influencing incentives for peace. One way in which aid lowers incentives for peace involves the capacity for emergency relief to reinforce a war economy simply because aid creates jobs. Aid agencies hire local individuals or groups as translators, drivers, and managers, and pay owners of needed hotels, houses, and vehicles, creating a group of people whose economic survival is linked to war-related enterprises. These individuals develop a stake in the continuation of conflict rather than in its cessation. 6 The distribution of humanitarian assistance can also reinforce existing societal divisions. Competition and tension mount between those who receive aid and those who do not, especially when aid agencies label people in need according to subgroup identities. 7 The third way in which humanitarian organizations can enhance and prolong conflict involves the implicit ethical messages that emanate from the conduct of organizations in the field and the manner in which aid is distributed. Foremost of all messages is that of international legitimacy of rebel groups and their political goals. By their mere presence, let alone their willingness to pay taxes to or negotiate access with rebel factions, relief agencies, as Sarah Kenyon Lischer phrases it, solidify the reputation of the group as powerful and legitimate. 8

3 52 The Monitor - Fall 2007 Anderson, a noted expert on the negative effects of aid, identifies seven other messages that can be conveyed by aid. First, when aid agencies hire armed guards and escorts, they reinforce the notion that might equals right. She says, It is impossible for aid to adopt the modes of warfare without reinforcing their legitimacy. 9 Second, the inclination of aid agencies to compete for funding rather than cooperation, typically by criticizing the work of other agencies, sends the message that it is unnecessary to cooperate with or respect people of different opinions, perpetuating an environment in which differences are not tolerated. Third, when aid workers use their goods and support systems for their own pleasure during rare opportunities for recreation, local people see their behavior as acts of impunity. This conveys the message that control over resources gives one complete freedom to decide what to do with them and that accountability is unnecessary. Fourth, humanitarian assistance can send a message of inequality in the value of lives and time when foreign aid workers are treated differently from local staff. For instance, expatriates are paid higher salaries, provided with transportation to work, and are evacuated first in times of crisis. Local staff members are paid lower salaries and are expected to walk long distances to work everyday. The fact that radio equipment may be evacuated before local employees (if they are evacuated at all) gives one the impression that resources have a higher value than the local man. Fifth, when field-based staff members project a powerlessness over the events around them, deferring all responsibility for failures in aid upon higher-ups at headquarters and donor communities, they demonstrate absolution from one s situation, reinforcing a perpetual victim mentality. It is always someone else s responsibility to affect change, to make peace. Sixth, humanitarian workers reinforce prevalent modes of interaction by being overly assertive and belligerent in their dealings with armed groups, although this may be just a mere manifestation of nervousness in times of increased tension. By assuming the worst in others, they reinforce the likelihood that the worst will happen. Seventh, by showing gruesome pictures in the media for the purposes of publicity, aid agencies run the risk of demonizing one side in war. There have been some cases in which militants commit atrocities against their own people in an effort to play to international sentiment.¹⁰ In his paper, Is Humanitarianism Part of the Problem?: Nine Theses, Roberto Belloni criticizes humanitarianism for sustaining a worldview in which individuals are either victims or perpetrators rather than human beings in [a] complex set of relationships. ¹¹ The danger in having such a naïve outlook is elaborated below in the context of Rwandan refugee camps in Zaire. The scenarios described above have appeared in numerous theaters of war. However, the following analysis limits the discussion of the negative implications of humanitarian assistance to case studies of conflict in Sudan and Rwandan refugee

4 How Aid Negatively Impacts Conflict 53 camps in Zaire. Sudan s history has been plagued by various internal conflicts, many of which stem from political ostracism felt by Southern Sudanese and Muslim populations which have been excluded from central power since A civil war between rebel groups such as the Sudan Peoples Liberation Army and Movement (SPLA/M) and the Sudanese government has persisted since 1983, leading to hundreds of thousands of deaths, famines, and the displacement of millions of Sudanese people. Operation Lifeline Sudan (OLS), a multi-ngo aid operation, was launched by the United Nations in 1989.¹² UN negotiations with all participants in the conflict led to the government allowing aid convoys into rebel territory for the first time, essentially broadening accessibility to the entire war zone. However, progress garnered through negotiated access came at the price of neutrality and impartiality as OLS became embroiled in Sudanese politics.¹³ Aid exacerbated the conflict in Sudan in several ways. Relief supplies were regularly stolen or diverted as international assistance provided a major source of income for the SPLA and granted the liberation movement legitimacy by conceding that the SPLA was an organization worth acknowledging in aid negotiations. Khartoum also found a means to profit from and control the massive influx of resources. The government speculated with foreign currency exchange rates, and reports that Khartoum was provisioning troops with aid were common. The presence of aid agencies also allowed the Sudanese government to build up strategic bases of support in the South and a means to resettle refugees according to political and economic strategies.¹⁴ According to John Prendergast of the Center of Concern, poor assessments of local food requirements enabled massive diversions of relief supplies, and certain NGOs exhibited favoritism in the distribution of aid.¹⁵ Furthermore, food donated to the North freed local production for export. Reports estimated that Sudan may have exported up to a million tons of sorghum in 1995 alone.¹⁶ The increase in GDP was undoubtedly used to finance the war. The case of Sudan demonstrates how aid can impact conflict directly, indirectly, and through the implicit ethical messages. Another portrait of the darker side of humanitarian aid manifested itself in the case of the Rwandan refugee crisis in Zaire. The Rwandan genocide began on April 6, 1994 when Hutu government extremists intent on arresting a power-sharing agreement with the minority Tutsi ethnic group encouraged Hutus to carry out a planned extermination of Tutsis and moderate Hutus perceived to support the Tutsi-dominated Rwandan Patriotic Front (RPF). Between 500,000 and 800,000 Tutsi and moderate Hutu were killed.¹⁷ When the RPF launched a stronger counter-offensive and the defeat of Rwandan Armed Forces (FAR) appeared imminent, FAR exhorted Hutus to flee the country. The largest mass exodus of refugees in history occurred in July 1994 when 500, ,000 Hutu Rwandans entered the neighboring country of Zaire.¹⁸ Emotionally

5 54 The Monitor - Fall 2007 supercharged media headlines describing Zairian refugee camps resulted in a massive outpouring of relief.¹⁹ Not only the FAR had blood-stained hands from the genocide. Because the instigators had encouraged all Hutus to become involved, thousands of people participated in the killing, some because of hatred or financial gain, but others participated reluctantly out of fear of the FAR. Refugee camps were comprised of a mixture of true refugees and ex-combatants fleeing out of fear of retaliation or prosecution by the RPF.²⁰ Under the Geneva Conventions, the latter group should have been denied refugee status, but the sheer volume of people made it impossible for aid agencies to distinguish real refugees from armed génocidaires hiding amongst them. Estimations approximate that 20,000-50,000 militia members accompanied the refugees into exile.²¹ Although only narrowly avoiding defeat, the Rwandan army was able to flee into Zaire virtually intact. With substantial financial resources and military hardware at their disposal, those intent upon returning to Rwanda to complete the genocide were able to regroup and establish a territorial base with the support and training from Zairian authorities.²² The so-called ex-far established military training bases nearby Rwandan refugee camps where they were able to stockpile weapons, recruit and train refugee fighters, and launch cross-border attacks.²³ Aid agencies made the mistake of allowing former Rwandan administrative structures to control the distribution of aid in camps in Goma and Bukavu. Consequently, aid was manipulated and diverted in order to enhance the ex-far conflict objectives. Control mechanisms employed by camp leaders included intimidation, violence, and propaganda aiming to endorse an image of insecurity in Rwanda and discourage refugees from repatriation.²⁴ Camp leaders made use of camp radios in order to broadcast messages justifying genocide.²⁵ Besides the obvious fact that aid was used to feed combatants and supporters of genocide, because humanitarian assistance fed the refugee population, the FAR did not have to. This freed up FAR economic resources to fuel the war. Refugee camp leaders imposed a thirty per-cent war tax on wages paid to Rwandans employed by aid agencies in order to finance the war economy.²⁶ Humanitarian assistance also financed the war economy as camp leaders inflated population numbers in order to receive excess resources or stole aid supplies. Camp leaders would also charge refugees for free supplies from the United Nations High Commissioner on Refugees (UNHCR).²⁷ Perhaps the most significant way in which aid contributed to conflict was by bestowing legitimacy and protection upon the genocide perpetrators. By acknowledging Hutu extremist as refugees deserving of asylum, they acquired legal protection under Article I.2 of the 1969 OAU Convention Governing Specific Aspects of Refugee Problems in Africa.²⁸ In the context of such situations, aid agencies are faced with moral and

6 How Aid Negatively Impacts Conflict 55 practical dilemmas. In the face of increasing criticism, NGOs and donors are moving toward adopting the Hippocratic principle, primum non-nocere, first do no harm, which simply means that aid agencies recognize that aid should not harm its beneficiaries.²⁹ However, Anderson warns, It is a moral and logical fallacy to conclude that because aid can do harm, a decision not to give aid would do no harm.³⁰ The situation is a far more complex moral dilemma. A moral dilemma is defined as a choice between two wrongs. Effectively, there is no possible course of action that does not breach a binding moral principle. In such a situation, aid agencies can adopt a defeatist attitude, viewing certain conflict situations as no win situations, or they can view dilemmas as a challenge to determine the lesser of two evils. ³¹ Belloni says, There are no perfect choices, but humanitarians should learn to distinguish between better and bad ones. ³² The course of action that aid agencies decide to take depends upon a development of ethics around moral dilemmas that starts with deciding where one stands in the ancient philosophical debate about the nature of goodness and the limits of moral responsibility. There are deontological, or duty-based, ethics that believe that certain actions, such as healing wounds, are intrinsically good. This approach is countered by teleological, or goal- based ethics, which are more concerned with the wider consequences of an action. From this perspective, healing a person s wounds is not always good if that person is then able to return to war to kill innocent people. Assessment of good is much easier for deontologists whose ethics are mere matter of doing one s duties, whereas teleological ethics are much more complicated and uncertain.³³ Agencies which adopt the latter approach can only justify distribution of aid by its potential to do more good than harm. Rony Brauman states, From a moral standpoint, weighing the pain inflicted against the pain avoided is an impossible endeavor. ³⁴ For a consequentialist, providing aid, knowing that it is being manipulated to intensify and prolong conflict presents a moral dilemma, In this case, providing aid causes harm, yet a decision to withdraw aid counters the most fundamental element of the humanitarian mandate to provide assistance to those in need. Hugo Slim, Director for the Center for Development and Emergency Practice (CENDEP), warns that the sometimes difficult choices masquerade as moral dilemmas. One type of tough choice which is often mistaken for a moral dilemma, referred to here as a practical dilemma, occurs when moral reasons for or against an act are in conflict with non-moral reasons.³⁵ An aid agency s reluctance to withdraw humanitarian assistance out of fear of losing funding is a common example of a practical dilemma faced by humanitarian agencies.³⁶ Because each agency adheres to its own unique mission mandate, agencies often lack solidarity in their efforts to avoid the negative effects of their work in the field.. On one hand, no organization can guess what the others will do, and

7 56 The Monitor - Fall 2007 agencies fear that if they withdraw, they will lose their market share of donations and status as a pre-eminent institution to the other organizations that stay. On the other hand, those aid agencies that choose to remain do so at the risk of losing their moral clout if their aid proves harmful.³⁷ Another practical challenge faced by humanitarian organizations is that required immediate response to emergency situations does not allow enough time for the planning necessary to avoid all negative consequences.³⁸ It is also notable that, for financial reasons, aid agencies oftentimes lack ideal independence from the UN and donor governments to make decisions in the field concerning where, how, and to whom aid is distributed.³⁹ Thus many NGOs are non-governmental only in theory. They are constrained by UN member governments, which may not understand nor prioritize preventing aid from worsening conflict. There are various ways in which aid agencies can mitigate their negative effects on conflict without having to withdraw assistance. During the United Sates Institute of Peace s symposium on Humanitarian Assistance and Conflict in Africa, collaboration between several concerned NGOs led to the identification of eight major steps NGOs can take to mitigate the direct and indirect negative impacts of aid. These steps encourage aid agencies to improve planning, assess local need more accurately, analyze the consequences of negotiated access, target and select the type of aid more carefully, contract independent monitoring and evaluation programs, empower local institutions, coordinate closely with other assistance programs, and deploy human right monitors to help protect local populations from exploitation. Planning may involve employing experts on the country in crisis to provide training and advice to personnel in the field and risk mapping, or identifying potentials for the misuse of aid, in advance.⁴⁰ At the symposium, John Prendergast attributed many of the problems encountered in Rwandan refugee camps in Zaire to ignorance and a lack of preparation. He suggests that rather than blindly accepting reports about food requirement from local informants, agencies may want to explore asking women, who are generally well-versed about household needs.⁴¹ This approach can help curtail diversion of supplies which occurs as a result of inflating population numbers. Aid agencies must assess how negotiations with armed groups can affect their neutrality and contribute to the legitimacy of a warring party. Donors need to select aid that maintains its value to the intended beneficiaries while providing a low incentive for it to be stolen.⁴² In Somalia, for example, the Red Cross distributed blankets that had been cut in half. While families could easily sew them back together, the blankets resale value plummeted, decreasing incentives to steal them.⁴³ Aid agencies should also avoid the mistake of allowing local leaders to deliver aid when conflict is ongoing. Although the provision of aid from one group to another creates an inherent dependency, humanitarian organizations can work to

8 How Aid Negatively Impacts Conflict 57 minimize this dependency. NGOs can encourage local authorities to fulfill their responsibilities for civilian welfare by engaging local NGOs rather than fostering a government of aid-dependent warriors unprepared to take over responsibilities of infrastructure assumed by nondomestic aid agencies in time of conflict. Additionally, while coordination in the field is a difficult task, it is a necessary step to avoid manipulation by local armed groups.⁴⁴ Mary Anderson asserts that aid feeding into and prolonging and exacerbating war is not inevitable so long as aid reinforces local capacities for peace and involves the beneficiaries of aid in discussions about its impact.⁴⁵ By buying goods locally, rather than importing them, aid agencies can combat posing a threat to the peacetime economy by encouraging it. They can also agree to fixed prices and wage rates for local goods and services and initiate discussions with local people about war profiteering in order to develop a system of community-based accountability. To counter reinforcement of intergroup tensions, aid agencies can create programs in which everyone benefits. They can also distribute aid in such a way that reinforces their interdependence. In order to increase the capacity of rebel groups to assume responsibility for civilian welfare in times of peace, aid agencies can educate and expose commanders to all aspects of aid and the impact of their policies.⁴⁶ To combat all of the negative implicit ethical messages of aid, agencies would ideally avoid all negotiation with armed groups and contracting militias for security purposes, coordinate with other agencies, never take time for recreation, always be the last in line for supplies and evacuation, assert unfounded efficacy in the field, believe only the best about everyone, and never utilize images of suffering for advertising purposes. Such an aid worker is unrealistic and would be ill-suited for relief work.⁴⁷ Realizing that is it virtually impossible to avoid every negative capability of aid, relief agencies should strive to find a balance in which aid does more good than harm by taking necessary steps in the appropriate contexts. In an attempt to combat aid s contribution to conflict in Sudan, OLS introduced a new system to assess local food requirements and consider the effects of food aid on the broader economic context so as not to undermine local production. NGOs also introduced human rights monitoring and effectively involved local Sudanese in decisions about the process of distribution. Despite failure of warring groups to move toward peace, OLS achieved substantial progress as a result of such program adjustments over the five year period from the start of the operation until OLS also demonstrated an impressive level of coordination amongst relief agencies.⁴⁸ With the realization that humanitarian aid delivered to Rwandan refugee camps in Zaire was feeding conflict, aid agencies were faced with a dilemma. Agencies weighed the consequences of further support against the benefit

9 58 The Monitor - Fall 2007 of staying without backing for UNHCR proposed initiatives to demilitarize camps.⁴⁹ Despite the fact that international donors were willing to spend $1.3 billion to sustain Rwandan refugee populations, they were unwilling to finance disarmament programs.⁵⁰ Several organizations decided to withdraw completely. After the murders of thirty-five Rwandan scouts that had been hired to control access to the camp and direct traffic in an effort to establish security separate from the political and military leadership of camp leaders at the Katale camp, CARE Canada decided to withdraw from all Goma Camps in October The International Rescue Committee (IRC) also withdrew from Zairian camps. MSF- France decided to withdraw its support in both Zaire and Tanzania upon discovery that aid was being used against refugees.⁵¹ The UNHCR, however, decided to stay. When the UN rejected requests to move camps farther from the border and hire a private security firm were rejected for logistical and financial reasons, the UNHCR shifted its priority to repatriation. Other NGOs that decided to stay did so out of the adherence to the humanitarian mandate to provide assistance to true refugees in need, a belief in the possibility for change, a pragmatic focus on the technical provision of relief, institutional logic concerned with maintaining relationships with donors, and sympathy for the Hutu cause.⁵² Some defenders of aid agencies argue that the negative effects of aid have a minimal, and perhaps negligible, effect on war. However, it is difficult if not wholly impossible for aid agencies confidently to measure their direct and indirect effects on conflict, and it is even more arduous to assess the ramifications of implicit ethical messages. This defense is unfounded and reflects a reluctance to concede the extent to which humanitarian principles are compromised in the field and accept responsibility for the darker side of humanitarian assistance. The fact is that aid agencies are only ideally, though not actually, neutral, impartial, and independent in the context of conflict. As Anderson states, aid agencies have no choice but to accept the reality that, When international assistance is given in the context of a violent conflict, it becomes a part of that context and thus also of the conflict. ⁵³ After having come to the realization that harm is a consequence of aid, aid agencies must analyze the ethics of what they do. Possessing purity of intentions is indeed admirable but insufficient. Although it may be difficult to divorce the notion of doing good from humanitarian assistance, aid agencies that profess to be truly concerned with human welfare must concern themselves with not only alleviating suffering, but protecting people from suffering caused by aid. Hugo Slim states it poetically: the true challenge for the relief worker is to develop a negative capability: that ability to be present in the worst of human situations; to be faced with the hardest of choices, and yet still to respect and protect human life in a way which constantly challenges evil without colluding in it. This is no easy task. ⁵⁴

10 How Aid Negatively Impacts Conflict 59 Notes ¹ Lischer, Sarah Kenyon. Collateral Damage: Humanitarian Assistance as a Cause of Conflict. International Security 28, no. 1 (2003): journals/international_security/v028/28.1lischer.pdf (accessed May 8, 2007). ² Anderson, Mary B. Do No Harm: How Aid can Support Peace--or War. Colorado: Lynne Rienner Publishers, Inc., ³ Ibid. ⁴ Ibid., 49. ⁵ Ibid. ⁶ Ibid. ⁷ Ibid. ⁸ Lischer 2003, 85. ⁹ Anderson 1999, 55. ¹⁰ Ibid. ¹¹ Belloni, Roberto. Is Humanitarianism Part of the Problem? Nine Theses. BCSIA Discussion Paper , Kennedy School of Government, Harvard University, April (accessed May 8, 2007). p. 17 ¹² Weissman, Fabrice, ed. In the Shadows of Just Wars : Violence Politics and Humanitarian Action. London: C Hurst & Co., ¹³ Ostheimer, Andrea E. Aid Agencies: Providers of Essential Resources? Angola s War Economy: The Role of Oil and Diamonds. Eds. J. Cilliers, C. Dietrich. Pretoria: ISS Publications, Ostheimer.pdf (accessed May 4, 2007) ¹⁴ Ibid. ¹⁵ Smock, David R. Humanitarian Assistance and Conflict in Africa. United States Institute of Peace. Peaceworks 6, Posted February 1, pubs/peaceworks/pwks6.pdf (accessed November 15, 2007). ¹⁶ Ibid. ¹⁷ Lischer ¹⁸ Terry, Fiona. Condemned to Repeat? The Paradox of Humanitarian Action. New York: Cornell University Press, ¹⁹ Waters, Tony. Bureaucratizing the Good Samaritan: The Limitations of Humanitarian Relief Operations. Colorado: Westview Press, ²⁰ Terry ²¹ Lischer ²² Terry ²³ Lischer ²⁴ Terry ²⁵ Ibid. ²⁶ Ostheimer ²⁷ Terry ²⁸ Ibid. ²⁹ Ostheimer 2000.

11 60 The Monitor - Fall 2007 ³⁰ Anderson 1999, 2. ³¹ Slim, Hugo. Doing the Right Thing: Relief Agencies, Moral Dilemmas, and Moral Responsibility in Political Emergencies and Wars. Disasters 21, no. 3 (1997): (accessed May 8, 2007). p. 247 ³² Belloni 2005, 25. ³³ Slim ³⁴ Tanguy, Joelle and Fiona Terry. On Humanitarian Responsibility. Ethics & International Affairs 13 (1999). opedsarticles/humanitarian.cfm (accessed May 8, 2007) ³⁵ Slim ³⁶ Lischer 2003 ³⁷ Ibid. ³⁸ Smock 1996 ³⁹ Ibid. ⁴⁰ Ibid. ⁴¹ Ibid. ⁴² Ibid. ⁴³ Anderson ⁴⁴ Smock ⁴⁵ Anderson ⁴⁶ Ibid. ⁴⁷ Ibid. ⁴⁸ Smock ⁴⁹ Terry ⁵⁰ Lischer ⁵¹ Terry ⁵² Ibid. ⁵³ Anderson 1999, 1 and 145. ⁵⁴ Slim 1997, 257.