COMPLIANCE MATTERS

Recent developments relating to compliance with multilateral treaties
in the area of disarmament and international security.

The newsletter of the Markland Group

Issue No. 6, November 1998


This newsletter was originally published as part of the Canadian Council on International Law Bulletin, Vol. 24, No. 2, Spring-Summer 1998. The version that follows has been slightly edited since it first appeared in the Bulletin.


In This Issue

I.       The Chemical Weapons Convention

II.      The Biological Weapons Convention

1.  BWC Verification Protocol Negotiations

2.  Cuba's Complaint Against The U.S.

III.     The ABM Treaty - Recent developments

IV.     Iraq: The On-Going Monitoring and Verification System

1.  Mandatory Legislation

V.      Book Review

 


I.       The Chemical Weapons Convention

Latest reports from the Organization for the Prohibition of Chemical Weapons (OPCW) demonstrate that the era of treaty-mandated disarmament has arrived. The OPCW press release of 24 June 1998 reports that as of 1 May 1998, OPCW inspection teams had witnessed the destruction of approximately of 1,115 metric tonnes of nerve agents and 1,468 metric tonnes of declared unfilled munitions devices. Nine certificates confirming the complete destruction of chemical weapons production facilities in four States Parties - China, France, the United Kingdom and the United States of America - had been issued by the Director-General.

Problems, however, are being experienced in the matter of declarations: 26% of the States Parties have not submitted the requisite initial declarations despite repeated requests. Also, 43.9% of the budget contributions for 1998 are in arrears. The Markland Group inquired of the OPCW as to its policy on the release of names of the countries involved in these defaults. No names are being released as matters now stand, but those in default of budgetary contributions may be named in the near future. On the other hand, the release of names of those in default of declarations could be more delicate and no moves in this direction are being planned at present.

II.    The Biological Weapons Convention

1.      BWC Verification Protocol Negotiations

(Brian Finlay-Dick contributed significantly to this section)

The latest in a series of meetings of the Ad Hoc Group under the BWC for the purpose of negotiating a verification protocol for the Convention took place in Geneva in March 1998. For a brief background note on this matter, see the previous issue of Compliance Matters.

At the conclusion of the five-day session, the so-called "rolling text" of the draft protocol reached 247 pages. The lion's share of the rolling text remains heavily bracketed. Discussions remain stalemated over myriad questions including those of compliance, confidentiality, scientific and technological exchange for peaceful purposes, and dispute settlement.

Non-aligned countries continued to push hard for stronger technical and scientific cooperation measures to be included in the compliance protocol. Some non-aligned states also called for an end to the current export control mechanisms, such as the one put in place by the Australia Group.

For their part, both the Biotechnology Industrial Organization (BIO) and the Pharmaceutical Research and Manufacturers of America (PhRMA) have expressed a willingness to support the BWC - but only if their concerns related to inspections are met. PhRMA maintains that, while the regular and challenge inspections of their members' facilities, as proposed by the AHG, may be acceptable, each individual firm must ultimately have jurisdiction to determine what is proprietary and therefore, what is 'out-of-bounds' for international inspection. In the case of the Chemical Weapons Convention, the support of private manufacturers was given without reservation which proved to be crucial to the successful negotiation of the treaty. The same cannot be said for that PhRMA which is proving to be an impediment to the negotiations.

Additional insight into the state of the negotiations is provided by Professor Graham Pearson writing in the May 1998 issue of Trust & Verify. He notes that the EU has taken a common position committing 29 States to work for declarations, visits to facilities, rapid and effective investigations into concerns and a cost-effective and independent organization. Professor Pearson sees much common ground with the US position as set forth in its fact sheet of 27 January 1998 which calls for agreement on declarations, voluntary visits, non-challenge clarifying visits and challenge investigations. He sees problems, however, in the US position on voluntary visits, since they must be at the discretion of the facility concerned.

Professor Pearson also refers to the EU's emphasis on the need for rapid action under challenge investigations. He remarks that the "difficulties of conducting investigations some time after an alleged event were clearly shown in regard to the April 1997 Cuban allegation that thrips palmi was dispersed from a US aircraft over flying Cuba.

He also believes he can discern a possible softening of the position of the non-aligned states on the matter of scientific and technical exchange. These States seem now to be attaching more importance to Article X of the Draft Convention "National Implementation Measures", a heading that usually includes mandatory legislation.

The AHG will reconvene for two further sessions to be held 22 June to 10 July, and from 21 September to 16 October in an attempt to settle outstanding disagreements over the final protocol.

2.Cuba's Complaint Against The U.S.

In the last issue of Compliance Matters, we reported that the Government of Cuba had levelled allegations at the U.S. claiming that the latter had willfully and deliberately disseminated a biological agent over Cuban territory on 21 October 1996 in contravention of the 1972 Biological Weapons Convention (BWC), to which both countries are parties. Cuba claimed that a US crop-duster plane, while flying over its territory, released a white substance from its fuselage. Two months later on 18 December 1996, the presence of a plague known as thrips palmi appeared at a local potato plantation in Matanzas Province in the area where the plane had been seen.

In March 1997, Cuba became the first country to make use of a new mechanism under the BWC for dealing with complaints. This mechanism was established by consensus among all BWC parties at the 1991 BWC Review Conference (UN Doc. BWC/C0NFIII/23, p. 15).

The rather meagre details of the 1991 mechanism are summarized in the previous issue of Compliance Matters. Also summarized are the various steps that were taken by the States Parties in response to Cuba's claim. The account given in the last issue brought matters down to mid-October 1997; it told of a Consultative Meeting of States Parties to the Convention at which 74 States Parties attended. The Consultative Meeting elected a "Bureau" consisting of a chairman and six vice-chairmen, including the Canadian representative, Mark Moher. (This body adopted the name "Bureau" in its report; the previous issue of our newsletter referred to it as a "Chair Group".)

Among developments occurring since our last issue, the Bureau received twelve briefs from various States Parties, including one from Canada. These were forwarded to Cuba and the U.S. with a request for comments. The Bureau then met on 27 November 1997 to consider the twelve briefs and the two comments, as a result of which the Bureau agreed by consensus that the Chairman should issue a report to be sent to all States Parties.

The two-and-a-half page report does not contain a summary of the Cuban allegations nor of the U.S. responses. It does, however, attach the complete text of these items and the twelve submissions received from the various States Parties. It should be noted that the 1991 agreed mechanism does not call for investigations, inspections or other procedures for collecting data relevant to the complaint. The report, however, indicates that some of the submissions received by the Bureau contain factual assertions.

The report states that, among the seven members of the Bureau and the ten other countries submitting briefs, there were some that concluded that there was no causal link between the over-flight of the U.S. aircraft and the insect infestation, while there were other countries that asserted that the lack of further detailed information made it impossible to draw any definitive conclusions.

The report appears to have been issued as a consensus document by the seven members of the Bureau. There is no requirement for consensus in the 1991 mechanism, nor was it made a requirement by the Consultative Meeting when it appointed the Bureau in August (BWC/CONS/1). Indeed, the appointment of a body such as the Bureau was not authorized by the 1991 mechanism. These considerations aside, the Chairman of the Bureau was given authority to make a report by the Consultative Meeting in August which stipulated that the report should go to the States Parties without the necessity of assembling the Consultative Meeting again.

The report, dated 15 December 1997, was signed by UK Ambassador Ian Soutar as Chairman of the Bureau. It reaches the following conclusion:

On the basis of the above, I wish to report to States Parties that, due inter alia to the technical complexity of the subject and to the passage of time, it has not proved possible to reach a definitive conclusion with regard to the concerns raised by the Government of Cuba.

It will be noted that the report neither confirms or dismisses the complaint. The Cuban representative made it clear that "her Government continues to adhere to the suspicions which had given rise to the original complaint."

It can be safely concluded that the 1991 mechanism failed to produce anything in the nature of an authoritative evaluation of the complaint. The conclusion to be drawn from that fact is well stated by the Bureau in its report:

The Bureau agreed that the experience of conducting this process of consultation had shown the importance of establishing as soon as possible an effective Protocol to strengthen the Convention which is being negotiated in the Ad Hoc Group.

III.  The ABM Treaty - Recent developments

by Jonathan Matloff and Walter Dorn

Originally designed as a bilateral treaty to prohibit defenses against long-range strategic missiles, the Anti-Ballistic Missile (ABM) Treaty today is being characterized by some as obsolete and by others as pointing to a new global regime.

As a disarmament treaty, the ABM Treaty has always been an oddity. It was based on the theory that the development of new defense-piercing strategic missiles could be effectively prevented by outlawing the development of the defenses themselves. This was deemed a plus, even though it meant that each side had no defense against the other side's existing long-range missiles. This was rationalized on the basis that an aggressor would always be deterred from attempting a nuclear knock-out blow by the prospect of devastating retaliation effected by the other side's missiles. The Treaty was dubbed by some as "mutual assured destruction (MAD)".

In the US, certain Republican senators are arguing that the breakup of the Soviet Union in 1991 renders the basic concept of the treaty invalid. The deterrent relationship upon which the treaty is based, they say, no longer exists in the post Cold-war world. They argue that the US could easily find itself threatened by long-range missiles and that the Treaty is seriously hampering the development of defenses. The Clinton Administration, however, views the treaty as being "at the center of our strategic relationship with Russia today". The Administration recently moved to update the Treaty both in relation to its substantive provisions and in relation to the parties adhering to it. Last September, in New York, the United States signed a Memorandum of Understanding on Succession (MOUS) which "establishes that the parties to the ABM Treaty shall be the United States, Belarus, Kazakhstan, the Russian Federation and Ukraine."

The new parties to the ABM Treaty, in addition to signing the MOUS, signed another agreement which deals with the substantive content of the treaty. It will differentiate between national missile defense (NMD) and theatre missile defense (TMD) systems. Testing and development of TMD systems, such as the Patriot and the Theatre High-Altitude Area Defense (THAAD), will be deemed compliant with the ABM Treaty if they do not exceed a velocity of 5 kilometres per second and a range of 3500 kilometres. TMD systems differ from NMD systems in that they are designed to protect troops in the field beyond the nation's borders, from the threat of short-range missile attack.

Thus, while this agreement allows the parties to continue to develop TMD systems, it makes no change to the ABM Treaty's stringent limitations on the deployment of a strategic or national missile defense. On the other hand, the argument has been heard that the testing and development of TMD systems can be viewed as dual-use in the sense that it might be possible for the technology to be adapted for use in defenses against long-range missiles, in which case a loophole in the basic ABM Treaty would be opened. This line of argument has thus far not prevailed at the policy level in the US or Russia.

The MOUS stipulates that its entry into force is "subject to ratification or approval by the signatory States in accordance with the appropriate constitutional procedures in each State." The same applies to the TMD clarification agreement. The Clinton Administration has yet to submit these agreements to the Senate. It anticipates trouble, especially from Republican Senators many of whom are deeply skeptical of the whole concept of the original ABM Treaty and would be happy to kill it if presented with the opportunity.

Apparently in an effort to sweeten the pill for these Senators, the Administration is planning to package together the two ABM protocols (the MOUS and the TMD clarification agreement) along with an additional agreement which extends the implementation of START II to 2007. By packaging the ABM and START II protocols as one piece of legislation, the Administration hopes to persuade the Senate to accept the ABM amendments, reasoning that the Senate will be less likely to vote down the ABM amendments if that vote also means a derailment of the START II agenda.

The Administration expects that this plan will have the added advantage of putting pressure on the Russian Duma to ratify the START II Treaty. While the US Senate has already ratified START II, the Russian Duma has delayed consideration of the Treaty until the fall. The Clinton Administration wants START II to enter into force as soon as possible in order to begin negotiations with the Russians on START III, which would further deactivate strategic nuclear delivery vehicles and ICBMs. By waiting to submit the agreements, the Administration is demonstrating to the Russians that it is willing to update the ABM Treaty, but only if they move quickly on START II.

The fate of the two ABM protocols will depend in the first instance on the Russian Duma when it votes on the ratification of START II, possibly in the fall of 1998. After ratification by Russia, the fate of the two protocols will pass to the US Senate, where an intense debate is expected over the future of the ABM Treaty itself and the prospects of NMD. Finally, the ABM protocols must also be ratified by Belarus, Kazakhstan and Ukraine.

IV.      Iraq: The On-Going Monitoring and Verification System

Efforts are underway in several quarters to persuade the Security Council to "close the file" on the aspect of inspections that applies to nuclear weapons. If the Security Council were to agree to such a move, the result would be that the current system, which involves partly active inspections and partly passive monitoring, would be converted to a system involving passive monitoring only. The UN documents refer to the passive monitoring aspect of the system as "on-going monitoring and verification" (OMV). The active inspections are expected to end at some point, but not necessarily coinciding with the end of the sanctions. The OMV system is expected to continue indefinitely until the Security Council decides there is no longer a need for it.

The issue of whether the time has arrived to advance to the OMV-only phase has already been raised in the Security Council (S/PRST/1998/11) and is likely to come to the fore in October when the Council receives its next regular report on the extent of Iraqi compliance with its inspection obligations.

Since little has been published by way of explanation of the OMV system, a few words on the matter would be appropriate. The system is of particular interest to lawyers because it includes a provision for mandatory legislation to be enacted by Iraq.

The OMV concept has its roots in the cease-fire agreement that was concluded by the UN and Iraq at the close of the Gulf War. That agreement was formulated in UN Security Council Resolution 687 (3 April 1991) which, agreed to by Iraq and was ratified by the Iraqi National Assembly on 6 April 1991. It is this resolution/agreement that the UN Security Council has been attempting to enforce against Iraq during the past 7 years.

Among other things, Resolution 687 calls upon Iraq

·         to make full declarations as to its weapons of mass destruction (nuclear, chemical, biological and long-range missiles);

·         to submit to inspections for the purpose of verifying the declarations;

·         to submit to the destruction, removal or rendering harmless of all its weapons of mass destruction;

·         to undertake never to acquire such weapons in the future;

·         to submit to a system of on-going monitoring and verification for the purpose of verifying this undertaking.

Although Resolution 687 introduces the concept of OMV, it contains no details; the parties are left to agree on details at a later date (paragraphs 10, 12, and 13). The Security Council's proposals as to the details of the OMV system were set out in Resolution 715 (11 October 1991). After much hesitation and remonstrance, Iraq finally agreed to Resolution 715 by letter dated 26 November 1993 (UN Document S/26811).

Resolution 715 incorporates by reference two documents, one setting forth details with respect to nuclear weapons and the other dealing with the other types of weapons of mass destruction. The document dealing with nuclear weapons (S/22872 Rev. 1) was prepared by IAEA which is the body responsible for inspecting and monitoring in respect of nuclear weapons. The other document (S/22871 Rev. 1) was prepared by the UN Special Commission on Iraq (UNSCOM) which is the body responsible for inspecting and monitoring in respect of the other prohibited weapons. Each document contains arrangements intended to ensure compliance by Iraq with its undertaking never to acquire the weapons in question.

Some of the more important features of the OMV regime are:

a)      on-site monitoring, including remotely-operated cameras and sensing equipment;

b)      detailed declarations by Iraq covering weapons-sensitive sites and activities, to be used as a baseline for future inspections;

c)      inspections any time any place to verify the completeness of Iraq's lists of declared sites and activities, including unannounced short-notice inspections;

d)      aerial surveillance from UNSCOM's high-altitude aircraft and UNSCOM's helicopters;

e)      a requirement that Iraq enact legislation to ensure compliance with its disarmament obligations under Resolution 687 and the OMV regime.

The term "passive monitoring" has been used to refer to this regime, even though it allows for some obviously active inspections. Indeed, Mohamed ElBaradei, the Director General of IAEA, recently issued a statement entitled "Nuclear Verification in Iraq - Are We Closing the File?" The general tenor of his statement was that IAEA may be close to converting to the OMV-only arrangement, but this will not mean the end of inspections. He explained matters in these words

It simply means shifting gears to ensure not only that the past programme has been neutralized, but also that it is not being revived. In the same vein, a future determination by the Security Council that Iraq has satisfied the requirements for lifting the oil embargo would not bring the monitoring and verification to an end.

In 1996, the UN Security Council added a new feature to the OMV regime - a mechanism for monitoring Iraqi imports of dual-use items such as computers and other items that can be used in civilian applications as well as in the making of weapons. This feature will enter into effect if and when the Security Council decides to relax that part of the sanctions regime that prohibits countries from supplying dual-use commodities to Iraq: Resolution 1051, para. 1; document No. S/1995/1017, para. 3. The mechanism includes the following features

·         detailed reporting requirements on the part of all supplier countries;

·         long detailed lists of dual-use items;

·         obligations on Iraq to cooperate by maintaining records showing its disposal of imported dual-use items.

Resolution 715, along with the two documents incorporated as part of it, entered into force in November 1993. The two documents specified that the OMV system was to begin operating immediately and to operate initially in tandem with the active inspections. The documents also specify that the system is to continue in operation indefinitely until the UN Security Council adopts a resolution to terminate it.

Before the transfer can be made to the OMV-only system, Iraq must complete the portion of the requirements that apply to it for putting the system into operation. Soon after delivering its letter of acceptance, however, Iraq began obstructing the installation of monitoring cameras and other aspects of the system. These problems have been partially alleviated but resistance continues to occur in some areas, notably the provision of full and accurate declarations and the enactment of legislation.

1.Mandatory Legislation

The OMV provisions requiring Iraq to enact legislation are modeled on a provision in the Chemical Weapons Convention (Article VII). The two documents referred to in Resolution 715 contain similar provisions on this point. In the nuclear document, Iraq is required to

prohibit all natural and legal persons under Iraq's jurisdiction or control from undertaking anywhere any activity that is prohibited for Iraq by Resolution 687 or 707 or by the present plan. Iraq shall enact penal legislation to secure enforcement of these prohibitions. (S/22872 Rev. 1, para. 34)

A similar clause appears in the document dealing with the other types of prohibited weapons (S/22871 Rev. 1, para. 20).

Iraq has been reluctant to enact this legislation. Despite UNSCOM's repeated requests over a period of several years and despite repeated promises by Iraq (e.g. S/1995/864, para. 93 and S/1998/312, para. 24), no legislation enacted by the Iraqi National Assembly has been submitted. Possibly some legislation can be expected soon under the nuclear section of the OMV scheme, because Iraq is making special efforts to satisfy the IAEA and the Security Council that the time has come in the nuclear area to make the conversion to OMV-only inspections and monitoring. As of 30 June, however, IAEA officials stated that nothing had been received from Iraq.

Iraq's delays and reluctance in this matter suggest that it is finding the idea of enacting the required legislation to be problematical. There could be a number of explanations for this reluctance, but there is one possible explanation that, if true, would be good news for those attempting to improve compliance regimes for disarmament treaties. The explanation could be that, contrary to what might be expected in an authoritarian regime, Iraq is concerned about the possibility that the legislation might some day be actually enforced against a government official. If there is any validity in this explanation, it could mean that treaty-mandated legislation (à la CWC) in authoritarian countries will be found to be more effective for promoting compliance than might otherwise be thought. If and when the Iraqis eventually submit their legislation, it may be found to contain some clues as to the validity of this explanation.

V.   Book Review

Economic Sanctions: Panacea or Peacebuilding in a Post-cold War World?
David Cortright and George A. Lopez (eds.)
Westview Press, 1995, Boulder, Colorado
231 pp., with index and bibliography review by Britt Elliott

Over the last several years, we have sen a flurry of sanctions activity within the United Nations system. For the first forty-five years of its existence, the UN Security Council imposed sanctions only twice. Since 1990, however, it has imposed sanctions ten times, including three cases of comprehensive economic sanctions against Iraq, former Yugoslavia and Haiti.

Despite all this, there have been surprisingly few attempts to address fundamental questions over the value and purpose of sanctions: Are sanctions effective? Are they humane? More precisely, what are the components of a sanctions regime that is effective, enforceable, and which complies with fundamental humanitarian norms? These questions are addressed head-on in Economic Sanctions: Panacea or Peacebuilding in a Post-Cold War World? edited by disarmament activist David Cortright and Professor George A. Lopez. Bringing together the work of policymakers, political scientists, economists, legal theorists and theologians, the book looks at some of the most pressing questions surrounding the use of sanctions.

The first part of the book includes three essays which examine sanctions from international and national perspectives. Of particular interest is an essay by James Ngobi, secretary of the United Nations Sanctions Committees. Ngobi's essay provides an overview of the UN sanctions program and identifies a number of shortcomings within the existing system. since the Security Council has yet to agree on an effective mechanism for administering the national implementation of sanctions, countries are prone to allow overt sanctions violations simply out of national pride or concern about internal political repercussions, while others engage in deliberate concealment.

Part Two examines some of the problems and controversies surrounding sanctions. An obvious questions arises: Do sanctions work? Kimberly Ann Elliott offers a preliminary framework for evaluating whether or not a particular sanctions program has been effective, and then lays out some factors that affect the success of sanctions. Elliott makes it clear that nowadays sanctions must involve many actors in order to be effective. Ironically, however, Elliott's essay discusses sanctions almost exclusively as a tool of US foreign policy. The author says very little about the effectiveness of UN instruments, which presumably would be the main vehicle for imposing the kinds of sanctions she appears to be advocating.

An essay by Christopher Joyner examines sanctions from the point of view of international law. Like Ngobi, Joyner points to some difficulties of monitoring and enforcing compliance with sanctions. In particular, he draws attention to the system's reliance on states to investigate and report on violations within their own country. Joyner also underscores the need to provide assistance to countries who participate in sanctions but are particularly harmed by the disruption in trade with the sanctioned country. Regrettably, the author gives only scant attention to Article 50 of the UN Charter, which entitles countries suffering from these problems to consult the Security Council for a solution. Some comment on the effectiveness of this instrument would have been useful.

Two exceptional essays look beyond questions of efficacy and examine the morality of sanctions. Jack Patterson of the American Friends Service Committee lays down some basic criteria for a sanctions system that meets basic humanitarian requirements. Drew Christianson and Gerard Powers (both of the US Catholic Conference) borrow some concepts from "just war" theory to provide a moral framework for evaluating sanctions.

Part Three offers case studies of multilateral sanctions in four countries: Iraq, Former Yugoslavis, Haiti and South Africa. Although the results are often depressing, they are also instructive. David Reuter, a US Defense Department official, argues that the sanctions on Iraq have been effective, while Bashir Al-Samarrai counters that sanctions have devastated innocent civilians, but have failed to loosen Saddam Hussein's grip on Iraq. In Haiti, Claudette Antoine Werleigh argues that sanctions were imposed incrementally and half-heartedly, and were not enforced in any serious way until near the end of the crisis in 1994.

One happy exception is found in the case of South Africa. Jennifer Davis of the American Committee on Africa explains how citizens, governments and civil society worked together to help South African groups bring down the apartheid system. This cooperative effort contrasts starkly with the results in Yugoslavia, where it is said that sanctions provoked a backlash among Serbs. The essays by Susan Woodward and Sonja Licht both suggest that economic and political isolation caused Serbian nationalists to rally around Milosevic, and squeezed moderate and dissident voices out of the political debate entirely.

The final section of the book looks at how the current sanctions regime might be strengthened. Lloyd (Jeff) Durnas calls for the establishment of a UN Council on Economic Sanctions and Peacekeeping as an independent monitoring mechanism. Such an instrument would help overcome a current shortcoming of the existing UN sanctions regime, the reliance on states to monitor their own compliance. Cortright and Lopez propose that future policy makes explore the use of humane alternatives, such as "positive sanctions". An example of such an approach is a European Bank for Reconstruction and Development's 1993 "debt for denuclearization" program, which proposed that Ukraine and other former Soviet Republics receive debt forgiveness and other incentives in exchange for a commitment to nuclear nonproliferation.

The contributions to this volume come from a wide range of disciplines, and with few exceptions, they are easily accessible to the non-specialist. The essays often tilt the debate toward American foreign policy, which can constrain the debate at times( of the seventeen contributions to this book, only five are based outside the United States). Some of the authors show a tendency to underrate the effectiveness of sanctions imposed by the UN Security Council. Particularly welcome, however, are the contributions by Ngobi and Durnas, both of which offer some thoughtful suggestions for improving the effectiveness of UN sanctions machinery. Despite its limitations, this collection of essays is a highly welcome addition to the relatively sparse body of literature on sanctions.