Fall 2006 (Volume IV, Issue III)
Promoting new understanding and improvement of Canadian foreign and defence policy.
In this issue:
- Message from the President – Robert S. Millar
- CDFAI New Advisory Council Members
- Congratulations
- Call for Papers
- CDFAI 2006 Annual Conference
- Article: Foreign Policy: Initial Impressions - Derek Burney
- Article: Measuring and Monitoring Governance - David Carment
- Article: Supporting our War Effort - Ray Crabbe
- Article: How can the Canadian Forces (CF) move ahead when they're busy playing catch up? -
Sharon Hobson - Article: Is the 3-D Construct at work in Kandahar or are we kidding ourselves? - Eric Lerhe
- Article: Developing Capabilities for the Canadian Forces - George Macdonald
- Article: Covering the Afghan Mission: A Lament on the Fourth Estate - Scot Robertson
- Article: Lebanon – Why Canada should not participate in the UN Force - Cameron Ross
- About Our Organization
- Subscribe
Message from the President - Robert S. Millar
Welcome to the Fall 2006 issue of “The Dispatch” newsletter. In this edition we welcome Perrin Beatty and David Pratt, former Ministers of National Defence as new Advisory Council Members. We look forward to their contributions on Canadian security, defence and foreign affairs issues.
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Foreign Policy: Initial Impressions – Derek Burney. “….Even more troubling is the apparent unwillingness of our society to support actions intended to sustain the liberty and security we often take for granted.”
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Measuring and Monitoring Governance – David Carment. An overview and some initial findings of the Canada Corps supported research on governance by the Country Indicators for Foreign Policy project (CIFP) at Carleton University.
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Supporting Our War Effort – Ray Crabbe. As the only country on Osama Bin Laden’s hit list to not be directly attacked by Al-Qaeda, is the indirect approach of attacking Canada’s military designed to send a strong message to Canadians?
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How Can the Canadian Forces Move Ahead When They’re Busy Playing Catch Up? – Sharon Hobson. What is missing? “A promise to provide the CF with the money it needs to buy the equipment it should have been buying all along, as well as the money to transform, and the money to win a war.”
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Is the 3-D Construct at Work in Kandahar or Are We Kidding Ourselves? – Eric Lerhe. Although purporting to not provide an assessment, Eric’s analysis is well documented, providing not only observations but also some questions a fuller assessment might consider. Improving the lives of the Afghani, he suggests, requires immediate action.
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Developing Capabilities for the Canadian Forces – George Macdonald. “Everyone’s fixation on the purchase of equipment is not inappropriate, but we must keep in mind that this commitment is only the first step in acquiring a capability…. Having said this, one major and persistent disconnect is the provision of personnel for a capability.”
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Covering the Afghan Mission: A Lament on the Fourth Estate – Scot Robertson. “Canadians deserve better and more substantial coverage and discussion of a mission as important as Afghanistan.” Scot offers several questions that the media might consider tackling in exploring some of the deeper issues.
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Lebanon – Why Canada Should Not Participate in the UN Force – Cam Ross. Not only does Cam point out the reasons why Canada should not participate in UNIFIL-2, he goes on to point out a role that Canada can play.
The rotation from the PPCLI to the Royal Canadian Regiment Battle Group is nearing completion and the worst week of casualties in the Canadian Afghan mission has occurred. A friendly fire incident and enemy engagements were the headlines over the Labour Day weekend. Individuals across the country are talking more about the Canadian Forces and our Foreign Policy than at any time in recent memory. Average Canadians are seeking to better understand the situation. It is time for leadership both at the political level and in the various federal government departments to provide a vision and plan that Canadians can understand and buy into.
CDFAI New Advisory Council Members
The Honourable David Pratt, P.C. is currently serving as Advisor to the Secretary General and Special Ambassador for the Canadian Red Cross. Mr. Pratt’s focus is on issues related to conflict prevention, the control of small arms and light weapons, international humanitarian law, war affected children and security sector reform. For 16 years, Mr. Pratt served as an elected representative at the municipal, regional and federal levels. He was first elected to the House of Commons for Nepean-Carleton in 1997. From December 2003 to July 2004, Mr. Pratt served as Canada’s Minister of National Defence. Prior to his appointment to Cabinet, Mr. Pratt was Chair of the House of Commons Standing Committee on National Defence and Veterans Affairs – a position he held from 2001 to 2003. He also served as a member of the House of Commons Justice Committee’s Sub-Committee on National Security. As Canada’s Special Envoy to Sierra Leone under two ministers of Foreign Affairs, Mr. Pratt was involved extensively in legislation to address the “conflict diamonds” issue.
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Perrin Beatty was first elected to the House of Commons as a Progressive Conservative in 1972. During his 21 years in Parliament, he served as Minister in seven different portfolios, including Treasury Board, National Revenue, Solicitor General, Defence, National Health and Welfare, Communications and External Affairs. Following the 1993 election, he joined a number of corporate boards and worked as a consultant and columnist. In 1995, Prime Minister Chrétien appointed him President and CEO of the Canadian Broadcasting Corporation (CBC). Since leaving the CBC in August, 2005, he has been President and CEO of the Alliance of Manufacturers & Exporters Canada. |
Congratulations
Dr. Denis Stairs, CDFAI Advisory Council Member and Fellow was recently awarded Officer of the Order of Canada
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The Conference of Defence Associations Institute (CDAI) is pleased to announce that Brigadier-General David A. Fraser has been selected as the recipient of the Vimy Award for 2006.
Currently the Commander of the Multi-National Brigade in Kandahar, Afghanistan, BGen. Fraser is a distinguished Canadian who has exhibited the highest standards of leadership The CDAI, which sponsors the Vimy Award, is an Ottawa-based think-tank dedicated to increasing public awareness of Canada’s security situation and the vital role played by the Canadian Armed Forces in our society. |
CDFAI 2006 Graduate Student Symposium
The Conference of Defence Associations Institute (CDAI) and the Canadian Defence & Foreign Affiars Institute (CDFAI) in collaboration with the Institute for Research on Public Policy (IRPP), Queen's University and the War Studies Programme at the Royal Military College of Canada will host the
9th Annual Graduate Student Symposium:
Security and Defence: National and International Issues
Deadline for submissions is September 23, 2006.
Click the following links for more information: English| en Français.
CDFAI 2006 Annual Ottawa Conference
Conference Topic: Foreign Policy Under a Conservative Government: An Interim Report Card
Keynote Speakers: Hon. John Manley and Minister Peter MacKay
Date: Monday, October 30
Location: Crowne Plaza Hotel Ballroom A/B 101 Lyon Street Ottawa, ON
The cost of this year’s conference is $150.00. The fee will include the conference session (five panels), two breaks and lunch. To register, visit the conference website www.peopleware.net/1540 or for more information visit www.cdfai.org.
Measuring and Monitoring Governanceby David Carment Within the scope of this project, governance refers to the traditions and institutions by which authority in a country is exercised for the common good. CIFP’s working definition of governance identifies seven discrete dimensions of the phenomenon: political stability and violence, rule of law and human rights, government efficiency, accountability, economic and market efficiency, democratic participation, and gender and equality. Each dimension captures one particular facet of the broader phenomenon of governance, to be measured and assessed using a number of different structural indicators. Level of Democracy
For example, in the figure above, the relationship between a given state’s level of democracy and its relative stability proves complex. Instead, the relationship resembles the inverted ‘U’ relationship that various writers have observed between conflict – both civil and international – and regime type. Clearly, the full democracies are the most stable of all. At the other end of the scale, full autocracies are also stable but slightly less so. However, states between these two extremes tended to be more fragile. The implication is that, while established democracies and entrenched autocracies tend to be relatively stable, states caught between those two extremes, termed anocracies by some writers, tend to be much more fragile.
Human Rights Intriguingly, a similar relationship exists between human rights indicators and fragility. The graph above, suggests that though states with the best human rights records tend to be the most stable, states with extremely poor rights records tend to be somewhat more stable than those that score nearer the mean. Such insights are in some ways surprising and even troubling, with potential implications for the way in which donor states engage both chronic human rights offenders and states undertaking human rights reform. As developing states work to encourage better respect for human rights within their borders, donors and partners alike must work carefully to minimize the risk of a potentially catastrophic destabilization of the state.
Gender Empowerment Other findings prove intriguing as well. In particular, the fact that strong performance on gender measurements correlates closely with stability may come as a surprise to some, even as it serves as vindication to others. The scatter plot above, plotting UNDP’s Gender Empowerment scores against the CIFP fragility index, suggests a strong correlation between gender and country stability. The possibility that gender parity may indeed play a strong and measurable role in the stability of the state beyond that of general development is a potentially powerful result, one that at a minimum warrants further quantitative investigation.
GDP/Capita
Finally, a number of authors have found that GDP per capita correlates strongly with both stability and peace. Interestingly, the graph above shows a non-linear relationship between poverty and fragility. The greatest returns to increasing mean income levels occur among relatively poor states; as per capita GDP increases further, the returns to stability appear to diminish. For more information about the project please and research on failed and fragile states visit CIFP’s website at www.carleton.ca/cifp or contact [email protected]. |
Is the 3-D Construct at work in Kandahar or are we kidding ourselves?by Eric Lerhe The increasing casualties resulting from our military commitment to Afghanistan are provoking many to call for reorienting our mission or even abandoning it. In addition, public support is declining with a majority now opposing sending Canadian troops to Afghanistan.1 Given that this mission is supported by two unanimous United Nations Security Resolutions and was agreed to in consultation with every one of our twenty-five allies in NATO, all of which are also in Afghanistan, drastic mission changes may not be merited just yet.2 On the other hand, the increasing costs in both blood and treasure suggest that the way we are conducting that mission is probably due for a mid-course assessment. This brief paper will not purport to provide that assessment. The federal government should do that review as they have both the responsibility and the resources. This paper will argue, however, that a detailed review should concentrate on the “Defence, Diplomacy, and Development” or “3-D” construct that provides the strategic guidance to our mission to Kandahar and the Provincial Reconstruction Team (PRT) charged with implementing it.3 It will also offer some general findings and several questions that a full review might consider. In brief, the paper argues that while the “3-D” is our declared national strategy; it is not being adequately supported by the development part of that partnership. Further, the success of our military operations may well rest on a development programme that produces positive local results quickly, and this is not happening. Finally, this paper suggests that if CIDA is not able to provide this capacity, our military should do so. The theory behind “3-D” suggests that a skilful combination of Canadian defence, development and diplomatic efforts can return stability to failed states and prevent them from becoming a breeding ground for terrorists.4 As a first step, any full-blown assessment must review that theory. In so doing, one probably has to accept that the concept has a strong internal logic. Why would one not expect better results if all Canada’s diplomatic, development, and defence efforts were tightly coordinated? Second, the logic parallels the efforts by our allies to coordinate these entities as seen in the United States Marine Corp’s vision of a “Three Block War” or the United Kingdom’s Conflict Prevention Pools.5 Finally, no one would suggest that crises of the sort found in Afghanistan will be solved by the simple application of military force. At the most basic level, local support for the Canadian security operations will be directly affected by how much the lives of Kandahari are improved or not by the total Canadian effort. Those with long experience in Afghanistan argue that local support may well turn to opposition if personal safety, health, and economic prospects decline instead of improving.6 A recent Center for International Governance Innovation (CIGI) report - “Canada in Haiti: Considering the 3-Approach” - reinforces that view arguing ”that poverty reduction is a fundamental component of any peace building initiative.”7 Offsetting those arguments are several that suggest some elements of the theory are not that sound at all. First, it is not at all clear that terror issues primarily from failed states. Saudi Arabia provided most of the 9/11 bombers, and it is by no means a “failed state.” It is equally hard to argue that the Afghanistan state that sponsored Al Qaeda qualified either. By most measures it was significantly more united, law abiding, and peaceful under the effective but allegedly unpopular Taliban than was the case before or after. This suggests that any counter-terrorist plan that relies exclusively on assisting failed states will be seriously incomplete. On the other hand, raising the ability of failed states to effectively govern themselves appears likely to reduce the threat posed by non-state terrorists, but this has not been proven in actual events. A more immediate theoretical problem arises within the “Development” component of the 3-D concept Many key members of this community in Canada simply do not accept significant elements of that vision. CARE Canada President John Watson describes “3-D” as part of a pernicious “groupthink that is leading us towards disaster.”8 He also argues “it is a canard that military deployments are necessary to provide security for humanitarian workers to operate.” OXFAM Canada rejects coordinating activities with the military and claims that the military and development components in Afghanistan “must remain separate to avoid any perception on the part of the local population that humanitarian workers are part of the war effort.”9 In support of this view, John Watson argues “government officials” and “military officials” delivering aid are “not aid workers” but “officials of a foreign occupying power.”10 The broad Non-governmental Humanitarian Agency (NGHA) and Non-Governmental Organization (NGO) thrust is that there is little cause to alter their longstanding commitment to the “impartial, neutral and independent” delivery of aid.11 In the view of the NGHA those principles offer better protection than that provided by closely coordinating their work with the military.12 Further, they argue that their assistance has a longer-range focus, more community “buy-in”, and greater overall effectiveness than direct government assistance efforts.13 No evidence supports these claims. However, one must acknowledge the NGHA community frequently offers a deep experience in the local environment that few government agencies can match. This is certainly the case in Afghanistan. There is only slightly more evidence for those arguing the opposing view that development should be coordinated with defence and development. While the just-cited CIGI report on “3-D” in Haiti argued for close coordination, the report itself acknowledges that the overall tone amongst its participants was “deeply pessimistic” and that the six recent UN missions there have failed to have “any lasting effect in terms of stabilizing Haiti’s turbulent political situation.”14 After three years in Iraq and four in Afghanistan, it is also clear that most Western security and development efforts there, whether performed in a coordinated fashion or not, have not brought greater stability.15 A 2005 Canadian conference assessing the 3-D concept in Afghanistan assessed that the only successful 3-D application occurred within the United Kingdom’s Provincial Reconstruction Team in Northern Afghanistan - the Canadian PRT had not yet been established.16 The evidence, and it is anecdotal, suggests that the UK model, which involved a fully coordinated “command group” composed of military, political, police, and development officials, extended the rule of law and eroded opposition force legitimacy. There are other successful operations although they do not completely follow the 3-D model. In Zabul province, adjacent to Kandahar in the southwest of Afghanistan, a U.S. PRT dominated by the U.S. military has achieved “remarkable” progress in stabilizing an area once dominated by the Taliban according to Graeme Smith of The Globe and Mail.17 In Zabul, the U.S. formula is based on the logic that “if you promise, you should do it” with the emphasis being placed on project delivery following as rapidly as possible after the initial discussion of the project with the Afghan villagers.18 Rapid action resulted primarily from their military commanders having the personal authority to spend some $30 million on development projects and some $22 million has already been disbursed.19 Local project agreement and final approval of work and funding rarely took longer than two weeks for the largest of their projects. Today, eleven months since its start-up, an assessment of how the Canadian PRT is performing is due. While acknowledging the mixed results enjoyed by the 3-D approach elsewhere, the short time the Canadian PRT has been operating, and the more dangerous security environment found in Kandahar, the hard data suggests the implementation of the 3-D concept there is largely fiction. There is no doubting the presence of the 2,300 members of Canadian defence component, 140 of which are in the PRT.20 However, the diplomatic component appears to be represented by three people, while CIDA temporary withdrew its single representative in April 2006 as a result of the Taliban attacks.21 Since his return, he has frequently been unable to venture beyond the PRT offices.22 In addition, OXFAM Canada will not station its workers anywhere near friendly military forces in Afghanistan. CARE Canada does not cooperate on aid projects with the Canadian Forces in Kandahar and argued before Parliament that its activities elsewhere in Afghanistan were better able to deliver aid than the competing Canadian Provincial Reconstruction Team.23 Inquiries to DND and CIDA were unable to identify any other Canadian NGHA coordinating its development services with the Kandahar PRT. Beyond the military, the most active Canadian PRT component regularly working with the Afghani is an RCMP six-man team engaged in training the Afghani police. Despite the lack of support from the rest of the development community, CIDA endorses the “whole of government” approach and states that it “fully supports” the deployment of the Canadian Kandahar PRT.24 As a way of underlining their commitment, their website site announces that Afghanistan is the “single largest recipient of bilateral aid” with some $1 billion being pledged from 2001-2009. However, most of this funding flows to national programmes largely directed by the Afghan national government and disbursed over the entire country. Only some $ 5 million per year is ultimately spent in Kandahar and such spending is not linked with the Canadian PRT.25 In fact, during the Canadian PRT’s first eleven months, CIDA only allocated some $4 million directly to PRT activities in Kandahar. Regrettably, little to nothing of this has actually been spent.26 Given that DND has spent in excess of $616 million on the first nine months of its Kandahar commitment, the overall CIDA contribution seems small indeed.24 The Senate Committee on National Security and Defence has noticed this discrepancy, but the Committee’s Chairperson reported that CIDA had “refused” to provide their Afghanistan budget details.28 This month, John Geddes suggested CIDA was now “feeling the heat” of such public questioning and that this may have spurred the agency to take steps to more obviously support the PRT.29 There are other problems beyond this small level of CIDA funding and its late arrival. Graeme Smith contrasts the rapid allocation of funds to locally approved projects in the U.S. PRT with the more ponderous bureaucratic process followed by CIDA and the U.K.’s Department of International Development. It seems even if the PRT and the local villages agree on a project, the approval must follow a delay-inducing trail up the CIDA decision chain. A USAID assessment of PRT activities in Afghanistan also remarked on the delays involved in CIDA establishing its “project funding and management process” in Kandahar.30 That assessment included concerns by some Canadian PRT members that the Afghans would interpret these delays as a lack of “equal commitment” to Afghanistan compared with the prior generosity of the U.S. effort and that would increase instability. On occasion, the situation was even worse than that. Garth Pritchard, an embedded journalist who spent four months in Kandahar, reported that CIDA promised $100,000 for water wells and schools contracted by the Canadian military in 2005 and then reneged once they were completed.31 The delays prompted the U.S. Military and the Canadian Department of National Defence to ultimately pay the local contractors. Certainly there are immense security problems in Kandahar. The January 2006 killing of the PRT’s political director, Glyn Berry, highlighted the risk to civilian workers and likely provoked the initial withdrawal of the CIDA representative and the temporary suspension of their activities.32 Yet when the representative was in place, the evidence suggests the small amounts of CIDA money he brought were offset by the bureaucratic delays CIDA introduced.33 Very recently CIDA started taking action in response to these criticisms. Projects are being increased, older ones are being accelerated, the single CIDA advisor at the PRT will be joined by two more, and they have partially addressed some of the cumbersome bureaucratic processes at the PRT.34 While acknowledging the dire security situation, one still has to ask how it took eleven months to achieve these very small improvements. Further, one also has to suspect that at the end of the day these improvements will not provide the Canadian PRT in Kandahar either the funding or the rapid approval process enjoyed by the US PRT in Zabul.35 It must also be acknowledged that however positive that US PRT may appear to the Globe and Mail, other observers have pointed out significant problems with the US model. Mismanagement, “marginal success” in development tasks, and duplication are cited.36 Yet the relative stability enjoyed by the Zabul province and the credit that is being given to its PRT for this suggests some aspects of that model bear closer examination. Indeed every PRT model must be examined for its ability to provide stability as well as development. This leads to some tentative observations a fuller assessment should review:
This could well involve the military taking the lead for development under such conditions. Further, some key members of the development community share this view. Meinrad Studer of the International Committee of the Red Cross (ICRC) international organizations division begins by arguing that the ICRC should “declare its willingness to cooperate with the military and other humanitarian agencies.”37 He then concludes with: When it is a matter of saving lives, a pragmatic approach must be taken. It is not inconceivable that in certain situations the military may be in a better position than the ICRC to carry out certain humanitarian tasks. As has been shown, that viewpoint is not shared by much of the Canadian NHGA community. This leads to some questions that a fuller assessment might consider:
Regrettably, there is no guarantee that a more complete assessment of the Canadian 3-D approach will follow this effort. Even if it does, a detailed review will take time. Meanwhile, Canadian lives are being lost in Afghanistan. Further, the evidence is increasingly demonstrating that any development measure that improves the lives of the Afghani will result in greater support to coalition forces. This suggests that immediate action is required in advance of any such fuller study. Until that review is complete and until CIDA can generate the personnel and financial resources to re-qualify for membership in the 3-D partnership, the concept should be put into abeyance. In the interim, the military commander should be immediately given the $30 million his U.S counterparts enjoy for local development projects and, most critically, the local authority to spend it rapidly. He should be provided whatever federal officials or military officers are needed to ensure funding and project delivery follows within two weeks of a local agreement. As quickly as the security situation allows and as quickly as CIDA can generate a meaningful contribution, the military commander should return the coordination of development over to the development experts.
1 The precise question was “Do you support or oppose sending Canadian troops to Afghanistan?” with some 55% choosing to oppose sending troops. See Jeff Sallot, “Opposition to Afghan mission rises in latest poll.” Globe and Mail, 6 Aug. 2006, p 4. In Jun 2006, a CDFAI poll asked the same question and had 59% supporting the sending of Canadian troops. See CDFAI Media Poll for the Ottawa Citizen, Jun 2006, (Toronto: Innovative Research Group, Inc., 2006). |
About Our Organization
Institute Profile
CDFAI is a research institute pursuing authoritative research and new ideas aimed at ensuring Canada has a respected and influential voice in the international arena.
Background
CDFAI is a charitable organization, founded in 2001 and based in Calgary. CDFAI develops and disseminates materials and carries out activities to promote understanding by the Canadian public of national defence and foreign affairs issues. CDFAI is developing a body of knowledge which can be used for Canadian policy development, media analysis and educational support. The Fellows program, a group of highly experienced and talented individuals, support CDFAI by authoring research papers, responding to media queries, running conferences, initiating polling, and developing outreach and education projects.
Mission Statement
To be a catalyst for innovative Canadian global engagement.
Goal/Aim
CDFAI was created to address the ongoing discrepancy between what Canadians need to know about Canadian foreign and defence policy and what they do know. Historically, Canadians tend to think of foreign policy – if they think of it at all – as a matter of trade and markets. They are unaware of the importance of Canada engaging diplomatically, militarily, and with international aid in the ongoing struggle to maintain a world that is friendly to the free flow of people and ideas across borders and the spread of human rights. They are largely unaware of the connection between a prosperous and free Canada and a world of globalization and liberal internationalism. CDFAI is dedicated to educating Canadians, and particularly those who play leadership roles in shaping Canadian international policy, to the importance of Canada playing an active and ongoing role in world affairs, with tangible diplomatic, military and aid assets.
CDFAI Projects
Minor Research Papers – four papers are released each year on current, relevant themes related to defence, diplomacy and international development.
Major Research Paper – one or two major papers are released each year providing a detailed, critical examination on current issues or analyzing existing policy.
Quarterly Newsletters – educate Canadians on timely topics related to Canada’s role on the international stage.
Monthly Columns – a monthly column written by J.L. Granatstein that raises the level of public debate on defence and foreign affairs issues.
Speakers’ Series – corporate and other leaders are invited to expand their knowledge of international relations through the experience and expertise shared by knowledgeable speakers.
Editorial Board – a group of highly respected academics ensure authoritative public policy integrity in all of CDFAI’s formal publications.
Annual Ottawa Conference – a joint project with Carleton, Laval, Queen’s University, UQAM, and the Woodrow Wilson Center for Scholars is held annually to address a topical issue.
National Polls – public opinion polls are commissioned to demonstrate Canadian current thinking on significant international issues.
Military Journalism Courses – annually, two eleven-day military/media courses (French and English) are run where upwards of 24 Canadian journalism students learn about dealing with the Canadian Forces.
Ross Munro Media Award – annually, CDFAI and CDA recognize one Canadian journalist who has made a significant contribution to the public understanding of defence and security issues.
Issue Responses – as required, CDFAI will respond to breaking news items with a reasoned, well articulated perspective to assist the public in understanding the issue.
Outcomes
Each of CDFAI’s projects is developed to bring attention to pressing Canadian international engagement issues. These projects not only analyze the issues but also offer solutions. By publishing the results of these research projects, CDFAI gives policymakers the means to carry out policy formulation and administration in a more informed manner. Interested Canadians will be more knowledgeable. The ultimate aim is to strengthen Canada’s international role in the world, thereby supporting a reasonable standard of living for current and future Canadians and those living around the globe.
Funding
CDFAI’s annual budget currently runs at approximately $800,000. Corporate, individual philanthropic, government contracts and foundation support are needed to carry on this important work.
Subscribe
If you would like to be included on our regular mailing regarding conferences, lectures and newsletters, please send your particulars to [email protected] or sign up for our mailing list at www.cdfai.org. All email addresses gathered by CDFAI are kept confidential as we do not release or sell any information collected from the public to any third party without explicit permission to do so.
CDFAI also adheres to a strict no-SPAM policy and as such, does not forward emails containing information provided by third parties and/or organizations and businesses with which it has no official interest, relevancy and/or affiliation.
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