The 2022 CHMR-AP: Revolutionising Civilian Harm Mitigation Strategy?

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Over 380 000 civilians have been killed as a direct result of U.S. Department of Defence (DoD) operations in Afghanistan, Pakistan, Iraq, Syria, and Yemen according to a 2021 study on the Human Cost of Post-9/11 Wars by Brown University.[1] Pressure has been mounting for the past twenty-years for the DoD to reduce its civilian casualty rates in conflicts. In 2017, when the New York Times Magazine published the results of a months-long investigation on underreporting of civilian casualties from airstrikes, demands from civil society for DoD transparency and reporting mechanisms grew.

The Civilian Harm Mitigation and Response Action Plan (CHMR-AP) is a preceding document to a DoD Instruction on Minimising and Responding to Civilian Harm in Military Operations (the DoDI). The creation of the DoDI was mandated by the National Defence Authorisation Act for Fiscal Year 2020 (NDAA), and passed by the US Congress.[2] According to Todd Huntley, the Director of the National Security Law Programme at Georgetown, the first draft of the DoDI had been developed almost exclusively within the defence community but in August 2021, when the DoDI was making its way through rounds of approval, a US drone strike killed 7 children in Kabul.[3] After public outcry about the incident, the Secretary of Defence (SecDef) Lloyd Austin issued a directive stating that the DoD would have 90-days to develop a Civilian Harm Mitigation and Response Action Plan and a further 90-days to release the Department of Defence Instructions (DoDI).

The CHMR-AP was released on 25 August 2022 after years of development, to prevent and report on civilian casualties. The CHMR-AP is a culmination of research and recommendations from civilian harm monitoring bodies and NGOs (under the collective InterAction), defence research think tanks like RAND, international organisations like the UN and the ICRC, and military and humanitarian advisors.[4] Though the CHMR-AP is just a plan, institutionalisation through the DoDI will send shockwaves through the defence community, both in the U.S. and abroad. So, what are the objectives of the CHMR-AP and why was it created, what can we expect from the DoDI, and what are the implications for international security?

The 11 Objectives of the CHMR-AP: Why and What

In the introduction of the CHMR-AP, Austin writes that, “[p]rotecting civilians from harm in connection with military operations is not only a moral imperative, it is also critical to achieving long-term success on the battlefield.”[5] Although framed as increasing chances of strategic success, the DoD cannot deny that the CHMR-AP is in response to negative public opinion towards combat operations as well as greater exposure of the civilian harm. As the DoD explains, the CHMR-AP is tailored to consider the “failures” of past operations and build off the successes of past DoD policy on protecting civilian life. The objectives are undeniably idealistic, the DoD argues they work, “…across a full spectrum of conflict,” and “…creates institutional architecture,” in preventing civilian harm.[6]

Objectives 1, and 2 focus on creating an institutional framework for the implementation of civilian harm mitigation (CHM) strategy. Complimentary to the CHMR-AP, the DoD has created the Civilian Protection Centre of Excellence (CP CoE) with dual functions: logistical work in reporting and data collection and groundwork in operation advising.[7] From this Centre, sub-bodies are created: the Civilian Environment Teams which advise on civilian protection before operations, the Civilian Harm Assessment Cells, which evaluate CHM efforts after operations, and the Civilian Harm Mitigation and Response Officers and Working Groups which ensure that the objectives are properly absorbed into command.[8]

Objectives 3, 4, and 5 focus on integrating CHM strategy before operations, as the CHMR-AP is primarily a preventative strategy for operations moving forward.

Objectives  6, and 7 focus on collecting civilian harm and casualty data and the subsequent reporting mechanisms. The emphasis is on a standardised approach, which seems to be the DoD’s reasoning for past “miscalculations” of civilian casualty.

Objective 8 regards public response to civilian harm, ranging from coordination with local authorities to condolence measures.

Objectives 9 and 10, interestingly, focus on allied approaches to CHM and incorporating CHM strategy across multinational operations.

Objective 11 authorises the implementation of the CHMR-AP through Department of Defence Instruction.

Objective 1. Establish the Civilian Harm Mitigation and Response Steering Committee.

As with any government initiative, the first task is establishing the bureaucratic framework. The Civilian Harm Mitigation and Response Steering Committee (CHMR-SC, or “Steering Committee”) is the leadership charged with the integration and fulfilment of the CHMR-AP. Interestingly, the DoD posits that the Steering Committee, “…requires…senior-level emphasis and engagement,” both for effective implementation and sustainability of CHM practices.[9] Further responsibilities of the Steering Committee includes:

  • ensuring that the CHMR-AP is compliant with existing law and policy on civilian harm, DoD transparency, and military accountability;
  • imitating necessary changes and first steps to incorporate the CHMR-AP;
  • fulfilling the Secretary of Defence’s (SecDef) intent for the CHMR-AP.

Unfortunately, further details on how exactly the Steering Committee will achieve these goals, nor on how (un)limited their power will be, are not provided. What is clear is that the leadership will be very high-level; the Under-Secretary for Defence Policy (USD(P)), the Under-Secretary for Defence Comptroller (USD(C)), and the Vice Chairman of the Joint Chiefs of Staff (VCJCS) are the co-chairs of the Steering Committee. This is not just a natural extension of defence leadership patterns, rather, it’s a conscience choice to put civilian protection in the agenda, at the highest level of defence and governance. The goal, in a way, is to change the mentality on civilian harm starting with the highest level of the Defence Community, while also pushing the message that high-level officials are involved in CHM. This is something executives have been accused of ignoring in past years. At the same time, cynics might say that the high-level nature of the Steering Committee is to avoid allegations of executive choices to commit civilian killings, the CHMR-AP seems to outline some level of executive responsibility for CHM.

Objective 2. Establish a Civilian Protection Centre of Excellence

The Civilian Protection Centre of Excellence (CP CoE) is tasked with, “…guid[ing] DoD’s understanding of the capabilities and practices that support civilian harm mitigation and response,” at both an operational and a research level.[10] The CHMR-AP identifies three functions of the CP CoE:

  1. Direct Support to Operational Commands: in this function, the CP CoE will develop CHM strategies in different Command policies and help the testing and integration of these strategies tailored to Command capabilities and focuses. Another aspect of this direct support is a standby personnel team available for advising.
  2. Support Policy, Doctrine, and Force Development: in this function, the CP CoE will expand on the DoDI and create policies and regulations that can achieve CHM and create curriculum on CHM strategy for military schools and training programmes, including CHM strategy in future conflict analysis.
  3. Research and Analysis: representing the research level, the CP CoE in this function will work on researching and analysing the effects of the implemented CHM strategy, and its future. This aspect of the CP CoE collects and reports data on civilian harm and casualty.

Objective 3. Incorporate CHMR into the Existing DoD Operational Environment

This objective narrows the incorporation of CHMR policy to awareness on the “civilian environment” at all operational levels of the DoD.[11] While little of this objective is defined, the “civilian environment” is basically an understanding of the civilian impact on the target environment. This might include data on the civilian population in the targeted area, information on civilian infrastructure in the area, and even so far as determining how the civilian population may react or be involved in an operation.

Furthermore, this objective posits that operational planning should include a civilian environment assessment and risk assessment, including CHM objectives within the mission objectives, as well as foresight on the ways the operations may impact the civilian environment, and lastly, practices on restoring the civilian environment after operations.[12]

The need for civilian environment planning in DoD operations stems from issues in the current DoD method in “civilian environmental scanning.” Firstly, there has been concern that civilian environmental scanning is almost absent in operations on the ground, and secondly, that an assessment on the civilian population is conducted after operations, with inadequate data. The goal, then, is to be mindful of the civilian population and civilian life before and during operations. The successful incorporation of civilian environmental scanning into operational planning and strategy places civilian life as a top priority of operations, an aspect which has been severely lacking in past years.

Objective 4. Improve Knowledge of CHM Strategy in the Joint-Targeting Process

Objective 4 is specific to the joint-targeting process – which is the identifying of targets and matching appropriate operations and responses to targets. This objective intends to include civilian consideration in the joint-targeting process which currently places a higher emphasis on adversary identification than on the civilian environment.[13] While Objective 3 and 4 are quite similar, Objective 4 takes a more preventative approach to civilian harm. Through this objective, Combat Commands (COCOMs) will have to consider the civilian environment when determining appropriate responses and operations during the joint-targeting process itself. Part of this Objective is the creation of Civilian Environment Teams which will conduct analysis and advise in the Joint-Targeting Process itself.

A notable aspect of this Objective, found in the Phase 1 and beyond actions is the involvement of COCOM intelligence.[14] The follow-up actions describe increased intelligence efforts and communication to COCOMS on the civilian environment that will then inform the joint-targeting process. In this way, we see the CHMR-AP and the forthcoming DoDI is not just a reformative process of DoD Operations but of the intelligence community as well. Heightened communication between COCOMS and intelligence operations has been a key demand by civil society and policy-makers, who feel that such communication will prevent misidentification, disproportional operations, and minimise civilian harm and casualty.

Objective 5. Develop Processes to Mitigate Bias and Target Misidentification

Objective 5 is perhaps the most controversial of the CHMR-AP, from both external and internal critics. The DoD intends to mitigate bias and target misidentification through the creation of Red Teams, which are essentially groups or individuals that counter aspects of operations. Marc Garlasco, an official advisor to the Pentagon on civilian harm mitigation, defines such Red Teams as, “…groups brought together to challenge assumptions, fight against biases, and adopt an adversarial approach to stress test a system.”[15] In an interview on the CHMR-AP, Garlasco framed the need of Red Teams, when discussing the drone strike incident in Kabul: arguing that a Red Team would have challenged the COCOMs misidentification of a terrorist cell based on the movement of objects out of a trunk of the car.[16] Red Teams, for example, would have challenged the assumption – or as the DoD defines it, bias – that objects moving from car to house were weapons and bombs.[17]

Red Teams, then, can mitigate civilian harm and risk by challenging assumptions often made by COCOMS or the DoD that any unusual behaviour is a security threat. RAND’s J7 report found that misidentification was the primary cause of civilian harm and casualty.[18] The DoD posits that combatting this primary cause will then reduce the number of civilian casualties due to DoD operations. The objective in this sense is a huge step forward in terms of changing mentality and protecting civilian life. However, Objective 4 is contested.

For those inside the defence community, there are concerns that Red Teams will prevent the effective work of COCOMS and on-the-ground operatives who will now have concerns and doubt surrounding their ‘in-the-moment’ decision making. For civil society, there are accusations that Red Teams are just for show and will not be taken seriously, as the Red Teams are given very little power in changing mission objectives or strategy.

The effectiveness of Red Teams will be left to how the DoDI expands on the rights, duties, and obligations of the groups and incorporates their work into official DoD policy.

Objective 6. Develop Standardised Civilian Harm and Casualty Data and Reporting

Objective 6 is seemingly obvious, yet, the lack of standardisation on civilian harm and casualty data and reporting is one of the most criticised aspect of Pentagon operations. It was actually one of the most fundamental demands of the NDAA for Fiscal Year 2020 from Congress.[19] The data and reporting on civilian harm as well as measuring the number of civilian casualties is either non-existent or involves different sets of practices altogether. This means that among various COCOMS, operations, and monitoring bodies, notional practices have led to inconsistent or absent data, resulting in misreporting on civilian harm. The CHMR-AP signals the end of these inconsistencies and a new era of uniform civilian harm and casualty data, and reporting with a centralised data bank. Even more incredible is the fact that civilians themselves and monitoring bodies will be able to submit data and accounts on the civilian harm and casualty figures resulting from Pentagon operations.[20]

The implications for Objective 6 go beyond proper data but increased Pentagon transparency and even avenues for Pentagon accountability for operations that result in high numbers of civilian harm and casualty. The involvement of the public also means that the Pentagon is not just responsible for holding itself accountable – which in the past has been unreliable – but allows for the Pentagon to be subjected to and held accountable, not only by the general public but victims of their operations.

Objective 7. Create and Improve DoD Procedure for CivCal Investigations

As Garlasco puts it, “[t]his is the big one.”[21] Previous to the CHMR-AP, the Centre for Civilians in Conflict (CIVIC), a branch of Columbia Law School, published a report on the failures of Pentagon investigations into civilian casualty incidents. The Pentagon investigations do not seem objective and are opened with a bias, aiming to justify or excuse civilian casualties. They rarely interview civilians or outside bodies on the incidents.[22] Past investigations stray from recommendations from organisations like CIVIC and even the United Nations.

The CHMR-AP introduces the creation of, “…a new DoD-wide civilian harm assessment framework…” that incorporates the recommendations from CHM organisations and advisors and corrects the mistakes of past Pentagon investigations.[23] Part of this new assessment framework requires COCOM to conduct civilian harm investigations in a standardised way that is overseen by Pentagon officials with collaboration from CHM organisations.

New Civilian Harm Assessment and Investigation Coordinators for each COCOM is also envisioned in the CHMR-AP, however, these CHMR-AP only give a “why” behind the creation of these coordinators rather than the “how.” Specifics on what reforms will take place in the investigative processes is also lacking.

Objective 7 also brings up questions on war crime accountability for the US government. Investigative reforms do very little if the result of Pentagon investigations remain the same. In this new top-down approach that is repeated throughout the CHMR-AP, there is the possibility to go beyond direct personal accountability and hold top Pentagon officials accountable.

Objective 8. Reform DoD Procedure on CivCal Public Response

Objective 8 regards Pentagon procedures after civilian harm and casualty. This objective is simply an undertaking by the Pentagon, in acknowledging incidents of civilian harm and casualty, and responding to them in other ways, aside from financial compensation to victims and their families.

These new practices for civilian harm response build off previous establishments of civilian environment assessments, meaning that responses and possible compensation should be based on the specifics of the civilian harm and casualty and, should address the concerns of the broader community. For example, if an operation resulted in a strike on a factory, then the reformed methods of response would include financial compensation to the loved ones of the deceased and compensation to the community for the loss of a factory that provided jobs and products.

While this raises the bar for duty of care that the Pentagon must take in the field, it directly applies to communities affected by operations. Objective 8 is interesting in the way it broadens the definition of ‘civilian harm’. Following the example above, civilian harm is not just the casualties and physical injuries, but the economic consequences that the civilian population bear. This includes the psychological harm, and the effect of civilian loss to the community, beyond the immediate family.

Objective 9. Incorporate CHMR as part of Security Cooperation Programmes and Ally Efforts

The Pentagon identifies an issue in the inconsistent understanding and implementation of CHM across different allies, even going so far as to say,

“…civilian harm caused by U.S partners undermined U.S strategic success and can prolong conflict and damage the reputation of the United States.”[24]

Even more surprising is the framing of CHM strategy as something to be achieved through arms transfer and improving offensive capabilities for allies and partners. However, the Pentagon emphasises that the implementation of CHM good practices for Allies to receive this assistance or partnership.[25]

Objective 9 of the CHMR-AP then extends past obligations within internal Pentagon policy. This objective places CHM as a consideration in U.S foreign policy and in the U.S international agenda. This objective also gives the Pentagon the role of norm and standard setting on CHM integration into operational strategy for the international community.

This objective is ambitious and contentious. The United States government is not well-known for best-practice standard setting in conflict nor is there guarantee that the U.S government will be willing to create conditional relationships with allies and partners based solely on CHM.

Objective 10. Establish CHMR as a Necessary Element of Multinational Operations

Complimentary to Objective 9, Objective 10 incorporates previously established CHM strategy and procedure into multinational and international operations. This objective opens channels for heightened information sharing between the Pentagon and allies, including both governments and non-state actors. In addition, to implement CHM strategy in multinational operations led by the U.S, and consider the CHM capabilities of allied before operations.

Within the next year, the CHMR-AP states that Pentagon’s policy on multinational operations will be amended to include the importance of CHM – but within the appendix.[26] The wording of this objective has gained some attention, as Objective 9, at face-value, seems to ensure CHM is mandated in all multinational operations but the strategic working of the document suggests that CHM will only be a strong consideration, rather than an enforced doctrine. Nevertheless, if implemented, this objective will reconcile different national practices to better avoid civilian harm and casualty worldwide.

Objective 11. Create CHMR Positions at all Levels of the DoD

Objective 11 puts the CHMR-AP into reality by creating positions dedicated to CHM throughout Pentagon command structure. The staff is made up of more than 150 employees, with most people being assigned to the different COCOMS as well as the headquarters.[27] Small numbers of the staff will also be assigned to the different Defence departments, such as the Army, Air Force, and Navy.[28]

The CHMR-AP is highly ambitious. As much as proponents of the CHMR-AP would like, a thorough, multi-level reform of the Pentagon to mitigate civilian harm and casualty to be wrapped neatly in a 50-page document is nearly impossible.

Main Expectations from the DoDI

While the CHMR-AP is meticulous in what it wants to achieve, there are gaps in how the Pentagon will fully realise these objectives. It now falls onto the highly anticipated DoDI to fill these gaps, although 90 days to create an expanded policy is quite limited and observers are hesitant to expect too much. Regardless of these challenges, there are five main areas we can expect from the DoDI:

    1. Creating the Civilian Protection Centre of Excellence as an Organ within the Department of Defence

    The CHMR-AP explains what the CP CoE can do but very little else. To become a functional organ of the Pentagon, logistical and bureaucratic elements of the CP CoE must be determined. Regarding the CP CoE, it can be expected for the DoDI to include:

    • Establishment of an office and headquarters. It can be assumed that the main headquarters will be in the Pentagon with offices in COCOM locations but the DoDI will need to confirm this.
    • Staffing. Objective 11 of the CHMR-AP identifies 30 positions for CP CoE staff but there is no information on the types of positions within this number nor on the distribution of the CP CoE staff across COCOMS. The CHM staff designated to COCOMS do not reference the CP CoE but following Objective 2, CP CoE staff will be across COCOMS.
    • Funding. Admittedly, there is little mention of funding throughout the CHMR-AP but an organ with such an ambitious mandate will need an adequate funding stream.

    2. Explaining New Considerations in Civilian Environment Assessments

    The CHMR-AP pushes forward the Pentagon’s belief that new forms of civilian environment assessments – incorporated as a priority at various operational levels – are an effective measure in mitigating civilian harm. The CHMR-AP does not provide the criterion in what is considered in the new civilian environmental assessments or how these criteria specifically mitigate harm. The Pentagon has clearly placed a great deal of faith in the civilian environmental assessments to guide action but with no understanding of how these assessments differ from the failed assessments of the past, the wider public is unable to do the same.

    3. Expanding on How Red Teams will be Incorporated into Operation Development

    The CHMR-AP explains that Red Teams are incorporated in two ways: education and training programmes for future decision-makers and ‘advisors’ in the joint-targeting and mission development process. Objective 11 creates two Red Team staff to nearly every COCOM. But there are remaining questions:

    • Where do Red Team staff fall in COCOM hierarchy?
    • How independent will Red Teams be? Will these staff be from outside organisations or members of the defence community?
    • How will Red Teams be incorporated into covert or highly classified operations?
    • How will Red Teams play a role in training and education – past war game activities?
    • What level of influence will Red Teams have in possible revising of joint-targeting or missions?

    For the general public and CHM accountability bodies to take the Pentagon’s inclusion of Red Teams seriously, the DoDI will have to give thorough answers to these questions.

    4. Define the New Levels and Considerations on Accountability – Both in the Legal Framework and to the Public

    As previously mentioned, the CHMR-AP, surprisingly, walks a dangerous line in implying new thresholds of accountability on two levels.

    The first is the legal accountability that is being questioned with the reformed civilian harm investigation process. The DoDI must contain more details on how the Pentagon will act on these investigations. Moreover, whether the creation of CHM responsibility at all levels of the defence community allows for greater accountability for civilian harm and casualty incidents concerning the offending officer and/or commander. An interesting question for the DoDI to answer is what level of accountability will apply and whether it will be able to go above the COCOMS in cases of severe incidents.

    Secondly is information on the new levels of social responsibility that the Pentagon has given itself for civilian harm and casualty incidents. More specifically, how will the Pentagon hold itself accountable for the follow-up of their new social responsibility obligations.

    5. Communicate the Role the Pentagon will take in Ensuring International Cooperation with the CHMAP

    Objectives 9 and 10 which reveals the CHM strategy and assessment, must be a part of international security institutions and in multinational operations. As of now, little to no information on what the Pentagon will do to ensure non-American policy corresponds or compliments the Pentagon’s agenda has been dictated. The DoDI will need to provide information on three main questions:

    1. Whether NATO allies will be expected to develop and adopt their own CHMR-AP and DoDI that either meets or exceeds the Pentagon strategy or will the DoDI be developed into a NATO-inclusive policy?
    2. How will multinational operations contend with opposing views on CHM strategy?
    3. When responding to cases of civilian harm and mitigation, what will be the methods in contending different levels of accountability and different response strategies across multinational and international actors?

    Implications for International Defence Communities

    The CHMR-AP is an American-created plan for an American policy with an American focus, but the implications for international defence communities are profound.

    1. Norm Setting

    Although the CHMR-AP does not say this in precise words, it is clear that the Pentagon intends to ‘lead-by-example’ in creating, implementing, and following CHM policy. As mentioned in Objective 9 and 10, the Pentagon will pay closer attention to the existence and development of CHM policy in allies and help develop the foundation of CHM strategy in multinational operations. This is a definite push for other States to adopt their own CHM policies

    It will be important to see whether the DoDI addresses CHM policy and NATO. If NATO allies are required follow American CHM doctrine in NATO operations and/or develop their own CHM doctrine, then the U.S will succeed in creating a developing norm for the entire international community. NATO members like the Netherlands have expressed interest.

    The obligation to use CHM strategy in multinational or international operations also immediately establishes common practice. This provides an added benefit of allowing States building their own CHM policy to ‘learn-from-doing.’

    2. Inclusion of Civil Society in Decision-Making

    The inclusion of civil society, and specifically civilian-harm monitoring bodies, in the creation of the CHMR-AP is surprising as it is ground-breaking. When the CHMR-AP was being developed, the Pentagon brought in several NGOs and civil society groups under the umbrella name InterAction, including noted critics of the Pentagon, to advise on improving the policy.

    This opens the door for more civil society – defence community interaction, communication, and collaboration. Civil society groups often provide an invaluable position, which is at some level unburdened by the mandate of national defence and national power politics, that can aid militaries in reform. In the past, these communities have been separated, and often too contrarian. Civil society also has more knowledge and better relationships with communities involved in conflict and can provide an informed perspective. The cooperation between the two allows for better and more humane practices in conflict. There must be a concentrated effort, however, from both sides to ensure that this level of collaboration is not a one-time event.

    3. Incorporation of Red Teams

    The incorporation of Red Teams was also a surprising aspect of the CHMR-AP and has already gained major pushback from those inside the defence community. It could be argued that Red Teams are on a trial run to determine their effectiveness and benefits in this stage of implementation (keep in mind, only two staff members are assigned to Red Teams for each COCOM). Despite this, the Pentagon is normalising the presence of Red Teams at the operational level, a presence which will hopefully spread to other military commands. If or when Red Teams do prove their worth, governments will have a hard time demonstrating their effectiveness when pushing for a Red Team in their own militaries.

    4. New Avenues of Military Accountability

    The U.S military is the largest in the world, in terms of funding and the third largest in terms of active personnel.[27] The U.S has also, undeniably, killed an irreconcilable number of civilians in its operations and is criticised around the world for evading accountability for these deaths. While the CHMR-AP – and the DoDI to follow – are not a perfect solution, it is a great leap forward in creating responsibility for civilian casualty incidents.

    The CHMR-AP envisions a variety of such responsibility, (1) responsibility for civilian harm throughout the defence hierarchy, (2) responsibility for holding wrongdoers accountable, and (3) a responsibility to the civilian population for civilian harm incidents. The U.S being willing to open itself up to such impressive and varied responsibilities puts pressure on other States to accept responsibility for civilian harm incidents as well.

    The CHMR-AP has introduced a new era for the Pentagon, and we must be aware of what this means for the world. Containing 11 Objectives ranging from research to strategy reform to data collection to international defence, the CHMR-AP lays out a path for increased civilian protection in conflict. The CHMR-AP places civilians at the centre of military objectives, rather than the enemy. Further, there are implications for international defence such as norm setting, collaboration with civil society, incorporation of Red Teams, and new levels of military accountability for civilian harm incidents. While the CHMR-AP is only an Action Plan, it has led many to have high-hoped for the DoDI, which will turn the objectives into concrete Pentagon policy.


    Nicolás Sol Centeno is an undergraduate student at the Geneva School of Diplomacy and International Relations and a blog writer at Platform for Peace and Humanity. He enjoys researching and writing on the convergence of international humanitarian law and emerging technology in conflict. Nicolás has previously interned at the International Institute for Sustainable Development and Global Migration Policy Associates and contributes to UN Today magazine.


    [1] Neta Crawford and Catherine Lutz, “The Human Cost of Post-9/11 Wars: Direct War Deaths in Major War Zones,” (Watson Institute, September 2021) <https://watson.brown.edu/costsofwar/files/cow/imce/papers/2021/Costs%20of%20War_Direct%20War%20Deaths_9.1.21.pdf> accessed 10 September.

    [2] Todd Huntley, “Airstrikes, Civilian Casualties, and the Role of JAGs in the Joint-Targeting Process,” (Lawfare, August 2022) <https://www.lawfareblog.com/airstrikes-civilian-casualties-and-role-jags-targeting-process> accessed 10 September.

    [3] The Lawfare Podcast, ‘Todd Huntley and Marc Garlasco on the Pentagon’s New CIVCAS Action Plan,’ (9 September 2022) <https://www.lawfareblog.com/lawfare-podcast-todd-huntley-and-marc-garlasco-pentagons-new-CHMR-AP-action-plan> accessed 10 September.

    [4] Marc Garlasco, “The Defense Department Finally Prioritizes Civilians in Conflict,” (Lawfare, August 2022) <https://www.lawfareblog.com/defense-department-finally-prioritizes-civilians-conflict> accessed 10 September.

    [5] United States Department of Defence, Civilian Harm Mitigation and Response Action Plan (CHMR-AP, 2022)  <https://media.defense.gov/2022/Aug/25/2003064740/-1/-1/1/CIVILIAN-HARM-MITIGATION-AND-RESPONSE-ACTION-PLAN.PDF> pg. 1.

    [6] Ibid. See footnote 5. pg. 1.

    [7] Ibid. See footnote 5. pg. 1.

    [8] Ibid. See footnote 5. pg. 1.  

    [9] Ibid. See footnote 5. pg. 4.

    [10] Ibid. See footnote 5.pg. 6.

    [11] Ibid. See footnote 5. pg. 9.

    [12] Ibid. See footnote 5. pp. 9-11.

    [13] Ibid. See footnote 5. pg. 12.

    [14] Ibid. See footnote 5. pg. 13.

    [15] Ibid. See footnote 5. pg. 15.

    [16] Ibid. See footnote 3.

    [17] Ibid. See footnote 3.

    [18] Ibid. See footnote 4.

    [19] Ibid. See footnote 2.

    [20] Ibid. See footnote 4.

    [21] Ibid. See footnote 4.

    [22] Ibid. See footnote 4.

    [23] Ibid. See footnote 5. pg. 20.

    [24] Ibid. See footnote 5. pg. 27.

    [25] Ibid. See footnote 5. pg. 27.

    [26] Ibid. See footnote 5. pg. 30.

    [27] Evan Hecht, “Who Has the Biggest Military? Breaking it Down by Active and Reserve Members,” (USA Today, August 2022) <https://eu.usatoday.com/story/news/world/2022/08/27/who-has-biggest-military-world-most-powerful/7888866001/> accessed 14 September.

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