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Bottom-Up Approach: A Viable Strategy in Solving the Somali Conflict

Nuredin Netabay
March, 2007

This piece was written while the author was completing a Master of Arts degree in Peace Studies at the Joan B. Kroc Institute for International Peace Studies at the University of Notre Dame.


Although Somali people have the same religion, language and cultural background, they have been forced to fight each other by self-interested warlords and their supporters at the cost of rule of law and statehood. The civil war has caused enormous destruction in the economic, social and political spheres of Somalia. Despite the current Transitional Federal Government that has been brought back to Mogadishu by Ethiopian force, it could not control and stabilize the country. The government has no support from most Somalis and its efforts to exert itself by force might bring another cycle of bloody violence. Hence, Somalia is still in partial anarchy, and its people have been hopeless and helpless about their future.

After so much destruction, after so much human misery and suffering, Somalia's civilian population is desperate for any solution. Somali people need hope and peace. They are in desperate need of a trustworthy government, free from clan and sub-clan influence, which can serve the interest of the whole Somali population to bring peace and stability. But peace and reconciliation might not be easy to come by in Somalia. There is a great social divide created by spilling of blood, which will take generations to erode. This paper, therefore, presents a bottom-up approach to build peace from the grassroots level in Somalia. The paper argues that the bottom-up approach is a viable strategy to narrow down the social divide in Somali communities and to realize a lasting peace and reconciliation in Somalia.


As the winds of change began blowing in the Communist block that led to the demise of the Soviet Union, the political landscapes of many other authoritarian countries were affected by the changes as well. Internal conflicts erupted in many countries under authoritarian regimes, in which the oppressive governments had been maintained and tolerated during the Cold War by the superpowers.[1] As a result, some oppressive and tyrannical governments in Africa, including the Somali government, were overthrown by armed factions and revolutionaries.

Siad Barre's regime in Somalia was one of the oppressive regimes that fell during the eruption of internal conflicts. In 1991, after years of political upheavals, Mohamed Siad Barre was overthrown by a coalition of armed factions.[2] The fall of Siad Barre's regime "left a vacuum that rival clan militias fought savagely to fill."[3] None of the warring factions could successfully win the war, but the same time, they could not come to a consensus on who would govern the country. As a result, in early 1991, "Somalia was at the mercy of armed factions, which were organized along clan lines."[4] Since then, Somalia has been without an effective government or any political system capable of governing the country.

The civil war among clan and sub-clan factions was destructive in terms of its material cost and the loss of life. "Not only had the state collapsed but all logistics were interdicted and roads blocked, the feeble economy ruined, and anarchy imposed. The result was a famine that put 4.5 million people at risk, including half a million dead, two million displaced, and one million made refugees."[5] This chaos and loss of life received regional and international attention. Consequently, several peace and reconciliation efforts were held by IGAD (Intergovernmental Authority onDevelopment), the United Nations, and regional governments such as Ethiopia and Djibouti, to reconstruct and reunite the Somali state.[6]

Despite the fact that "some of the Somali peace and reconciliation efforts have had positive outcomes" they have frequently failed to take root in the long-term.[7] So far, none of the efforts could reconcile the warring factions, and thus could not end the anarchy in the country. The outcome of every peace effort has generated new and worse conflicts. Therefore, the important questions are:

  • Why did all effort in Somalia not bring peace and stability?
  • Was the approach used in the previous Somali peace efforts relevant to the realities in Somalia?

Roy Licklinder in his article "Obstacles to Peace Settlements" argued that the reason why peace effortsin civil wars or violence, fail is because they do not solve the problems that caused the civil wars.[8] This argument is relevant to the Somali peace efforts. The main causes of the Somali civil war were unequal power distribution, poor sharing of resources among different Somali clans, negative clanism, marginalization of intellectuals, misrepresentation in the government, and negative external influences. In most previous peace efforts, the top-down approach was used to reconcile the divided Somali society by addressing the causes of the conflict. Paradoxically, a top-down approach could not properly address the aforementioned factors, which contributed greatly to the failure of those peace efforts.

The scope of this paper is, therefore, to propose a bottom-up approach to solve the conflict in Somalia. The paper argues that the best strategy that could solve the problems related to power, resource-sharing, participation, and representation of all communities would be adopting a pure bottom-up approach.

The Failure of the Top-Down Approach

According to Somali scholar Abdullah A. Mohamoud, "through [a] top-down approach, twelve national reconciliation conferences were convened with the goal of restoring a central authority in Somalia, yet no success was achieved. The immediate reason for this was that the faction leaders and warlords who signed the peace deal, and agreed to form a national government, frequently failed to honor their promises."[9] The main reason that these warlords failed to fulfill their promises is that they did not trust each other; and they feared being bypassed and losing their economic and political power in the national government.

There is a great social divide that has been created by the spilling of blood, accompanied by bad memories of the devastation in Somalia. Characterizing contemporary conflicts like that of Somalia, John Paul Lederach says, "The conflicts are characterized by deep-rooted, intense animosity; fear; and severe stereotyping." Given this reality, Somali people are very alert and sensitive to any kind of authority that is imposed from outside their country or from above through a top-down approach to peacebuilding. They are afraid of a clan-lord and warlord-dominated central government, which might repeat the ugly events of the civil-war period. Considering this deep mistrust and suspicion between Somali clans, it cannot be surprising that adopting a centralized approach has been problematic in Somalia.

The "Quasi-Bottom-Up Approach"

A quasi-bottom-up approach has been tried in some of the previous peace efforts in Somalia. I call the approach used in these peace efforts a "quasi-bottom-up approach" because, in reality, the approach did not have the characteristics of bottom-up approach. First of all, the conferences were held outside of Somalia. Second, the participants were all warlords who have no Somali public support. Third, nothing was done to build local capacity, raise public awareness and lay ground inside Somalia for a successful outcome of the conferences.

During the UN-sponsored Addis Ababa Peace and Reconciliation Conference of 1993[11] and the later IGAD-led Peace and Reconciliation Conference of 2004, for example, a quasi-bottom-up approach was tried. In the Addis Ababa conference, the Transitional National Council was formed with the objective of establishing strong regional administrations before building a central government.[12] The approach was not successful because nothing was done to clear the ground for effective institutional and administrative apparatuses at regional and sub-regional levels. "The idea of the Addis agreement was a parallel top-down and bottom-up approach (track 1 and 2)".[13] But in practice the top-down approach was the dominant one. From the beginning, the UN was pushing for "quick top-down solution with the warlords."[14] In addition, when warlords like Aideed rejected the formation of regional administrations, the UN officially changed its approach and tried to form a central government by bringing all of the warlords together. Therefore, the quasi-bottom-up approach of the Addis Ababa conference did not work.

Similarly, in the IGAD-led conference of 2004, the Transitional Federal Government was formed with the aim of establishing a federal system composed of clan-based regional governments.[15] The formation of clan-based regional administrations was problematic because it was difficult to specify the boundaries of different clans. In addition, nothing was done to raise the local capacity, or to create a favorable ground for regional administrations. Members of the federal Assembly could not even agree about where to locate the seat of the federal government. The minister and the members of the federal assembly had no public support inside Somalia since all were self-appointed.[16] "Given all these factors, some Somali people have lost hope of a successful outcome for this peace process. They do not trust what they see as the network of warlords and their masterminds."[17] Overall, the approaches previously used to try to establish a federal administration were considered as externally imposed, and were unable to serve the interests of Somalis.

The Potential of a True "Bottom-Up" Approach

If the top-down approach and quasi bottom-up approaches could not work, then, what approach might possibly solve the Somali problem? The simple answer is: a true bottom-up approach. A bottom-up approach is a people-centered approach that advocates peace from within the affected societies and requires changing hearts and minds of the local people to get them to work for peace and reconciliation whole-heartedly. A pure bottom-up approach requires developing institutions from the grassroots level, developing local capacity for self-government, raising public awareness, promoting representation of all Somali communities, and providing an ideal environment for the development of local administrative units as the basis for a decentralized government. When strong regional administrations are established, it will be easier to establish a federal government. The bottom-up approach is, according to Mohamoud:

"Basically an internal affair and a locally driven peace process. The dominant players are the local-level leadership, such as the traditional elders, religious leaders, locality and community leaders, local traders and [the] network of grass-roots civic associations such as women, intellectuals, etc. The local-level leadership initiated the reconciliation procedures as a gradual process and attempted to build the peace step by step."[18]

Therefore, the bottom-up approach is establishing basic institutions and administrative apparatuses as a cornerstone for a future federal government starting from the local communities, and free from clan affiliations and the interference of warlords.

The Life and Peace Institute of Sweden and John Paul Lederach have contributed comprehensive approaches to peace building that could possibly be used in solving the Somali conflict. In his comprehensive transformation-oriented peacebuilding and conflict transformation approach, Lederach divides the society into three levels: top leadership (level 1), middle-range leadership (level 2) and grassroots leadership (level 3).[19] In divided societies like Somalia, Lederach advocates concentrating on indigenous actors within the country and not external actors. "The aim of Lederach's peace-building approach is to identify representative individuals or groups in the middle range level and empower them by means of mediation and other peace-building measures. The role of external actors is limited to supporting the internal actors by means of empowerment."[20] Basically, Lederach's idea is that by empowering the middle-level leadership, it is easier to influence the bottom or the grassroots level, as well as the top-level leadership, to transform the society quickly.[21]

Slightly different from Lederach's approach, the Life and Peace Institute (LPI) focuses on both middle-range and grassroots level leadership with more emphasis on the grassroots level in the conflict country. Basically, LPI's approach is by "empowering these two levels sooner or later the entire society will be transformed by peaceful means."[22] In this case, the peacebuidling process is both vertical and horizontal with more emphasis on people and affected communities.

Although focusing on the middle-range leadership is important, putting more emphasis on the grassroots level is very crucial in the case of Somalia. Given the reality that there have been no clear and legitimate leaders that have support in the middle and top-level, it might weaken the bottom-up approach to put more focus on the middle and top levels. The current government in Somalia is made up of former warlords who do not have full public support. The government has been brought to Mogadishu by external forces, and it has been exerting itself using external forces. As history shows, however, a forcefully imposed government cannot be sustained in Somalia. In the middle-range level, there are no strong cross-religious or regional organizations, NGOs or other influential groups that could influence the top and bottom levels at the same time. Even most Somali intellectuals who could play a great role in the middle-range leadership live in the diaspora. In addition, Somali society has been divided along clan and sub-clan lines and their allegiance is to the clan leaders or elders at the village level, not to intellectuals or politicians who live in the diaspora. Therefore, a bottom-up approach with more emphasis on the grassroots level is very consistent with the realities in Somalia.

The Bottom-Up Approach as a Multi-Dimensional Process

In the bottom-up approach, the peace process should not be conceived of as a single process. In previous peace processes, efforts were made to establish a government for Somalia, but little had been done to raise the awareness of the people, to identify the social, cultural and political constraints for the process or to prepare the Somali society to accept the government. For lasting peace in Somalia, developing a local capacity and basic institutions is very crucial. Strategic accessibility and the mobilization of those localities and communities,[23] and sections of society like elders and women, who are willing to be involved in the process, are also crucial steps in attaining peace.

The Role of Women

At this point I would like to emphasize the role that women could play in uniting divided communities in Somalia. In traditional Somali society women "play an indirect but important part in conflict resolution. In the early stages of a conflict they can act as peace envoys for their clans and are sometimes the 'first messengers sent between disputing clans to break the ice."[24] Even during the course of the civil war, "women across Somalia have been deeply involved in peace promotion and peace-making."[25] In the grassroots and community level, women have respect and could exert influence over their traditional leaders (clan leaders), elders and politicians. Understanding this fact, the Life and Peace Institute has put "a strong focus on the empowerment of women as peacebuilders, through direct capacity building and training, or support to special women's meetings."[26] Therefore, women should be empowered in order to be at the forefront of any peace efforts in Somalia. They should be allowed to participate in any future peace and reconciliation conferences and decision-making processes.

Marriage as a Tool of Peace

Another thing that could contribute to peacebuilding from the grassroots level in Somalia is identifying cross-clan and sub-clan marriage relations. In Somali society, marriage across clans and sub-clans is prevalent. "Marriage in Somali society is a contract between families or lineages... and young people are encouraged to marry into a group where new relations can be established."[27] Marriage relationships are a binding force among different clans and sub-clans and could help them develop close relationships and solve any disagreements through peaceful means. "Cross-clan marriages create diplomatic relations between groups, and are therefore treated with respect."[28] Marriage strengthens bonds between lineages and often creates a basis for interaction among different clans and sub-clans. Thus, in a bottom-up approach to peacebuilding, cross-clan marriage relations could be used to solve disagreements among communities. People who have marriage connections from different clans and sub-clans could play a crucial role in narrowing the differences and perceptions among rival communities to work together toward lasting peace. NGOs and Civil Society: In the building of a local capacity, the NGOs and civil society could contribute a lot in the peaceprocess in Somalia, through awareness raising programs, and by undertaking different socio-economic projects that benefit the local people. Civil society organizations and NGOs could raise the hopes of people of different clans by changing their hearts and minds in order to develop mutual trust and confidence, so that all can work for lasting peace whole-heartedly. The warlords and fighters, who have savaged the country, are sons of these people. If the society could develop confidence and trust in each other, it might be easy to eliminate warlordism.

In every society, the stories you tell to your children are very important for the harmony of the society.[29] If you pass narratives of hatred and enmity to your children, that means the conflict and mistrust will continue. Thus, civil societies, grassroots level organizations, and NGOs are needed to change the hearts and minds of Somali communities, so that they can begin to bury the past misery, hatred and enmity, for the sake of peace and a united Somalia.


Since the bottom-up approach requires mutual understanding and confidence-building among communities, there should be no time limits during the peace process. "Enough time must be made available to find a quality settlement, that is, one that deals effectively with the basic issues of conflict. When this is not met, and negotiators are forced into rushing a decision, agreements of poor quality may result."[30] Such problems, of limiting time and rushing for a decision, have taught peacemakers bitter lessons that should be remembered, especially those learned during the UN-sponsored Addis Ababa conference of 1993. In connection to the time frame, mediators in the peaceprocess should be familiar with the social and cultural realities of the communities they are working with, so that they can understand the real problems of the culture, and help work toward their solutions. In protracted conflicts where the societies have suspicion and distrust of each other "only intermediaries that understand the cultural nuances of the society and who enjoy the Confianza (something more than simply 'trust') of the antagonist can hope to carry out intermediary roles successfully."[31]

Though the initiation of building a local capacity should come from within, external support is also important in terms of providing financing, facilities and technical assistance. The Life and Peace Institute and John Paul Lederach also argue that external actors should be limited to facilitation roles.[32] I agree with LPI's and Lederach's idea of facilitation, but external actors who facilitate the process should be sympathetic to the cause of Somali people. They should not be politically motivated and self-interest oriented international and regional actors.

In addition, any facilitation role played by external actors or the international community should not be that of arranging another conference outside Somalia. The international community must also not just pump money into the process for conferences. The international community should provide support for building the Somali local-level capacity for self-government, developing grassroots institutions, and encouraging civil society as a corner stone for regional administrations.

Bottom-Up Approach and Somali Traditional Peace and Reconciliation Mechanism

The bottom-up approach has clear appeal in Somalia, when we see Somali traditional peace and reconciliation mechanisms called Xeer.[33] "Xeer is a precedent-based social code which is understood to apply to all Somali people and served as a necessary restraint and moderating guide in disagreements and feuds between groups and individuals ? [it is] equivalent to an ad hoc village council and at which all males are ostensibly permitted to voice their concerns."[34] It is the most democratic tactic, which solves disputes peacefully and allows all people to participate equally in the process of electing their leaders and establishing their administration.

Xeer fits with the bottom-up approach in the sense that it contains social and political conventions and contracts, and it emphasizes a decentralized political authority that is administered by community leaders. "Xeer is an institution to mediate social and political arrangements in present-day Somalia, where anarchy and state collapse continue."[35] Xeer has been tried, experimentally, in Somaliland and Puntland and has proven to be very successful. These two regions succeeded in creating institutions led by a council of elders that "have both mandates for, and experience in conflict resolution and continuing responsibilities in establishing peace."[36] Especially in Somaliland, the council of elders "succeed not only in creating a constitution but in appointing the government."[37]

Somaliland and Puntland might serve as models for stabilizing the other regions. If all regions succeed in establishing community-based administrative institutions, the formation of a federal state would not be difficult. "It must be realized that true peace for Somalia can only come from the Somali people themselves, with the engagement of traditional and indigenous peace and reconciliation mechanisms, and without international domination."[38]

Bottom-Up Approach as a Means for Fair Power and Resources Sharing

The problem of power and resource-sharing is a major factor that led to the failure of previous peace efforts in Somalia. The power and resource-sharing problem is not limited to the Somali case; but it is a determining factor in most civil wars and intrastate conflicts. "It is logical as these wars involve a struggle for power and influence in society. This is a way to handle the participation of parties in a society after a war: to give space to a host of actors who have previously been suppressed or excluded from influence."[39] Unless all parties feel secure, the peace-process is likely to fail because it "involves control over government, as government resources can be used to maintain the security dilemma or to transcend it."[40] Thus, ensuring the security of all parties should be part of any peace process.[41]

If one of the warring parties is skeptical about its security after the agreement or in the future government, certainly it will spoil the agreement. "Even a small but dedicated group can commit a series of violent acts that can bring about the collapse of the peace process."[42] Therefore, for any peace process to be successful, it should involve all parties.[43] In addition, a successful peace process requires the properly shared control of power and resources.[44] But "shared control may require some degree of trust; [and] it may also be a temporary arrangement for a transition period?This is where all parties are represented in [the] government according to a formula agreed upon beforehand."[45]

Therefore, in the Somali case, the use of the bottom-up approach is ideal for solving the aforementioned problem of power and resource-sharing, and the participation and security dilemmas. Somalis have a "traditional system of land management, agricultural and grazing systems, conflict mediation, legal adjudication, and related functions."[46] Using this system, Somalis solve disputes related to power, land, resources, and the security of different communities and clans. Somali people "seek broad-based power sharing, both as an echo of the past and as a search for a more participatory future."[47] For this reason, "any new model of governance must include power sharing,"[48] which could only be realized through a bottom-up approach in order to represent all Somalis.


Today, Somalis are in desperate need of peace and stability. After enormous destruction in the economic, social and political spheres of Somalia and loss of life, Somalis need any sort of peace. In all previous peace efforts, Somalis were hoping to hear good news, news of peace and unity. Unfortunately, most of the previous peace efforts could not bring the lasting peace that Somalis have dreamt for decades. The main causes of the conflict are believed to be unequal power and resources sharing among different Somali clans and sub-clans. These issues have never been addressed in the previous efforts. The top-down approach, forming a centralized administration starting from the top-level leadership, was used in the previous peace efforts. However, given the hatred and suspicion among Somali clans, a top-down approach could not solve the Somali problem. The only possible approach that could solve the Somali problem, as this paper argues, is adopting a bottom-up approach.

A bottom-up approach is a comprehensive and community-centered long-term strategy that could bring a lasting peace in divided societies. Bottom-up approach in Somalia requires empowering local people, raising public awareness, and ensuring representation and participation of all sections of the community in the process. Accessible sections of the society like women and elders should play a crucial role in the peace process. In short, a bottom-up approach in Somalia should be indigenizing the peacebuilding process. The peace process should start from within and trickle up in Somalia and should win the hearts and minds of the Somalia people.

Somalis do not need externally convened conferences where self-appointed governments are set up. As history shows us, previous peace and reconciliation conferences failed and the governments which had been elected in these conferences had no public base. They could not win the support of people, so they could not unite the country. Therefore any future peace process should be inside Somalia by Somalis. External actors should restrict themselves to providing facilitation for the process. In addition, they should provide financial and moral assistance for the process. Otherwise, external actors should let the Somalis take the ball of the peace process and play the game by themselves.

[1] Mohamed Sahnoun, Somalia: The Missed Opportunities (Washington, D.C.: United States Institute of Peace Press, 1994), p.1.

[2] Mary-Jane Fox, Political Culture in Somalia: Tracing Paths to Peace and Conflict, Report No. 56 (Uppsala: Uppsala University, Department of Peace and Conflict Research, 2000), 146.

[3] I. William Zartman, Cowardly Lions: Missed Opportunities to Prevent Deadly Conflict and State Collapse, (London:Lynne Rienner Publishers, 2005), 79.

[4] Roel Van Der Veen , What Went Wrong with Africa? A Contemporary History (Amsterdam: KIT Publishers, 2004), 148.

[5] Zartman, 88.

[6] Ibrahim Farah, Abdirashid Hussein and Jeremy Lind, Deegaan, Politics and War in Somalia (Chapter 7).

[7] Ibid.

[8] Roy Licklider, "Obstacles to Peace Settlements," in Turbulent Peace: The Challenge of Managing International Conflict, ed. Chester A. Crocker, Fen Osler Hampson, and Pamela Aall (Washington, D.C.: United States Institute Peace Press, 2001), 697-698.

[9] Abdullah A. Mohamoud, State Collapse and Post-Conflict Development in Africa: The Case Study of Somalia (USA: Purdue University Press, 2006), 158.

[10] John Paul Lederach, Building Peace: Sustainable Reconciliation in Divided Societies (Washington DC.: United States Institute of Peace Press, 1997), 23.

[11] Wolfgang Heinrich, Building the Peace: Experiences of Collaborative Peacebuilding in Somalia 1993-1996 (UK: Ipswich Book Company, 1997), xvii.

[12] Ibid.

[13] Thania Paffenholz, The Development of the Life and Peace Institute's Approach to Peacebuilding and Lessons Learned from the Somalia Experience (1990-2000) (Kenya: Kijabe Printing Press, 2003), 34.

[14] Ibid., 35.

[15] "Negotiating a Blueprint for Peace in Somalia," An International Crisis Group Report, Africa Report No 59, 6 March 2003, Mogadishu/Brussels, p. 4-5.

[16] Abdullahi D. Khalif, "Somalia's Peace Process Weakened by Top-Down Approach," Mwangaza: Newsletter of Trocaire's East Africa Regional Office (EARO), Issue 2, December 2004.

[17] Ibid.

[18] Abdullah A. Mohamoud, 159.

[19] John Paul Lederach, Building Peace: Sustainable Reconciliation in Divided Societies (Washington DC.: United States Institute of Peace Press, 1997), 39.

[20] Paffenholz, 22.

[21] Ibid., 60.

[22] Ibid.

[23] "Strategic Peacebuilding from Below" Talk by Prof. John Paul Lederach at the Strategic Peace Building Conference during the 20th Anniversary of Kroc Institute, November 6, 2006.

[24] Zeynab Mohamed Hassan and Shukri Hariir Ismail, "Women and Peace-making in Somaliland" in Somalia — The Untold Story: The War Through the Eyes of Somali Women, ed. Judith Gardner and Judy El Bushra (London: Pluto Press, 2004), 140.

[25] Ibid.

[26] Paffenholz, 62.

[27] Sadia Musse Ahmed, "Traditions of Marriage and the Household" in Somalia — The Untold Story: The War Through the Eyes of Somali Women, ed. Judith Gardner and Judy El Bushra (London: Pluto Press, 2004), 52.

[28] Ibid., 57.

[29] "Strategic Peacebuilding from Below" Talk by Prof. John Paul Lederach at the Strategic Peace Building Conference during the 20th Anniversary of Kroc Institute, November 6, 2006

[30] Pierre du Toit, "Rules and Procedures for Negotiated Peacemaking" in Contemporary Peace Making: Conflict, Violence and Peace Processes, ed. John Darby and Roger Mac Ginty (Palgrave: Macmillan, 2003), 66.

[31] Christopher Mitchell, "Mediation and the Ending of Conflicts" in Contemporary Peace Making: Conflict, Violence and Peace Processes, ed. John Darby and Roger Mac Ginty (Palgrave: Macmillan, 2003), 82.

[32] Paffenholz, 59.

[33] Ibrahim Farah, Abdirashid Hussein and Jeremy Lind, Deegaan, Politics and War in Somalia (Chapter 7).

[34] Mary-Jane Fox, 61.

[35] Ibrahim Farah, Abdirashid Hussein and Jeremy Lind, Deegaan, Politics and War in Somalia (Chapter 7).

[36] United States Institute of Peace, "Removing Barricades in Somalia: Facilitating Peace," 11/15/2006. http:/

[37] Ibid.

[38] Abdullahi D. Khalif, "Somalia's Peace Process Weakened by Top-Down Approach," Mwangaza: Newsletter of Trocaire's East Africa Regional Office (EARO), Issue 2, December 2004.< /p>

[39] Wallensteen, 139.

[40] Ibid., 133.

[41] Ibid.

[42] Roy Licklider, 701.

[43] Ibid.

[44] Wallensteen, 55.

[45] Ibid., 56.

[46] United States Institute of Peace, "Removing Barricades in Somalia: Facilitating Peace," 11/15/2006. http:/

[47] Ibid.

[48] Ibid.

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