9&9" 1% Denise NATALI PROFESSIONAL EXPERIENCE Hires/or, Center for Sll'a/egic Research (CSR), Diximgul'shzd Rescul'ch Fellow, will Minerva Chum /ar Na/iannl Sludte: (INSS), Nahum! Defense Umvetoily (NDU). war/ringnm DC January 201 1 presenr. I As Director, oversee budgerr administration, research and teaching, for ID CSR senior and military fellows. Suppon director in developing and implementing strategic vision. policy, and research guidelines to assure that CSR lneets NDU mission objectives (March 2017- present). - As Distinguished Research Fellow/Minerva Chair, provide analysis, strategic support. and regular briefings on Middle Easr security issues to the Joint Staff at the Department of Defense (DOD), Special Operations Command CentraL CENTCOMI USO agencies, and the broader nalional security and intelligence communities Member of SOCCENT Senior Advisory Group and subject matter expert (SME) for strategic mullirlayer assessment orthe Islamic State of Iraq and . ria (1315) and post-ISIS srahihzauon planning. wuh a focus on Turkey. Syria. Iraq, Iran. and the trans-border Kurdish Issue. - Supported the Office of the Secretary of Defense's Minerva Research In alive on paste authoritarian states. with a focus on Iraq, Turkey and regional energy security in the East Mediterranean Basin, the Caspian Basin. and the South China Sea I Teach elective eolnse "Intervention and PostcConflict Twenty years of War" at NDU's College of lntematlonal Security Affairs. Developed the currlculum on the Middle East and North Africa for the Eisenhower Schools National Security Policy and Strategy core course, Provide guest lectures and SME support [0 NDU colleges. research institutes, and other US. professional lnilitarv education institutions Member of NDU faculty advisory committee to enhance communication between NDU presidency. faculty, and research centers, . Sponsor and organize conferences. and symposia on Middle East and energy security issues that engage illtel'national and national DOD, use agencies, thinkclanks and academic comlnunlties. - Publish policy-onenred and scholarly articles for leadingjournals, thinkeranks, and forums. Write analytical r-epuns (FOUO) on field research trips and conferences conducted at NDU, which are dlsselnlnared to USG agencies. . Give presentations at international and national conferences, expert roundlables, and seminars. Provide interviews and expert Commentaries on local and regional dynamics in the Middle East to national and international media, Adyunc-I .41 mt iule Pm; Mir, for Securlly Similar, minim! Walsh School of Foreign Service, Gem'gulmt'n txniuer pring 2012, 2013, 2017. 2018. - Teach course. Security Issues in the Middle East" for 1571:; Masters' students. DHS EXH 001 Academic Dean of Students, Research Centers Director, Director of International Programs and Exchanges, and Associate Professor, The American University oflraq-Sulaimani (A Ul-S), Sulaimani, Kurdistan Region ofIraq. August 2009-December 2010. • Devised and implemented university-wide policies relating to student performance, disciplinary issues, and overall academic matters. • Developed and directed the first research centers at AUI-S to include roundtables, guest-lecture series, brown bag lunch programs, and conferences that engaged international, local and regional scholars and practitioners. Established and maintained institutional linkages with foreign universities and international organizations to enhance the intellectual life at AUI-S. Wrote grant proposals and secured over $1 million for student scholarship program. • Liaised with high-level government officials, international organizations, and universities on AUI-S academic matters and student exchange programs in Iraq and abroad. • Taught undergraduate course in Middle Eastern History. Head ofDepartment, Assistant Professor, Department ofPolitics and International Relations, University ofKurdistan-Haw/er (UK.HJ, Erbil, Kurdistan Region ofIraq. September 2006-July 2009. • Member of start-up team for first public-private university in Kurdistan Region of Iraq based on U.K. higher education system. Devised curriculum and taught courses offered by the department of politics and international relations at undergraduate and graduate levels. Acted as line-manager for 5 expatriate staff. Interacted and coordinated with regional and local education officials, U.K. based officials, and other departmental heads. • Conducted large-scale research project on youth attitudes in the Kurdistan Region in coordination with Dr. Eric Davis and supported by The American Academic Research Institute in Iraq. Visiting Lecturer/American Academic Research Institute in Iraq Fellowship, Salahaddin University, College ofPolitical Science, Erbil, Kurdistan Region ofIraq. Sept 2005-June 2006. • Taught courses at College of Political Science to undergraduate, masters, and doctoral students. • Conducted in-depth field research and published articles on the political economy of post-war Iraq, which included extensive interviews with different socio-economic groups, local institutions, aid agencies, youth organizations, and local officials. Project Director-Research Fellow, Washington Kurdish Institute (WK!), Washington DC and Paris, France. Jan. 2001-June. 2005. • Designed and directed U.S. Institute of Peace-supported comparative research project that examined the impact of globalization processes, migration and refugee flows, and transnational networks on Kurdish nationalist movements in Iraq, Turkey, and Iran. Conducted extensive interviews with Kurdish Diaspora and NGOs in France, Germany, England, and northern Iraq. Research integrated in final chapter of The Kurds and the State. Information Officer, Disaster Assistance Response Team (DART), Office of Foreign Disaster Assistance (OFDA), Agency for International Development, U.S. Department ofState, Northern Iraq. May 1993-July 1994. • Served as DART team member in support of Operation Provide Comfort (OPC) II, which provided humanitarian aid, relief assistance, and stabilization operations to war-affected populations. Travelled extensively throughout no-fly zone/safe haven in northern Iraq and Turkey (southeast and Incirlik) to evaluate USG-funded programs and the economic, political, and security issues that impacted relief projects and stabilization. Created field reporting and weekly analyses disseminated to USG stakeholders, senior military and civilian officials. • Liaised with senior U.S. military leaders and USG officials, U.N., international donor agencies, NGOs, and local officials. Represented OFDA at regional and local (Iraq) meetings. 2 DHS EXH 002 • Regularly briefed senior U.S. military and State Department officials at the U.S. Military Coordination Center in northern Iraq, Incirlik base, and Washington D.C. Research Assistant, Center for Strategic and International Studies, Washington D.C. Sept.1991-May 1993. • Provided research support and analysis for Dr. Edward Luttwak for his book on geo-economics, The Endangered American Dream. • Conducted research, field assessments, analyses, and writing on international security issues in Afghanistan and the Middle East, with a focus on the Kurdish regions in Turkey, Iraq, and Syria. Project Specialist, American Red Cross, International Division, Washington DC. Feb.-July 1991. • Provided in-depth analysis, documentation, and operational assistance for Gulf Relief Project in southeastern Turkey and northern Iraq. Wrote weekly briefing reports on the Gulf War refugee crisis and natural disasters in the Middle East and South Asia that were disseminated to USAID, NGOs, and international agencies. Director, Cross-Border Operations, Freedom Medicine (FM}, Peshawar, Pakistan. Sept. 1989-Jan. 1991. • Managed strategic planning and implementation of cross-border activities for USAID-funded healthcare delivery and training project for Afghan refugees. Coordinated operations with FM clinics and hospitals in Northwest Frontier Province. • Provided logistical and management support to secure and transport 180 Afghan paramedics, medicines, and relief supplies to and from remote border areas in Pakistan and Afghanistan. • Trained Afghan counterparts and prepared FM's monitoring missions throughout war-affected regions of Afghanistan; documented results into written reports disseminated to USAID and INGOs, and international donor organizations. • Liaison to the Afghan Interim Government's Ministry of Public Health. EDUCATION Doctor ofPhilosophy (Ph.DJ, University of Pennsylvania, Department of Political Science, Philadelphia, PA. 1994-2000. • Specializations: Comparative Politics and International Relations University of Tehran, Dehkhoda Program in Farsi language. Tehran, Iran. In-house resident at L'Institut de Recherche en Iran. Feb.-May 1998. Fran~ais Institut National des Langues et Civilisations Orientales. Paris, France. Persian and Kurdish language courses. 1996-2000. Tel Aviv University, Tel Aviv, Israel. Courses in Israeli Politics, Islam, and Arab-Israeli Affairs. June-Aug. 1992. Master of International Affairs (MIA), Columbia University, School of International and Public Affairs, New York, NY. 1985-1987. • Specializations: Western Europe and International Political Economy Bachelor ofArts (BA), Franklin & Marshall College, Lancaster, PA., 1981-1985. • Major: Government • INSTEP Program in government (Imperial College). London, England. Sept.-Dec. 1983. 3 DHS EXH 003 PUBLICATIONS Books The Kurdish Quasi-State: Development and Dependency in Post-Gulf War Iraq (Syracuse: Syracuse University Press, July 2010) The Kurds and the State: Evolving National Identity in Iraq, Turkey, and Iran (Syracuse: Syracuse University Press, 2005). Trans. To Turkish. Kurt/er ve Dev/et: Iraq, Turkiye ve Iran 'da Ulusal Kimligin Gelismesi (Istanbul: Avesta Press, 2009). Second edition to include new chapters on Syria. Articles/chapters in edited volumes "State break.down and its beneficiaries: the Kurds'', in The Routledge Handbook ofInternational Relations in the Middle East (London: Routledge, forthcoming). "The Political Economy of China's Maritime Silk Road Initiative in Iraq", forthcoming chapter for edited volume. "Syria's Spillover on Iraq: State Resilience", Middle East Policy Vol. XXIV, No. 1; Spring 2017; 48-61. "The Middle East", in Richard H. Hooker (ed.), Charting a Course: Strategic Choices for a New Administration (Washington D.C., National Defense University, 2016); 249-265. "Engaging Kurds in U.S. Policy: Strategic Allies or Tactical Partners?'', Strategic Studies Quarterly, (National Defense Research University, Ministry of Defense, Armenia, 2016). "Can Syria's Kurds Leverage War Gains into Political Autonomy?'', World Policy Review, May 2016; 1-12. "Settlers and State-building: the Kirkuk Case" in Hak.lai, Oded and Neophytos Loizides (eds.), Settlers in Contested Lands: Territorial Disputes and Ethnic Conflicts (Stanford University Press, 2015); 114-140. "The Kurdish Quasi-State: Leveraging Political Limbo'', The Washington Quarterly; Vol. 38, No. 2; Summer 2015; 145-164. "Counting on the Kurds: The Peshmerga's Prospects Against ISIS'', Foreign Affairs, April 22, 2015. "Transborder Kurdish Politics: Unity or Division?'', Harvard Journal ofMiddle Eastern Politics and Policy, Vol. III; 2013-2014; 28-38. "Iraqi Kurdistan: Stabilizer or Spoiler?", Georgetown Journal ofInternational Affairs, Summer/Fall 2013; 71-79. "The Persistent Boundaries of Kurdish Nationalism", World Politics Review, May 9, 2012. "The Politics of Kurdish Crude", Middle East Policy, Vol. XIX, No. 1; Spring 2012; 110-118. 4 OHS EXH 004 "The Kirkuk Conundrum", Ethnopolitics 7, no. 4; Nov. 2008; 433-443. "The Spoils of Peace in Iraqi Kurdistan", Third World Quarterly 26, no. 6; Sept. 2009; 1111-1129. "Kurdish Interventions in the Iraq War", in Paul Stares and Hazel Smith (eds.), The Diaspora Conundrum: Peacemakers or Peacewreckers (New York: UN University Press, 2007); 196-217. Transnational Networks: New Opportunities and Constraints for Kurdish Statehood'', Middle East Policy, XI, Spring 2004; 111-114. "Kurdayeti in the late Ottoman and Qajar Empires'', Critique: Critical Middle Eastern Studies Vol. 11, No. 2; Aug. 2002; 177-199. "Manufacturing Identity and Managing Kurds in Iraq" in Brendan O'Leary, Ian S. Lustick, and Thomas Callaghy (eds.) Rightsizing the State: The Politics ofMoving Borders (Oxford: Oxford University Press, 2001); 253-88. "International Aid, Regional Politics, and the Kurdish Issue in Iraq since the Persian Gulf War", (Abu Dhabi: Emirates Center for Strategic Studies and Research, Spring 1999). Analyses and Op-ed articles in War on the Rocks, al-Monitor, Law/are (Brookings), Carnegie Endowment for International Peace, Middle East Research and Information Report, Foreign Policy, The World and I, and the Christian Science Monitor. PRESENTATIONS/GUEST LECTURES Provide lectures, briefings, and conference and keynote speaker presentations to think tanks, universities, and organizations in the U.S. and overseas. These include; U.S. Institute of Peace, Carnegie Endowment for International Peace, American Political Science Association, International Studies Association, Council of Foreign Relations, Middle East Studies Association, World Affairs Council of Philadelphia, Princeton University-Woodrow Wilson School of International Relations, Elliot School of International Relations, The George Washington University, Foreign Service Institute, RAND Corporation, Middle East Institute, Atlantic Council, Hudson Institute, Center for Strategic and International Studies, New American Foundation, Columbia University, Institute of Turkish Studies, State University of New York, Open Society Institute, Washington Institute for Near East Policy, C.D. Hyton Senior High School, American University School of International Service, American Enterprise Institute, German Marshall Fund, London School of Economics and Political Science, Truman Institute-Hebrew University, Moshe Dayan Center-Tel Aviv University, Middle East Security and Cooperation Conference (Track II-Prague), the Istituto Affari Internazionale (Rome), al-Sharq Forum, U.K. Foreign Office, Chatham House, University of Oslo, Durham University-School of Government and International Affairs (UK), UN University (Hong Kong), Austrian Institute of International Affairs, University of Southern Denmark, University of Amsterdam, French Institute for International Relations (Paris), Nowruz and Soran University (Kurdistan Region-Ira), Academy and Finance (Switzerland), Bi-Partisan Policy Council, SETA Foundation, Turkish-American Coalition, Turkish Policy Center, Embassy of the Republic of Turkey, Embassy of the Federal Republic of Germany, and Israel Public Affairs Committee. 5 OHS EXH 005 INTERVIEWS/MEDIA Provide interviews and briefings to national and international media outlets in English and French to: the New York Times, Washington Post, MSNBC (Nightly News, Morning Joe}, NPR (All Things Considered}, BBC, PBS, CNN, Reuters, Associated Press, France 24, McClatchy News Service, Swiss Radio, Swedish National News, NBC, le Figaro, France 24, Le Parisian, 20 minutes, France 5, Sun News, Radio France, Voice of America, The Los Angeles Times, War on Rocks, al-Jazeera English (TV}, CNN Turk, Australian Broadcasting Corporation, al-Hurra, Zaman, Middle East Times, Corriero Braziliense, Energy Intelligence, Kathleen Dunn Show, Greenwire News, Environment and Energy, International Business Times, Energy Compass, Bloomberg-Businessweek, Radio Free Europe, Ilkehaber (Turkish}, Hurriyet (Turkish), Anadolu Agency (Turkish}, al-Zaman, The Atlantic, and TheQuestion, MEMBERSHIPS, ACTIVITIES, HONORS & AWARDS Member of Advisory Council, Atlantic Council Iraq Initiative, 2017-present. Life-time Member, Council of Foreign Relations. February 2015 to present. Member, International Institute for Strategic Studies (USS). March 2011-March 2013; June 2014 Present. Contributing Editor, War on the Rocks Columnist, al-Monitor Member, Future oflraq Task Force, Atlantic Council. 2015-2017. Member, Council of Foreign Relations Task Force on Turkey. March 2011-April 2012. Editorial Board Member. International Journal ofMiddle East Studies (IJMES), January 2010-2013. Choice Award. Outstanding Academic Title for The Kurds and the State: Evolving National Identity in Iraq, Turkey, and Iran. January 2006. Honorary Research Fellow. Institute for Arab and Islamic Studies, Exeter University, Exeter UK, April 2006-2009. The American Academic Research Institute in Iraq (TAARI}, Fellowship. "Differentiated Development in Post-war Iraq". 2005-2006. The U.S. Institute of Peace, solicited grant award. "Transnationalism and Diaspora Networks: Reconfiguring Kurdish Nationalism." 2003-2004. The U.S. Institute of Peace, Jennings Randolph Peace Scholar. Washington DC. 1998-99. The University of Pennsylvania Dissertation Fellowship. Philadelphia, PA. 1997-98. The U.S. Department of Education Foreign Language Area Studies (FLAS) Fellowship (Farsi), The University of Pennsylvania, Middle East Department, Philadelphia, PA. 1995-97; and Berkeley University, Berkeley, CA. Summer 1995. 6 OHS EXH 006 The White House Fellowship, Regional Finalist. Washington DC. 1991. SPECIALIZED TRAINING AND SKILLS Humanitarian !reformation Management (HIM) - Vietnam Veterans ofAmerica Foundation, Information Management and Mine Action Symposium. Washington DC. Jan. 19-25, 2004. • Training and certificate in structured humanitarian assistance reporting, data management, and technical resources. Disaster Management-American Red Cross. Washington DC. July 1991. • Training and certificate in disaster response management. Languages: French (fluent), Kurdish and Farsi (conversant). Security Clearance: SECRET level 7 OHS EXH 007 DECLARATION OF DENISE NATALI Qualifications I am the Director and Distinguished Research Fellow of the Center for Strategic Research at the Institute for National Strategic Studies, National Defense University (INSS) where I specialize in the Middle East, Iraq, trans-border Kurdish issues, and post-conflict stabilization. I joined the INSS in January 2011 as the Minerva Chair, following more than two decades ofresearching and working in the Kurdish regions of Iraq, Turkey, Iran, and Syria. At the INSS, I provide Middle East security analyses and strategic support to senior leaders at the Department of Defense, unified combatant commands, State Department, intelligence communities, and the broader national security community. I am a subject matter expert and part of the Senior Advisory Group for the strategic assessment of the Islamic State of Iraq and the Levant (ISIL) in support of the Joint Staff, SOCCENT and CENTCOM. I am also the author of numerous publications, op-eds, and short analyses on Iraq, Syria, Turkey, Kurds, and countering ISIS. My books include: The Kurdish Quasi-State: Development and Dependency in Post-Gulf War Iraq and 171e Kurds and the State: Evolving National Identity in Iraq, Turkey and Iran, which was the recipient of the Choice Award for Outstanding Academic Title (trans. to Turkish Kurtler ve Devlet: Iraq, Turkiye ve Iran'da Ulusal Kimligin Gelismesi). I also specialize in post-conflict relief, reconstruction, and stabilization. I worked as the director of cross-border operations for a non-governmental organization in Peshawar, Pakistan ( 19891991 ), specialist for the American Red Cross Gulf Relief Crisis Project in Washington D.C., and information officer for the Disaster Assistance Relief Team, U.S Agency for International Development's Office of Foreign Disaster Assistance in northern Iraq in support of Operation Provide Comfort II (1993-1994). I returned to post-Saddam Iraq (2005-2010), where I engaged in research, teaching, and university start-ups in the Kurdistan Region, including positions as Associate Professor, Director of Research Institutes, and Dean of Students at the American University oflraq-Sulaimaniya (AUI-S). I provide frequent commentary on national and international media sources. I am also an adjunct associate professor at Georgetown University's Center for Security Studies, a columnist for a/Monitor, contributing editor for War On the Rocks, and a member of the Council on Foreign Relations and International Institute for Strategic Studies, and Advisory Board for the Foreign Policy Research Institute. Most recently, I returned from a research trip to Iraq in September 2017 where I met with diverse groups and officials in northern Iraq and Baghdad, including Prime Minister Haidar al-Abadi, members of the Iraqi parliament, Sunni Arab tribal sheikhs, provincial representatives, civil society leaders, members of the business community, and teachers and students. 1 OHS EXH 008 !11troductio11 I have been asked by the Department of Homeland Security to provide my opinion concerning the risk of hann faced by Iraqi deportees from the United States, including those who belong to religious or ethnic minorities and those who have criminal histories. I have reviewed numerous statements, including those authored by Marie Lattimer, Nina Shea, Rebecca Heller, Daniel Smith, Michael Rubin, and Douglas Ollivant as well as other background material. My opinion is based upon over twenty years of extensive research, study, and work in Iraq up to the present day and represents my own views and not those of the United States government, the Department of Defense, or the National Defense University. As I have recently explained in testimony before a Senate Foreign Relations Subcommittee, Iraq is home to vulnerable religious and ethnic minorities facing many post-liberation challenges. 1 While those challenges can be significant and should not be minimized, they do not translate into an appreciable risk of persecution or torture for every Iraqi who is deported from the United States to Iraq, whether that person is a member of a religious or ethnic minority, or not. The opinions expressed in the statements I reviewed are outdated - Michael Rubin's and Douglas Ollivant's as exceptions - as to the effects of ISIS 's recent occupation of territory in fraq and as to anti-American or anti-western sentiment in Iraq. In fact, many of the Sunni Arab communities that were most hostile to the U.S. after the overthrow of Saddam Hussein, have told me that "they made a mistake" and want greater U.S. engagement and presence in Iraq. There is no direct correlation between the defeat of ISIS and threats to Christian populations. The statements also convey a misunderstanding of the nature of the various militias operating in Iraq and their relationships with religious and ethnic minorities. The government of Iraq is focused on counter terrorism and post-ISIS stabilization, and l find the suggestion that the government of Iraq will be interested in detaining returning Iraqis, even those who are criminals, for a substantial period of time, much less banning them, to be farfetched. The Iraqi government's over-riding priority, and where it has focused its over-stretched resources, is on ISIS members and those suspected of supporting ISIS. The other key issue facing the Iraqi government is creating the necessary conditions so that internally displaced persons (IDPs) can return to their homes, stabilizing the country, and engaging in reconciliation. I do not share their conclusions that all rraqis living in the United States face grave dangers if deported or that the deportation of an Iraqi national would necessarily violate laws against genocide, persecution, and torture. 1 "The Future oflraq's Minorities: What's Next After ISIS?", Testimony before the Senate Foreign Relations Subcommiuee on Western Hemisphere, Transnational Crime, Cfrilian Security. Democracy. Human Rights, and Global Women's Issues, October 4, 2017, Denise Natali. 2 OHS EXH 009 The Aftermath ofISIS 's Occupation The ISIS offensive that began in the summer of 2014 resulted in the occupation and control by ISIS oflarge swaths oflraqi territory in Ninewah province and elsewhere in Iraq. Over 3 million IDPs found themselves in camps or other localities, about one million in the Kurdistan Region, with others in central and southern Iraq. Within the areas of Iraq under its control (approximately one-third of Iraq at its height), ISIS committed mass atrocities against religious minorities. It also brutally attacked Shi'a communities throughout Iraq, as well as some Sunni Arabs who refused to support the group, or who defected. Today, the situation is much different. ISIS has been routed from all but a small portion of Iraq. As the government of Iraq and Iraq's Popular Mobilization Units (PMUs) have made significant gains against ISIS, ISIS has been unable to maintain an effective insurgency or wage widespread guerilla warfare, although ISIS cells remain in some fonnerly occupied towns and cities. Iraqi officials expect and are preparing for ISIS to continue to stage attacks and act as an insurgent group, to which they are not fully prepared to counter. The groups directly targeted by these insurgent attacks are generally Shi'a communities. The liberation of fonner ISIS safe-havens has encouraged the return of IDPs. By September 2017, about 2.2 million of about 3.2 million IDPs had returned to their homes. Although ongoing security threats, the lack of services, and sporadic or sometimes nonexistent reconstruction support have deterred the return of religious minorities (as well as Sunni Arab groups, who comprise the vast majority ofIDPs), they no longer face a threat from ISIS. Nor do they face mass atrocities or targeted harm by any other group or by the government of Iraq, which has retaken control over much of the disputed territories, including the Ninewah Plains and Kirkuk. Rather, as I recently testified before the Senate, religious minorities are caught up in the political cross-fire between Baghdad and Erbil (the capital city of the Kurdistan Region) as well as affected by the influence of Iranian-backed militias. For example, in the recently-liberated Christian town of Bartella, there is a new Imam Khomeini primary school with flags of Iran. Different militias, including those backed by Iran, control the checkpoints in the town, with different Christian militias inside the town. The Iranian-backed militias do not target Christians and Yezidis, rather, their presence feeds local power struggles, sectarianism, and the risk of future conflict. Additionally, the Christian community itself is fractured over the Kurdistan Regional Government's (KRG's) influence in parts of Ninewah province. Their ancestral lands are claimed by both the Iraqi government and the KRG. Most view the KRG's influence, specifically the forces controlled by Masoud Barzani's Kurdistan Democratic Party (KDP) negatively, while others support the KRG - those who have been coopted or are KDP members. The KRG has expended significant resources on some Christian and Yezidi communities as part of its larger aim to annex the territories into a future Kurdish state or expanded Kurdistan region. This effort has dissipated since the referendum, as the Iraqi government has reasserted federal 3 DHS EXH 010 authority over the Ninewah Plains and most of the disputed areas. At present a ceasefire is in place between Baghdad and Erbil. Taken together with the lack of reconstruction support, the contestations of Baghdad and Erbil, local power struggles, and the resulting political instability have deterred the return of many IDPs who are minorities to their homes and villages in the Ninewah province. Even so, thousands of Christians and Yezidi have returned uneventfully to rebuild their homes, and their villages and towns are often protected by Christian and Yezidi militias, as well as PMUs and Iraqi forces. This return could increase as Baghdad reasserts federal authority over the Ninewah Plains, Kirkuk and other disputed territories. Although there may be isolated incidents of violence, those that have returned have not suffered mass atrocities and do not face the risk of harm they once did. Rather, many of these minority group militias from Yezidi and Assyrian communities are working with Baghdad. More can be expected to return in the future, particularly if the current political trend to reduce ethno-sectarianism throughout Iraq gains traction. If they do not, it will likely be because of increased instability due to the continuing power struggle between Baghdad and Erbil or lack of opportunities, rather than any specific targeting of religious minorities for harm. Many Christians have returned to Mosul and other areas in the Ninewah Plains. Some have had their first mass in years. They are now free to celebrate their religious traditions without the fear of reprisals. Minorities in areas of Iraq not occupied by ISIS remained largely unaffected by ISIS's offensive in 2014. For example, over 7 million people reside in the capital city of Baghdad, and that population includes Christian, Assyrian, Armenian, and Yezidi communities that lived in Baghdad throughout the offensive and continue to do so today. Since the rise and fall of ISIS, the priority of the government of Iraq is now identifying, prosecuting, and detaining ISIS members, as well as reconstructing liberated territories and stabilizing Iraq. The suggestion that the government of Iraq would have a particular interest, time, or resources to focus on deportees from the United States or other western nations, whether or not a deportee has a criminal history or is a member of a religious minority or is in possession of a current identity document, is not born out by any reliable evidence of which I am aware. Iraq 's Popular Mobilization Units Iraq's PMUs are a group of now state-sponsored militias that have come under the umbrella of the government of Iraq. Since December 2016, the PMUs have been incorporated into Iraq's military and are subject to the authority of the Prime Minister. Some militias operate independent of the government of Iraq, which has tolerated them because of their shared common goal of defeating ISIS and bringing stability to Iraq. A minority of the PMUs are funded and supported by the Iranian Islamic Revolutionary Guard Corps (IRGC). The 4 OHS EXH 011 government of Iraq estimates that about I 0% of the PMUs are IRGC-backed. Other estimates place the number as high as 30%. Whatever the number may be, these IRGC-backed PMUs are not targeting religious minorities such as Christians and Yezidi despite opportunities to do so. Although they are principally Shi'a, some are recruiting Sunni Arabs by offering salaries, food provisions, and security services that, until now, have not been offered by the Iraqi government. This is evidence that membership in a militias is driven as much by financial and security concerns as by ideological ties and ethno-sectarianism. Many militias have mixed membership that cross ethnic, religious, and political lines. Some are comprised of largely or entirely of religious· minorities, and villages and towns that are Christian or Yezidi often have their own militias protecting them. In the course of fighting ISIS, PMUs have committed human rights abuses, particularly in ISIS strongholds and against suspected sympathizers among Sunni communities, but there has not been the widespread targeting of religious minorities or even Sunnis at large. Their focus has been on routing ISIS and its supporters. The government of Iraq has pledged to investigate and punish those members of the PMUs who have committed human rights abuses. An Iraqi deportee would have no particular reason to fear the PMUs barring an association with ISIS or a history as a high-level Ba'athist. This reflects the lingering suspicions and retributions between Sunni and Shi'a Arabs, and within the Sunni Arab populations. Many years in the United States should reduce the risk that such an individual would be suspected of an ISIS association. Anti-American/ Western Sentiment Although in the past there has been anti-American sentiment in Iraq, and it may linger among certain individuals or groups, it is not accurate to say that such a sentiment is widespread in Iraq today or that Iraqis face a heightened risk of persecution when they are perceived as aligned with western or United States' interests. Indeed, some Iraqi populations, particularly among the Sadrists and Communist groups, are anti-American. This sentiment is rooted in propaganda often disseminated by Iran - that the U.S. seeks to break up Iraq and has created ISIS. Even then, these groups are not targeting Americans and in fact, are seeking for the U.S. to support Prime Minister Abadi in encouraging political reforms. These groups and PMUs do not regularly target individuals or groups because of an anti-American or anti-western sentiment. It was only with the support of the United States that the government of Iraq and the PMUs were able to take back the land occupied by ISIS. This is why Abadi can make public statements seeking for the U.S. to remain engaged in Iraq - although not with a large military presence - and not fear reprisals from the Iraqis, and particularly from the Sadrists. At present, the principle and most dangerous anti-American sentiment lay with ISIS and other terrorist groups, which have largely been driven out of Iraq or killed. 5 OHS EXH 012 Since the breakdown of the Iraq state and the emergence of sectarian conflict in 2003, many religious minorities fled Iraq. The return of religious minorities over the years, including many from western nations, and the re-activation of their church services, in Baghdad, Mosul and the Ninewah Plains, have acclimated many communities to returnees. Their return is welcomed by religious and community leaders seeking to rebuild and strengthen their communities after the routing of ISIS. Those with ties to the United States or western nations, or even wealthy Iraqis, may be perceived to have money and therefore · could be possible targets for kidnapping or extortion. Those who have no familial ties to Iraq may also have more difficulty re-integrating into Iraqi society than those with a potential support network. But they will not be subject to a widespread anti-American or anti-western animus. Conclusion The statements2 that I have reviewed concerning ISIS are outdated and show little understanding of current realities on the ground in Iraq, with the exception of those authored by Douglas Ollivant and Michael Rubin. They do not take into account that today, ISIS's occupation has ended and that much of the post-ISIS stabilization involves Sunni Arab territories and communities, and some disputed areas in northern Iraq. The risk of facing anti-American or anti-western sentiment as well as the risk of harm from the PMUs is grossly overstated. If anything, the time spent in the United States reduces the risk of harm because the individual would be presumed to have no ties to ISIS, which is the principal focus of both the government of Iraq and the PMUs at the present time. Similarly, the risk that an Iraqi deportee who has spent significant time in the United States will be placed in custody and banned upon arrival is unsupported. Iraq indisputably has challenges to overcome before it will be less vulnerable to the political instability caused by tension with the K.RG, Iranian influence, and ethno-sectarianism. These challenges are felt by religious minorities in disputed tenitories who have become the political victims of regional power struggles. But this does not translate into a risk of harm for every Iraqi returning from the United States. Although it goes without saying that an Iraqi who has spent years or decades in the United States will have difficulties upon return to Iraq, religious minorities no longer face the high risk of being singled out for torture, death, and even genocide that they did during ISIS's occupation. Even then, an individual returned to Iraq could have likely avoided harm by resettling outside of occupied territory. Now, such an individual can return to where he or she may have family ties in Iraq, wherever that may be, without facing a significant risk of being singled out for harm simply because he or she may be a member of a religious minority, has spent significant time in the United States, or may have a criminal history. 2 The statements authored by Mark Lattimer, Nina Shea, Rebecca Heller, Daniel Smith, Michael Rubin, and Douglas Ollivant are attached hereto. 6 OHS EXH 013 In short, Michael Rubin and Douglas Ollivant paint an accurate picture of the situation on the ground in Iraq vis-a-vis the risk of harm faced by an Iraqi returned from the United States today. There would have to be a unique circumstance, · such as suspected ISIS affiliation, for such a person to face a risk of harm that is greater than that shared by Iraq's population of 37 million as a whole. Accordingly, I assess, contrary to the statements of Mr. Lattimer, Ms. Shea, Ms. Heller, and Mr. Smith, that Iraqi deportees do not face an appreciable risk of harm merely by virtue of their return to Iraq, and therefore that the Department of Homeland Security can seek to remove Iraqis without running afoul of laws and treaties protecting persons against persecution, torture, genocide, and other human rights violations. Pursuant to 28 U.S.C. § 1746, I declare under the penalty of perjury that the foregoing is true and correct. Executed on this 8th day of November, 2017. Denise Attachments 7 OHS EXH 014 Natali