By Kirsty Welch
Commonwealth Human Rights Initiative
A forum full of potential: the Commonwealth provides an opportunity to all members, regardless of traditional dominance in international affairs, to sit as equals during discussions and decision-making. Thus the Commonwealth, as a unique grouping of 53 member states, which together comprise approximately a third of the world’s population, has the potential for innovative positive advances. The organisation is large enough to have an important influence on international affairs, if it so chooses. Furthermore, its workings and composition mean that it is both big enough and discrete enough to function as an ‘ideas lab’ that would allow it to implement and disseminate good practice and innovation of a wider relevance to the rest of the world. However, much of the Commonwealth’s potential remains underutilised as a result of internal wrangling regarding the organisation's purpose, enforcement of values and conservative functioning regarding the role of non-state actors.
The year 2013 should be remembered for the adoption of a Commonwealth Charter that emphasised the important role of civil society and affirmed the importance of core values such as human rights, democracy, peace, the rule of law and tolerance.[i] However, it was the 2013 Commonwealth Heads of Government Meeting (CHOGM) that drew more attention. The 2013 CHOGM was held in a country with a government that has undermined the independence of the judiciary,[ii] failed to respond adequately to allegations of gross violations of international humanitarian and human rights law[iii] and which stands accused of harassing, intimidating and conducting smear campaigns against dissenting voices.[iv]
Sri Lanka hosted a historic CHOGM in 2013. Historic, because it was attended by only half of the Commonwealth’s Heads of Government,[v] demonstrating both an increasing irrelevance of the organisation to its members and a potential split in membership regarding the direction the organisation is perceived to be travelling in. Moreover, the 2013 CHOGM was historic because multiple civil society organisations (CSOs) were absent[vi] and the Commonwealth People’s Forum (CPF) – the civil society component of the meeting – was controlled entirely by Sri Lanka’s Ministry of Defence.[vii] Unfortunately, a summit that should have celebrated the values of the Commonwealth turned into a clear demonstration of its inability to protect core values.
2013 saw the Commonwealth weather one more year, but it did not emerge stronger. When one compares the Commonwealth to other intergovernmental organisations, its response to violations of human rights demonstrates the increasing irrelevance of the body. The Commonwealth needs an investment in its future, one that is capable of demonstrating its commitment to its values. For this reason, 2013 was the year that the Commonwealth Human Rights Initiative (CHRI) renewed its call for reform of the Commonwealth’s governance system through the creation of a Commonwealth Commissioner for Human Rights, an independent specialist who could monitor, investigate and advise on human rights situations, and be a bridge between the official Commonwealth institutions and the people of the Commonwealth.[viii]
The need to reform the Commonwealth
During the first decade of the new millennium there were various calls to increase the relevance of the Commonwealth; one mooted idea was to increase the protection offered to its organisational values.[ix] In response, an Eminent Persons Group (EPG) was created to build a stronger and more progressive Commonwealth, relevant to its people and to the current time.[x] Several of the EPG’s recommendations have now been adopted. A Commonwealth Charter, consolidating Heads of Governments’ commitment to human rights was adopted;[xi] the Secretary-General’s Good Offices role, initiatives using behind-the-scenes diplomacy and capacity-building assistance in an effort to improve a country’s compliance with Commonwealth values,[xii] was strengthened;[xiii] and the mandate of the Commonwealth Ministerial Action Group (CMAG), a group of foreign ministers that discusses member states in serious violation of Commonwealth principles, was enhanced.[xiv] However, the EPG’s recommendation to appoint a Commissioner for Democracy, the Rule of Law and Human Rights was abandoned,[xv] and since the release of the EPGs findings there has been no tangible improvement in the spirit of partnership between CSOs and the official Commonwealth.[xvi]
Looking around the Commonwealth today, despite these reform efforts, there is little evidence that the Commonwealth’s protection mechanisms – principally CMAG, the Secretary-General and the Commonwealth Secretariat’s Human Rights Unit (HRU) – are sufficient to deliver interventions capable of protecting the human rights of the people in its jurisdiction. CHRI is of the view that the absence of a Commonwealth Commissioner for Human Rights is the missing link in the chain of renewal and that as a minimum, to improve the Commonwealth’s response to human rights violations, there is a need to increase the nature and scope of CSO participation.
The renewed Commonwealth mechanisms remain insufficient and underutilised for protecting human rights effectively. CMAG, the intended custodian of Commonwealth values and the only body capable of enforcement action,[xvii] continues to interpret its mandate narrowly, with the effect that only challenges to democracy will draw its attention.[xviii] Examples of human rights violations that have not made it onto CMAG’s agenda include continued impunity for credible allegations of war crimes committed by both sides in Sri Lanka’s civil war;[xix] widespread reports of limitations on fundamental freedoms and the commission of torture by state security officials in Uganda;[xx] and the continuing constriction of constitutional guarantees in Swaziland.[xxi] Unfortunately, CSOs have no role to play in influencing CMAG’s agenda, in order to ensure that these situations are discussed by the organisations custodian.[xxii]
CSOs are, however, able to input into CMAG deliberations by way of written submissions, but the impact of these is unclear, as meetings are usually held in private and deliberations are never disclosed. Furthermore, CSOs are tacitly discouraged from even this minimal level of participation, as dates of meetings and information regarding submission processes are difficult to obtain. CMAG lacks independent advice and would therefore greatly benefit from an increased level of civil society participation. Two recently reported controversies, the withholding of relevant legal opinions[xxiii] and the denial of access to the United Nations High Commissioner for Human Rights,[xxiv] demonstrated this by showing that currently the Secretary-General controls CMAG’s access to information.
The Secretary-General’s role as gatekeeper to CMAG is especially worrying, as the interests of CMAG may differ markedly from the Secretary-General’s interest in his Good Offices function. During discussions of the Secretary-General’s Good Offices role, he has repeatedly reaffirmed his preference for quiet diplomacy over public engagement. As a result the Commonwealth frequently appears paralysed and disengaged when faced with gross violations of human rights. Yet the good offices are often cited as tangible examples of Commonwealth efforts to uphold human rights. The problem with this is that their vigour and worth can only be guessed at because they remain cloaked in secrecy.[xxv] Moreover, the test of quiet diplomacy should be the ability to achieve results. There is no reason why success should not be publicly revealed. If concrete results cannot be attested, or observed, the quiet diplomacy must therefore be assumed to have failed. Both the EPG and the Commonwealth Advisory Bureau, the official independent think-tank of the Commonwealth which focuses on issues of democracy, globalisation, civil society and human rights, have noted a fear that “the Commonwealth’s bias towards behind-the-scenes diplomacy has allowed abusers “to continue to violate Commonwealth values.”[xxvi] It is concerning that the reform process did not address the conflict between quiet diplomacy and public denunciation or the conflict of interest between the Secretary-General’s Good Offices role and his role with CMAG.
Moreover, HRU, the only Commonwealth body dedicated to addressing human rights on a full-time basis, remains under resourced and overstretched. The HRU has been widely commended for its efforts towards capacity building[xxvii] and has demonstrated openness to civil society engagement;[xxviii] however, its small team lacks the resources and expertise to monitor and investigate human rights situations around the Commonwealth effectively. It further lacks the independence that would be required for it to lobby effectively for country-specific action against the wishes of the Secretary-General.
The role of civil society in the Commonwealth
CSOs currently have a limited role to play in Commonwealth decision-making, despite the role of the Commonwealth Foundation, a separate organisation from the Commonwealth Secretariat, to facilitate CSO engagement,[xxix] and despite the existence of the Commonwealth Foundation’s Civil Society Engagement strategy,[xxx] Civil Society Advisory Committee, and a Civil Society Liaison Officer in the Commonwealth Secretariat. CHRI has observed that it is actually becoming increasingly difficult for human rights-oriented CSOs to engage effectively in the relevant Commonwealth fora.
While written submissions can be made to CMAG, Ministerial Meetings and CHOGM, input is generally not solicited, and information regarding submission deadlines is not released with sufficient notice to allow meaningful CSO input.
The ability of CSOs to participate physically in ministerial meetings, including permission to attend meetings is ad hoc and inconsistent.[xxxi] Despite ad hoc arrangements in the past, currently, there are few opportunities for any type of CSO to physically participate in official Commonwealth meetings. Where CSO participation has been regular this has tended to be limited to meetings that do not have a direct role in protecting core Commonwealth values. Further, sporadic examples of previous good practices, such as inviting CSOs to provide oral testimony to CMAG on a particular country’s situation, thereby facilitating discussions regarding a state’s potential suspension from Commonwealth membership, demonstrates the present underutilisation of CSOs, as a result of the closing space for civil society within the official Commonwealth.[xxxii]
At one time CHOGM offered an effective lobbying opportunity for CSOs, despite limitations on permission to attend official discussions. However, new organisational practices, restrictions on access to facilities and censorship are limiting the space for CSO engagement at CHOGM. Immediately prior to CHOGM, the CPF is held so that CSOs can engage with the official Commonwealth.[xxxiii] However, in 2013 the CPF and CHOGM were deliberately held in separate cities,[xxxiv] and the management of the event by the Sri Lankan Ministry of Defence led to an “intimidating atmosphere”,[xxxv] thereby reducing CSOs’ opportunities to raise human rights concerns with Commonwealth leaders.
However, even when the CPF is not held under such repressive circumstances, it rarely promotes in-depth discussion of human rights. The CHOGM theme, which dictates CPF discussions, is selected without official space for CSO input and usually has a generalised development focus, thereby reducing scope for discussion of topical human rights concerns. In response, in 2003 and 2005, CHRI[xxxvi] instigated a parallel Human Rights Forum (HRF).[xxxvii] What ensued were productive discussions covering a wide range of human rights concerns. However, instead of encouraging this forum, the Commonwealth Foundation, which convenes the CPF, did everything in its power to subsume the HRF within the CPF.
Since the merging of the fora the resulting civil society statement to Commonwealth Foreign Ministers must incorporate the concerns of all CSOs present, further reducing the space for human rights concerns. Moreover, the value of the engagement with Foreign Ministers during the presentation of the statement is questionable. More often than not the lack of interactive dialogue reveals the real value the Commonwealth places on CSO input, demonstrated when Ministers fail to comment or restrict themselves to hostile comments regarding what they see as the role and credibility of the civil society representatives.[xxxviii]
Moreover, as with all official CHOGM submissions, the CSO statement is vetted by Commonwealth officials, and only if it is approved is it put into the information packs presented to Heads of Government. In the early 2000s it appeared that the message from the CPF was being manipulated before reaching the Heads, and in 2003 CHRI’s written submissions to CHOGM were the subject of an intense battle. This censorship function does not sit easily with the importance the Charter gives to civil society and further illustrates the intolerance of the Commonwealth to CSO input.[xxxix]
There is a continuing sense that the Commonwealth is an association of governments rather than people. This extends to the manner in which CSO engagement is facilitated. Key factors here include how much time is available for meaningful discussions; the nature of discussions and decisions on which CSO input is permitted; who and how many CSOs are invited to participate; how much time is given to CSOs to prepare their submissions; and what information is shared prior to the event.
Comparisons, in terms of CSO engagement, between the Commonwealth’s practice and that of the United Nations Human Rights Council (UNHRC), the UN’s premier human rights body, highlight the archaic approach of the Commonwealth. The Office of the High Commissioner for Human Rights (OHCHR) actively promotes and facilitates civil society involvement, noting that “cooperation with civil society remains a strategic priority because it bolsters our shared objectives, helps to address our mutual concerns, and supports the Office’s human rights mission.”[xl] When the UNHRC is in session, accredited CSOs have access to the building and delegations; are able to make written and oral submissions; can attend meetings; and can hold their own side events on issues of concern. To ensure that CSOs can engage in the most effective manner during these opportunities, OHCHR developed an extranet, electronic mailing list, a twitter feed and system of text message alerts to share documents, drafts and agendas with civil society. To engage CSOs beyond Geneva, all proceedings of the UNHRC are webcast. Furthermore, the OHCHR actively requests input in relation to the Universal Periodic Review, a periodical review of a country’s human rights performance; the work of Special Procedures, the UN’s independent experts tasked with reporting on specific human rights issues or country situations; treaty bodies, committees of independent experts that monitor implementation and compliance with specific human rights treaties; and for specific thematic human rights reports.
Despite commitments to the role of civil society in the Charter, adequate promotion, encouragement, facilitation and support for civil society remains largely absent in the Commonwealth. The Commonwealth must reflect on the changing nature and dynamics of civil society participation, including levels of civil society access and impact in other multilateral arenas. Additionally, CSOs of the Commonwealth must themselves push for a greater role, as the current extent of CSO involvement not only inhibits the volume of first-hand reliable information available to decision-makers, but also creates an atmosphere of distance from the people of the Commonwealth.
Conclusion: the need for reform
To date, the Commonwealth has not been able to hold its member states to its professed core values because its current mechanisms are not adequate for protecting human rights and it does not use the mechanisms it has to optimum effect. A further problem is the limited role that the Commonwealth is prepared to allow civil society in its processes. There is therefore a need for a renewal of the governance systems of the Commonwealth to enable it to effectively protect the human rights of its citizens.
It is the view of CHRI that a full-time, independent expert, resourced with appropriate infrastructure and mandated to provide politically neutral country information and advice, would enable effective monitoring and investigation of human rights abuses, promote better informed decision-making and facilitate the adoption of transparent procedures that would make obvious the Commonwealth’s commitment to human rights. Moreover, a Commonwealth Commissioner for Human Rights, who could be easily accessed by the citizens of the Commonwealth, would go some way to addressing the isolation of the Commonwealth from its people, enhancing and protecting the role of CSOs at the official Commonwealth and engaging citizens with the organisation.
This was the argument that CHRI took forward in its 2013 report to CHOGM, The Missing Link: A Commonwealth Commissioner for Human Rights.[xli] No formal response to this proposal was received from CHOGM, but CHRI is not concerned by this. Advocating for a change in international governance is a slow process that requires a long-term strategy. It is positive that CHRI’s call has already fed into the concerns of the international community, provoking the question of the desirability of membership of an organisation that does not protect the values for which it claims to stand.[xlii] Since CHOGM 2013, there has been an increased willingness by stakeholders to discuss the effectiveness of Commonwealth mechanisms. Conferences, roundtables and panels are taking place in 2014 with the sole focus on protecting and advancing the Charter. The debate is progressing, and the call for reform of the system through the creation of a Commissioner is a logical progression to the current debate.
It is hoped that as attention surrounding the debate grows, the CSOs of the Commonwealth will recognise that their rightful place is being denied to them and they will start to demand change. This in turn should lead the Commonwealth to look inward in order to make the necessary investments in its future to increase civil society involvement, and thereby its effectiveness at protecting human rights.
All citizens of the Commonwealth have a role to play in making the Commonwealth fit for purpose. We hope that other voices from the Commonwealth will join us to insist that our Commonwealth fulfil the purpose we need. Governments have a limited need to engage with the Commonwealth as it does not offer economic, business or geopolitical advantages that cannot be gained elsewhere. Yet the Commonwealth grouping poses a particular advantage for CSO engagement, due to the size and influence of the organisation. If the Commonwealth can be changed into a force for good in the world the advantage to individuals is clear. This ambition is not unattainable. At the 2013 CHOGM, approximately half of the Heads of Government did not attend the event. This is indicative of the real split in the organisation between states that are reform-minded and concerned about the increasing irrelevance of the organisation and those that seek to restrict the Commonwealth for their own individual self-interests. The fact that such a large proportion of the membership has indicated a dissatisfaction with the organisation demonstrates a unique opportunity for civil society to build alliances with reform-minded states in order to push for a more principled and relevant organisation.
The Commonwealth can only be revitalised if its people feel invested in it and as a result, countries feel the need to continue to financially and physically participate. The first step towards this is increasing CSO participation and the organisational response to CSO concerns. The alternative is an increasingly dissatisfied civil society that may eventually cease engaging with the organisation, either in a trickle fashion or as part of an organised boycott. Such a step would significantly impact the organisation’s legitimacy. There is hope for the Commonwealth only as long as the people of the Commonwealth continue to care about it.
[i] Articles II-VII, Commonwealth Charter, The Commonwealth, available at: http://thecommonwealth.org/our-charter.
[ii] R Sirilal and S Aneez, Sri Lankan chief justice impeachment illegal: Supreme Court, Reuters, 3 January 2013, available at: http://www.reuters.com/article/2013/01/03/us-srilanka-impeachment-idUSBRE90209D20130103 .
[iii] On Sri Lanka’s continuous lack of progress on holding people to account for violations of international humanitarian law please see: Promoting reconciliation and accountability in Sri Lanka, Report of the Office of the United Nations High Commissioner for Human Rights, UN doc A/HRC/25/23, 24 February 2014, available at: http://www.ohchr.org/EN/HRBodies/HRC/RegularSessions/Session25/Documents/A-HRC-25-23_AEV.doc .
[iv] Cooperation with the United Nations, its representatives and mechanisms in the field of human rights, Report of the Secretary-General, UN Doc. A/HRC/21/18, 13 July 2012, available at: http://www.ohchr.org/Documents/HRBodies/HRCouncil/RegularSession/Session21/A-HRC-21-18_en.pdf .
[v] 27 of the 53 member states were represented by their Heads of Government. See N Wijedasa, CHOGM-SHOWGM: Highs and lows of the Govt.’s magnum opus, Sunday Times, 17 November 2013, available at: http://www.sundaytimes.lk/131117/news/chogm-showgm-highs-and-lows-of-govt-s-magnum-opus-73694.html .
[vi] Joint Civil Society Statement Memorandum to CHOGM, Centre for Policy Alternatives, 8 November 2013, available at: http://www.cpalanka.org/joint-civil-society-memorandum-to-commonwealth-heads-of-state/ .
[vii] J Perera, Gatekeeping at the Commonwealth People’s Forum, The Sunday Leader, 10 November 2013, available at: http://www.thesundayleader.lk/2013/11/10/gatekeeping-at-the-commonwealth-peoples-forum/ .
[viii] The Missing Link: A Commonwealth Commissioner for Human Rights, Commonwealth Human Rights Initiative, 2013, available at: http://www.humanrightsinitiative.org/programs/CHOGM/The_Missing_Link_Report.pdf .
[ix] Common What? Emerging Findings of the Commonwealth Conversation, Royal Commonwealth Society, 26 November 2009, available at: http://www.cpu.org.uk/userfiles/Common%20what_.pdf ; K Afar-Gyan, A Jahangir and T Sheey, Democracy in the Commonwealth. A report on democracy in the Commonwealth eighteen years after the adoption of the Harare Declaration, Commonwealth Policy Studies Unit, 2009, pg 2, available at: http://eris.org.uk/images/userfiles/File/Democracy%20TEXT%20ONLY.pdf .
[x] A Commonwealth for the people. Time for urgent action, The Report of the Eminent Persons Group to Commonwealth Heads of Government, Eminent Persons Group, October 2011, available at: http://www.sirronaldsanders.com/Docs/EPG%20Report%20FINALprintedVersion.pdf .
[xi] Above fn 1.
[xii] Mechanisms of the Commonwealth to address violations of Commonwealth Values – Three part series, Paper one: The Good Offices of the Commonwealth Secretary-General, Commonwealth Human Rights Initiative, 2014, available at: http://www.humanrightsinitiative.org/publications/nl/paper_series_2014/CHRI-Series%20on%20CW%20Mechanisms-Good-Offices%20of%20the%20SG.pdf .
[xiii] Report by the Commonwealth High Level Review Group to Commonwealth Heads of Government, Commonwealth High Level Review Group, 3 March 2002, available at: http://www.chogm2002.org/pub/statements/hlrg.html ; and Strengthening the Role of the Commonwealth Ministerial Action Group (CMAG), Report of CMAG as adopted by Heads of Government at their meeting in Perth, 2011, available at: http://secretariat.thecommonwealth.org/files/245418/FileName/Strengthening-the-Role-CMAG_2011.pdf .
[xiv] Strengthening the Role of the Commonwealth Ministerial Action Group (CMAG), Report of CMAG as adopted by Heads of Government at their meeting in Perth, 2011, available at: http://secretariat.thecommonwealth.org/files/245418/FileName/Strengthening-the-Role-CMAG_2011.pdf .
[xv] CFNHRI Communiqué to Commonwealth Heads of Government CHOGM 2013, Colombo, Sri Lanka, Commonwealth Forum for National Human Rights Institutions, 2013, available at: http://cfnhri.org/wp-content/uploads/2013/12/CFNHRI-Communique-to-CHOGM-20133.pdf ; and P Jebaraj, Commonwealth defers decision on Human Rights Commissioner, The Hindu, 30 October 2011, available at: http://www.thehindu.com/news/national/commonwealth-defers-decision-on-human-rights-commissioner/article2580121.ece .
[xvi] Above fn 10, pg 125-6.
[xvii] Our Governance: Commonwealth Ministerial Action Group, The Commonwealth, 2014, available at: http://thecommonwealth.org/our-governance .
[xviii] A Duxbury, Reviewing the Commonwealth’s Rights Record: From Recognition to Realisation, (2003) South African Journal on Human Rights 19, pg 656.
[xix] Sri Lanka not on CMAG agenda, Business Standard, 26 March 2013, available at: http://www.business-standard.com/article/pti-stories/sri-lanka-not-on-cmag-agenda-113032600444_1.html .
[xx] Appalling Crackdown on Freedoms in Uganda continues, CIVICUS, 29 August 2013, available at: http://civicus.org/media-centre-129/press-releases/1844-appalling-crackdown-on-freedoms-in-uganda-continues .
[xxi] R Lee, African Union Criticises Swazi Elections, All Africa, 23 September 2013, available at: http://allafrica.com/stories/201309231019.html .
[xxii] Above fn 16.
[xxiii] Expose: Full Text of Sharma’s Buried Report: Impeachment Violated C’wealth Principles, Sowed Seeds of Anarchy, Colombo Telegraph, 9 September 2013, available at: https://www.colombotelegraph.com/index.php/expose-full-text-of-sharmas-buried-report-impeachment-violated-cwealth-principles-sowed-seeds-of-anarchy/ .
[xxiv] Sharma Preventing Navi from Addressing CMAG, Colombo Telegraph, 26 September 2013, available at: https://www.colombotelegraph.com/index.php/sharma-preventing-navi-from-addressing-cmag/ .
[xxv] There is no public website presenting a list of current projects, criteria for triggering their operation, activities undertaken or progress made.
[xxvi] R Bourne, Forging Commonwealth consensus: the buck stops with the Secretary-General, Commonwealth Advisory Bureau, September 2012, available at: http://sas-space.sas.ac.uk/4840/1/Opinion_piece_09_12.pdf .
[xxvii] Above fn 13.
[xxviii] For example, CHRI resourced a Commonwealth regional training on the Universal Periodic Review in Africa and the Caribbean at the request of the HRU.
[xxix] Memorandum of Understanding, Revised by Commonwealth governments 21 September 2012, Commonwealth Foundation, available at: http://www.commonwealthfoundation.com/sites/cwf/files/downloads/Commonwealth%20Foundation%20Memorandum%20of%20Understanding.pdf .
[xxx] Civil Society Engagement Strategy, Commonwealth Foundation, September 2013, available at: http://www.commonwealthfoundation.com/sites/cwf/files/downloads/Commonwealth%20Foundation%20Civil%20Society%20Engagement%20Strategy_0.pdf .
[xxxi] For more information, please see: http://www.humanrightsinitiative.org/cwhra/cs_cw_minister_meetings.htm .
[xxxii] Human Rights Advocacy in the Commonwealth: A User’s Handbook, Commonwealth Human Rights Initiative, 2005, available at: http://www.humanrightsinitiative.org/publications/hradvocacy/hr_advocacy_in_the_cw.pdf .
[xxxiii] For more information, please see: http://www.commonwealthfoundation.com/project/cpf#sthash.oZ0H7bkT.dpuf .
[xxxiv] CHOGM was held in Colombo and the People’s Forum was held in Hikkaduwa.
[xxxv] Above fn 7.
[xxxvi] CHRI facilitated the Human Rights Forums in collaboration with local partners: in 2003, Legal Resource Consortium, Nigeria and National Human Rights Commission, Nigeria; and in 2005, Amnesty International Malta Group.
[xxxvii] In 2003, in Abuja, Nigeria and in 2005, in Valletta, Malta.
[xxxviii] Observations of CHRI staff who have attended the CPF and the roundtable with Foreign Ministers.
[xxxix] Above fn 1.
[xl] Civil Society, Office of the High Commissioner for Human Rights, 2012, available at: http://www.ohchr.org/EN/ABOUTUS/Pages/CivilSociety.aspx .
[xli] Above fn 8.
[xlii] Canada to Send Low-level Rep to CHOGM in Colombo, Will Review Funding for C’Wealth, Colombo Telegraph, 7 October 2013, available at: https://www.colombotelegraph.com/index.php/canada-to-send-low-level-rep-to-chogm-in-colombo-will-review-funding-for-cwealth/comment-page-1/ .