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He Said, Xi Said: The Difficulties of Strategic Communication between the United States and China

  • Published
  • By Cadet Myles Arenson


The People’s Republic of China (PRC) is a rising revisionist power whose actions pose a significant challenge to the United States and its allies.1 To face this challenge, US national policy under Pres. Donald Trump focuses on competing with PRC aggression. National policy like the National Security Strategy (NSS) and the National Defense Strategy (NDS) have outlined deterrence as the cornerstone for military strategy with the PRC. In its Indo-Pacific section, the NSS states that the United States “will maintain a forward military presence capable of deterring and, if necessary, defeating any adversary.”2 The NDS outlines the need for the United States to “deter adversaries from aggression against our vital interests.”3 More specifically, the NDS highlights the need to “set the military relationship between our two countries [US and PRC] on a path of transparency and non-aggression.”4 Effective communication is required for transparency, as well as any strategic deterrence operation. Any breakdown in signaling degrades a nation’s ability to effectively deter enemy aggression, making that nation more exposed to enemy threats.

Communication or signaling is a necessity in all strategic deterrence operations. The United States and the PRC have an extensive history of failing to effectively communicate or signal one another. The implications of communications breakdown between the United States and the PRC could lead to misunderstanding and unintended escalation between nuclear powers. This would certainly devastate both nations, in addition to the global community. Given the history of communication failures between the United States and China, the United States needs to develop a more effective communications strategy to effectively deter China and meet the objectives of the NSS and the NDS.

Fraught US–China Relationship

This year the United States and the PRC celebrated 40 years of formal relations between the two nations, yet this milestone passed largely unnoticed and uncelebrated by either country. In the past two decades, the PRC has become the world’s second-largest economy, more than tripled its military spending, expanded the president’s executive power, and become more confrontational internationally, with aggressive economic, political, and military behavior illustrated by intercepting several foreign aircraft and naval vessels.5 The PRC is greatly opposed to the United States’ frequent reconnaissance missions, especially in the South China Sea. After an interception between a Chinese J-10 fighter jet and US EP-3 signals reconnaissance plane, the People’s Liberation Army (PLA) released an official statement: “Close-in reconnaissance by U.S. aircraft threatens China’s national security, harms Sino-U.S. maritime and air military safety, endangers the personal safety of both sides’ pilots and is the root cause of unexpected incidents.”6 President Trump’s initial meeting with PRC president Xi Jinping excited many who believed Pres. Barack Obama had failed in his Pivot to Asia policy. Amid a series of trade wars and rhetoric, modern tensions between the United States and PRC may have reached a historic highpoint. US accusations of Chinese espionage and the May 2019 blacklisting of Chinese tech company Huawei has caused deeper mistrust between the two nations. A recent PRC travel warning, issued to Chinese citizens in the United States, about mass shootings comes as a sign of defiance and anger against the White House. Finally, China’s recent claim that the United States is responsible for anti-Beijing protests in Hong Kong is reminiscent of the past, coming only a few days after the thirtieth anniversary of the Tiananmen Square protests of 1989.7 In short, the Sino-American relationship is fraught, and while the tensions have been managed thus far, there is still the potential for a small incident to escalate into a larger crisis.

Politicians from the United States and China are not effectively communicating with each other, despite the potential of undesirable consequences due to misunderstanding. It is critical to remember that even one seemingly small miscommunication could cause large-scale ramifications, especially under the stress of a continuing trade war. Military or political mix-ups from poor signaling could trigger hostilities and strain strategic deterrence with China. If signaling and deterrence fail, the world could anticipate an aggravation of force in five particular hotspot areas.8 Unsettling hotspots include the South China Sea (SCS), northeast India, the Taiwan Strait, space, and cyberspace. Some of these hotspot zones include two or more nuclear-armed nations—additional motivation to not allow strategic deterrence to deteriorate.

Deterrence Strategy

Deterrence is a psychological strategy that seeks to decisively influence the decision-making process of the adversary. Put simply, deterrence prevents aggressive action from the adversary by making the adversary believe that the negative consequences of their action will outweigh any benefit while mitigating the consequences of restraint, so that restraint is the least bad option.9 Deterrence is most effective when strategies are tailored to best fit a particular adversary and one side can “get into the head” of the other side. This can mean the difference between deterrence and disaster. An effective deterrence strategy influences the “cost-and-benefit” decision analysis in the mind of the adversary.10 Clarity and credibility of the United States’ signals to the PRC are essential to influence the decision maker in order for deterrence to function properly.11

Deterrence strategies require effective communication to decisively influence the adversary, where communication is defined as both words and/or actions. For communication to be effective in a deterrent strategy, an actor must send a message or signal, it must be received by the adversary, interpreted as intended by the sender, and perceived as credible by the adversary (fig. 1). There are many opportunities for communication to break down in this process.12

Figure 1: Communication requirements for deterrence

Communication can be more straightforward among those who speak the same language and share the same culture; however, differences in language, culture, and history can greatly affect the ability to communicate effectively. The United States and China have vastly different languages and cultures, which directly impacts the effectiveness of communication between both nations, increasing the probability of miscommunication or a failure of signaling. As a result, the United States has a difficult time anticipating the actions of PRC leaders when their decision-making process does not follow the same behavior patterns as employed in the West.13

Deterrence is a key component of the United States’ NSS, which means improving the US ability to effectively communicate with China is imperative. In the recent past, the United States has faced difficulty deterring PRC aggression, which is the direct result of communication errors. Because communication is vital for effective deterrence strategies, the United States must improve its communication issues with the PRC to achieve its national security strategy. If the United States fails to do this, a new strategy will be needed—one likely to involve war and escalation of violence.

Historical Case Studies

The Korean War

Although the United States does not have an extensive history of comprehensive dialogues with the PRC, the two nations do have a history of fateful miscommunications. In fact, the failure of effective signaling has occurred between the United States and China on multiple occasions. In 1950, just one year after the creation of a communist state in China, the North Korean People’s Army (NKPA) crossed the 38th parallel in an attempt to unify with South Korea under a communist government, triggering the Korean War.14 The United Nations (UN) forces pushed the NKPA back across the 38th parallel and deep into North Korea. The PRC leader, Mao Zedong, was concerned about potential “armed aggression against Chinese territory.” Officials in China attempted to signal to UN forces by “relaying messages to the United States through Indian diplomatic channels.”15 Records indicate that UN forces did not receive these messages and continued to push the NKPA back into North Korea. As a result of the failure of communication, China believed the UN forces might continue to push into the PRC and threaten Chinese sovereignty. The resulting Chinese involvement in the Korean War occurred due to the failure of UN forces to receive the PRC’s message (fig. 2). The PRC sent massive waves of PLA troops into North Korea, pushing UN forces back across the 38th parallel.16

Figure 2: Failure to communicate—message not received

After Chinese involvement, the war began to stall as communist troops lacked sufficient weapons or tactics to defeat the combined firepower of the UN. From the end of 1951 until 1953, UN negotiators attempted to bring the war to an end, yet again, failure to communicate dashed hopes of “ending the war and being home by Christmas.”17 Although the war had dulled, the PLA and NKPA refused to answer UN communications and continued to invade South Korea, suffering heavy losses. By 1951, Lt Gen William Harrison Jr., US Army, and North Korean general Nam II had already begun peace talks; however, progress was extremely slow. The communist forces refused to continue the talks due to concerns over repatriating prisoners of war (POW). The communists had captured 10,000 UN POWs, while the UN forces held 150,000 POWs. Many of the PLA prisoners were former soldiers of the Chinese Nationalist Movement, who refused to return home to a communist regime.18 This was an embarrassment to the communist forces and led to a halt in armistice talks between UN and communist forces. Military leaders of the PLA and NKPA were impossible to signal, resulting in the extension of the war and hundreds of thousands of unwanted deaths. Ultimately, the Chinese and UN forces suffered an estimated 900,000 and 58,000 casualties respectively. If communications had continued after initial talks, it is probable that an armistice would have been reached months or years prior to July 1953, saving hundreds of thousands of lives.19

The Rebalance to Asia

In 2009, President Obama desired to continue the favorable relationship with China that was fostered under the preceding Bush administration.20 During his first year as president, Obama announced that his administration welcomed the PRC’s emergence as a global power and that the new US policy would include strategic reassurance toward China.21 The PRC interpreted this strategic reassurance as a shift in US policy toward Taiwan and the SCS. The PRC therefore demanded that the United States cease its weapons sales to Taiwan and halt military surveillance of the SCS. When Obama refused, the Chinese believed the United States had lied to them. The PRC did not fully understand US intentions behind the strategic reassurance, through which, China was expected to reassure the US in return.22 (fig. 3).

Figure 3: Failure to communicate—message not interpreted as intended

In 2013, President Obama announced a new Pacific foreign policy focus. Obama, who once referred to himself as the Pacific president, believed that the United States had ignored the PRC and other nations in East Asia.23 The PRC, having survived the 2008 economic recession relatively unscathed, was rapidly expanding its economic growth outside of China’s borders. Realizing that Asia and the PRC would soon be the largest base for middle class consumers, President Obama wanted to expand trade with the PRC. “In an interconnected world, power does not need to be a zero-sum game, and nations need not fear the success of another. Cultivating spheres of cooperation—not competing spheres of influence—will lead to progress in the Asia Pacific.”24

Unfortunately, President Obama’s objectives for his rebalancing campaign were once again unclear to the Chinese. Territorial disputes in the SCS increased hostilities between the PRC and its neighbors. China interpreted the US rebalance as an attempt to contain China to prevent its rise.25 This was due in part to the US refusal to remove troops from Japan and South Korea, despite troop reductions and removals from Iraq and Afghanistan. Mistrust from the Chinese was reinforced when the US military touted its partnerships with nations like Vietnam, Laos, and Burma. President Obama desired to shift military focus away from issues in the Middle East and instead “pivot to Asia.”26 This pivot, instead did little to slow PRC expansion and fostered deeper mistrust between the United States and the PRC. The United States failed to effectively communicate with the PRC its goals for Obama’s rebalancing of Asia. The lack of clear goals for the rebalancing initiative caused China to believe the United States was intentionally lying to gain an unfair military advantage over the PRC (fig. 4).27

Figure 4: Failure to communicate—message not believed by adversary

Why Do the United States and China Struggle to Communicate?

The aforementioned examples are simply two of the many instances in which the United States and the PRC have failed to communicate effectively. Although the United States and the PRC have worked to learn from those signaling errors, challenges still remain. Among the most significant, but less understood challenges are the vast cultural differences between China and the West. Western–Chinese business relationships can be cited as an example of how both cultures approach conflict management. Conflict management, which directly applies to military de-escalation, is the process of limiting negative aspects of a conflict while increasing positive aspects of a conflict. As observed in a 2001 study on differences in conflict-avoiding, “one of the most commonly cited issues in cases about foreign companies in joint ventures with Chinese companies is differences in how conflict is managed and, in particular, a Chinese tendency to avoid conflict.”28 The way people act in situations of conflict is often based on their deeply held values. This means that cultural behavior in times of conflict is unlikely to be altered by an outside influence. More specifically of the Chinese culture, “Western managers report great frustration when their Chinese colleagues do not approach differences openly and directly.”29

The miscommunications in the business or military spheres of influence, however, is not always for a lack of effort. The PRC and the United States already have an emergency telephone link, the Defense Telephone Link (DTL), between the two military forces.30 Although the DTL does provide quick communication if desired, the Chinese can simply refuse a call from the US Armed Forces. When the phones are answered during a tense military situation, additional problems remain. Military hotlines limit some actions during a time of crisis. Without a political hotline, it is unlikely that the PLA will make quick and strategic military action without the approval of the Chinese Communist Party or the Central Military Commission. A possibility also remains that the PLA may mistrust the DTL in a time of crisis, believing that the Americans are lying to gain a military strategic advantage.

There is also the possibility that signals are received under the proper conditions, yet the message is lost in translation. The vast differences between the English and Chinese-Mandarin languages can pose difficulties. Mandarin is often spoken by the Chinese in a poetic or metaphoric tone. Chinese translations into English are not always straightforward and comprehensive. “The precision of a language is intended to denote is the quality of clarity between an object and relation . . . the precision of Mandarin differs from that of English.”31 This means an experienced translator and a well-trained interpreter may still misinterpret a message from the PRC, as different metaphors hold varying meanings for each individual. Such metaphorical or poetic transmissions will complicate government signaling and increase the probability of communication failure.

Methods to Improve Communications

While communication with the PRC may be difficult day to day and dangerous during a conflict, all is not lost. Reconnecting and restructuring ways to improve communication is possible, and doing so is the best way to increase the credibility of deterrent strategies. The United States and the PRC have a number of options to curb future signaling errors from happening. Some of these options are bilateral, and others the United States can perfect unilaterally. Listed below are four potential methods for improving communication and signaling between the United States and the PRC. These methods directly benefit military communications but are not limited to success in the military domain alone. These methods are listed in order of least complex to more complex. These proposed methods also build on each other to increase the likelihood of progress.

A Glossary of Terms

In efforts to improve the interpretation of military signaling, the US Armed Forces and the PLA should cooperate to build a linguistic glossary of agreed upon definitions of key words and phrases. Although this may sound like a simple or insignificant project, the implications of establishing a rule-based system to define words is foundational to communication. First, a glossary of terms will help translators to prevent confusion among dialects or colloquialisms. Slang words and metaphoric phrases between military and political leaders would have a set definition. This will mitigate some of the difficulties of translating between English and Mandarin. A set list of agreed upon terms mitigates unfavorable decision making based on misunderstanding or mistranslation. The glossary would be the best way to define words and key phrases concretely. For example, if a glossary of terms had defined what President Obama’s rebalance had meant, the PRC’s distrust of the Pivot to Asia could have been largely mitigated.

Secondly, building a glossary of terms of military acronyms and political key phrases, while tedious, would ensure that both nations engage in dialogue. Advisors and editors of the glossary would likely have to meet together in person on multiple occasions, again increasing face-to-face interaction between the two nations and dispelling preconceived stereotypes of each other. This would have the added benefit of potentially building trust and closer relationships. Even if commanders and politicians only use the glossary to double-check seemingly unclear communications, the glossary of terms would be a success.

Better Trained Linguists

Although the military and political leaders have identified the need for more Mandarin-speaking interpreters, greater effort to expand general knowledge of the Chinese language within the US government and Armed Forces should be a priority. Military interpreters attend the Defense Language Institute–Foreign Language Center in Monterey, California, however, there may not exist enough language specialists in Mandarin Chinese. The US military should invest in more Mandarin interpreters and more interpreters who specialize in Chinese customs and courtesies. In addition, the common signaling errors with the PLA needs increased emphasis when training linguists. Linguists who are well versed in Chinese idioms or metaphors should be able to prevent miscommunication if the PLA uses such language.

Students at the Defense Language Institute Foreign Language Center who are studying Chinese can also practice calligraphy as an extracurricular activity. As one of the oldest written scripts in the world, Chinese characters remain in use today. Calligraphy, which is thousands of years old, is still widely taught and practiced, opening a window for students to be more exposed to Chinese culture. (U.S. Army photo by Patrick Bray/Released)

Figure 5: US military linguists in training. Students at the Defense Language Institute–Foreign Language Center who are studying Chinese can also practice calligraphy as an extracurricular activity. As one of the oldest written scripts in the world, Chinese characters remain in use today. Calligraphy, which is thousands of years old, is still widely taught and practiced, opening a window for students to be more exposed to Chinese culture. (US Army photo by Patrick Bray)


An initiative to increase the number of highly trained interpreters should not be restricted only to the military. Politicians in direct contact with the PRC would no doubt also benefit from Chinese lingual experts. Due to the poetic style of Mandarin, better trained interpreters are an essential part in limiting signaling misinterpretations. In a similar light, the PRC should encourage its linguists to improve their understanding of American English. Potential study exchanges could also enhance each other’s knowledge of different cultures. The enhanced training of linguists is also something the United States can do unilaterally, regardless of the PRC’s willingness to participate. Furthermore, the previously described glossary of agreeable language terms should also be made known to, if not written by, these expert linguists.

Text-Message Hotline

Although military and space hotlines currently exist between the United States and the PRC, they have seen limited success. In 2008, Pres. George W. Bush and Pres. Hu Jintao agreed that a 24-hour phone line should be established between the two militaries. An additional space hotline, used to prevent “potential satellite collisions, approaches, or tests from escalating to dangerous situations,” was installed in 2015.32 Both hotlines have been praised as means to prevent escalation during a crisis, yet the hotline-phone systems are not fulfilling their intended purpose. During the Obama administration, the Chinese cut the hotline-link on two different occasions. In protest to US actions in the SCS, the Chinese cut the phone line—ironically, during a time when the hotline system could have been most useful. It is also common for calls to the PRC to go unanswered.33 This is due, in part, to the command structure of the PLA.34 In the PLA, “no one person, wherever that person sits, even if that person is [Pres.] Xi Jinping, can make a decision by themselves.”35 As such, a Chinese official can answer the hotline but is authorized to do little more than take a message and relay it through the proper channels for a decision to be made. Imagine if you will, the potential errors and miscommunications that could arise from a Chinese official quickly scribbling down a message in a foreign language from a foreign military or political leader in a time of crisis. The message in such a hypothetical situation would certainly include important details like who the message is intended for, what needs to be communicated, how quickly a response is should be, to whom should the call be returned, and so forth. This process is unfortunately like a children’s game of telephone, in which the message becomes increasingly distorted from one person to another.

As previously mentioned, assuring that the adversary receives the message and that the message is interpreted as intended are vital pieces of the communication requirements for deterrence. The United States can assure that messages are received by the PRC through the means of a text-messaging system. A simple computer monitor designed to receive military and political signals could display the messages to the PRC in writing. Messages would be transmitted in a standardized form, displaying the information of who, what, where, why and, how in an organized fashion. The Chinese official receiving the message simply has to print the form and present it to the decision-making authority. A written message in this manner eliminates the game of telephone and prevents the possibility of message distortion. The proposed form, after frequent use, would also become familiar to both the United States and the PRC, further promoting transparency and formalized communication. This text-message system would use the aforementioned glossary of terms to assure that transmissions are precise and consistent. This suggested system guarantees that the message reaches the PRC and increases the probability that it is interpreted correctly. With the text-messaging system, miscommunication becomes a nonsensical excuse for either side to claim.

Memorandums of Understanding

The United States and the PRC should both express willingness to pursue agreeable measures to prevent the escalation of violence. A memorandum of understanding (MOU) is a written agreement by two or more parties to outline acceptable practices. Although MOUs cannot erase the possibility of a US–Chinese crisis, such agreements are a great place to start when a crisis ultimately occurs. MOUs between the US and former-Soviet navies avoided collisions and prevented naval attack simulations since the Cuban Missile Crisis of 1962.36 If a US–Soviet naval collision had occurred during the Cold War, US and Soviet sailors would have followed MOU procedures to de-escalate the situation. MOUs essentially serve as a checklist for military commanders to follow in times of emergency. The mitigation of a military crisis before it occurs, instead of during the event, removes the stress of anticipating what the enemy will do next. If both sides follow MOUs during an emergency, the escalation of violence is preventable and the hotline system will not be needed. MOUs not only prepare commanders during stressful situations, they can also calm the tempers of politicians in situations like the 2001 Hainan Island hostage situation. Although some MOUs currently exist with the PRC, additional MOUs are needed to prevent miscommunication.

In 2015, presidents Obama and Xi agreed on terms for air-to-air intercepts, addressing “the correct radio frequencies and the wrong physical behaviors to use during crises.”37 Without an MOU, a military crisis naturally becomes more stressful, as agitated troops stand by their weapons in anticipation and sometimes fear.38 MOUs improve communication by providing a crisis-solution handbook in which both parties can trust and believe. MOUs for air, land, sea, space, and cyberspace domains will allow commanders to resolve issues at the lowest possible level, while also removing a commander’s ability to unintentionally escalate a crisis. Also notable is the time and effort needed to draft multiple MOU documents. Writing MOUs require the presence of highly trained linguists and an agreeable glossary of terms. Again, several in-person MOUs meetings would further the teamwork and cooperation of both nations. Additional MOUs with the PRC will keep people safe and improve the communication and trust between soldiers, sailors, and airmen of both nations.


The former Chinese “junkyard” military is now a robust conventional and nuclear-capable antagonist, and as such, the United States should expect and prepare to compete with and deter aggressive PRC actions for the foreseeable future. The United States and the PRC have an unfortunate history of miscommunication; however, the mistakes of the past can be prevented from happening again. Effective communication with the PRC is essential for strategic deterrence to function. As such, the United States must employ new methods to fix its signaling capability with the PRC before tensions escalate. There is no doubt that friction will occur in the future of the US–PRC relationship, yet with effective communication, the United States and the PRC can limit unwanted escalation in coming decades of international competition. In addition, the efforts expended to develop ways to mitigate communication errors may have the secondary benefit of increasing trust between the United State and the PRC. Strategic deterrence is not a new strategy but is extremely complex due to the psychological nature of deterrence. As such, effective communication is the cornerstone of any deterrence strategy.

Cadet Myles Arenson

Cadet Arenson is a first-class cadet at the United States Air Force Academy in Cadet Squadron 16, majoring in history and minoring in German. Cadet Arenson wrote this submission after conducting research with the J55 Plans and Policy Division at the United States Strategic Command in June and July of 2019. After graduation in May 2020, Cadet Arenson plans to pursue a career in Air Force intelligence.




1 I wish to thank my advisor and instructor, Ms. Jennifer Bradley, whose sincere and thoughtful suggestions have directed the formation of my article. I greatly appreciate her guidance and patience in this process. All errors found herein are my own.

2 Office of the White House, National Security Strategy (Washington: White House, 2017) 8.

3 Department of Defense, National Defense Strategy (Washington: DOD, 2018), 4.

4 Ibid., 2.

5 “U.S. Relations with China: 1949–2019,” Council on Foreign Relations, 10 May 2019,

6 Idrees Ali, “Chinese Jets Intercept U.S. Surveillance Plane,” Reuters, 24, July 2017,

7 Heilier Cheung, “China Media: Hong Kong Protests,” BBC News, 10 June 2019,

8 David Forman, “Deterrence with China: Avoiding Nuclear Miscalculation,” Eurasia Review, 13 November 2014,

9 Jennifer Bradley, “Increasing Uncertainty: The Dangers of Relying on Conventional Forces for Nuclear Deterrence,” Air & Space Power Journal 29, no 4 (July–August 2015), 72,

10 Ibid., 73.

11 Ibid.

12 Keith Payne, The Fallacies of Cold War Deterrence and a New Direction (Lexington: University of Kentucky Press, 2001), 38–40.

13 Elaine Bunn, “Can Deterrence be Tailored?” Strategic Forum 225 (January 2007), 1–2.

14 William Stueck, The Korean War: An International History (New Jersey: Princeton University Press, 1995), 14–17.

15 Richard Stewart, The Korean War: The Chinese Intervention (Washington: US Army Center of Military History: 2003), 3-6

16 Ibid.

17 Ibid.

18 Stueck, The Korean War, 34.

19 Clay Blair, The Forgotten War: America in Korea 1950-53 (New York: Doubleday, 1987), 34–35.

20 “The United States and the Asia-Pacific Region: Security Strategy for the Obama Administration,” Defense Technical Information Center (February 2009), 23.

21 Scott Snyder, “Obama’s Asia Rebalance in His Own Words,” Forbes, 24 November 2014,

22 Stephen J. Blank, Challenges and Opportunities for the Obama Administration in Central Asia (Carlisle, PA: Strategic Studies Institute, US Army War College, 2009),

23 Barack Obama, “Remarks by President Barack Obama at Suntory Hall” (speech, White Office Press Secretary, 14 November 2009).

24 Ibid.

25 Michael E. O’Hanlon, “A Glass Half Full: The Rebalance, Reassurance, and Resolve in the U.S.-China Strategic Relationship,” Brookings Institute, October 2016,

26 Janine Davidson, “The U.S. Pivot to Asia,” American Journal of Chinese Studies 21 (2014): 77–82,

27 Ibid.

28 Ray Friedman, Shu-Cheng Chi, and Leigh Anne Liu, “An Expectancy Model of Chinese-American Differences in Conflict-Avoiding,” Journal of International Business Studies 37, no. 1 (2006): 76–91,

29 Ibid.

30 Jeremy Patterson, “Hotline to Link U.S.-Chinese Militaries,” Arms Control Today, 38, no. 3 (2008): 46–47,

31 George Cheong, “A Cursory Comparison between Chinese and English on Precision,” Elementary English 49, no. 3 (1972): 341–48,

32 John Garnaut, “We Value Your Call: US and China Test Hotline,” Sunday Morning Herald (Australia), 4 April 2013,

33 Ibid.

34 Mingjiang Li, “The People’s Liberation Army and China’s Smart Power Quandary in Southeast Asia,” Journal of Strategic Studies 38, no. 3 (2015): 362–65,

35 Garnaut, “We Value Your Call.”

36 “Agreement between the Government of the United States of America and the Government of the Union of Soviet Socialist Republics on the Prevention of Incidents on and over the High Seas” (Bureau of International Security and Nonproliferation, Department of State, 1972), article III.

37 Phil Stewart, “U.S., China Agree on Rules for Air-to-Air Military Encounters,” Reuters, 25 September 2015,

38 Ibid.



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