Daniel Arthur Laprès
Avocat au Barreau de Paris
Barrister & Solicitor (Nova Scotia)
222 blvd Saint-Germain - 75007 Paris France
Tel: (33)-01.53.32.50.77 - Fax: (33)-01.45.26.81.35
web site: www.lapres.net - e-mail: email@example.com
Adrian Zenz, “Wash Brains, Cleanse Hearts”: Evidence from Chinese Government Documents about the Nature and Extent of Xinjiang’s Extrajudicial Internment Campaign, Journal of Political Risk, Vol. 7, No. 11, November 2019
1. - Introduction
The proposition advanced by Adrian Zenz that is the subject of this review is the following:
Overall, the author suggests a new speculative upper limit estimate of 1.8 million or 15.4 percent of adult members of Xinjiang’s Turkic and Hui ethnic minority groups, and a new minimum estimate of 900,000 or 7.7 percent. These figures pertain to all minority adults in previous (since spring 2017) or current extrajudicial internment. While still speculative, the new upper limit is eminently defensible based on existing and new data sets. (Emphasis added)
Zenz’s use of the word “speculative” is not consistent since elsewhere in the same article he qualifies his estimates as “eminently realistic” and “appropriate”.
As a matter of observation, Zenz’s estimates are generally relied upon by commentators and policy-makers in Western countries. They are challenged by, inter alia, the Chinese Government and media as well as a few doubters in the West.
The point of this review is to evaluate the reliability of Zenz’s proposition.
This review does not address Zenz’s charge that the Chinese Government has committed genocide in Xinjiang, which he advances in another article. However, any doubts about Zenz’s credibility as to his charge of 1.87 million Muslim minority people being held in “extrajudicial internment” would of course affect one’s attitude toward his “genocide” charge.
This review does not concern any other aspects of the Chinese Government’s policies, such as toward Hong Kong or Taiwan, or in the South China Sea, or as regards treatment of political dissidents or the faithful of underground religious groups.
The conclusion reached here, namely that Zenz’s estimates of the number of Muslim minority people held in Xinjiang in “extrajudicial” detainees are not reliable, should incite decision-makers to study more carefully the claims of mistreatment in Xinjiang.
The conclusion reached here does not deny the existence, even widespread, of such mistreatments.
While the mistreatment of even one person is a cause for concern, the appropriate reaction does after all vary depending on the scope and the extent of the mistreatments, hence partly on the number of mistreated.
Which is, of course, why it would be in the interest of critics of the Chinese Government from all angles to inflate the number of detainees in Xinjiang to serve their own special objectives.
Therefore, to call Zenz to account for exaggerating the number of detainees will serve to adjust the reactions of decision-makers on this question to a proportionate level.
Also, Zenz invokes the status of academic and researcher to buttress his claims. His articles are presented in what is purported to be an academic context. For instance, Zenz emphasizes that his articles are “peer-reviewed”.
It is therefore appropriate that Zenz’s theses be submitted to scrutiny according to academic standards, which his article does not meet, as will be demonstrated below.
Sources other than Zenz have advanced estimates of the number of sites in Xinjiang where Muslim minority people are held against their will to undergo “re-education”. For instance, as discussed below, the Australian Strategic Planning Institute and journalists of Buzzfeed, upon examination of satellite photos, have advanced estimates of the number of facilities corresponding to mere fractions of Zenz’s estimate (some 27, and more recently 380 by the former, and some 250 by the latter). Not only may those estimates may be questioned as per below, they do not in any case advance any estimates of the number of people actually held in “extrajudicial” internment.
In the end, Zenz appears to be the source upon whom all others rely to advance estimates of the number of Muslim detainees in “extrajudicial“ internment.
Hence the importance of examining the reliability of his estimates, as undertaken below.
2. - What does Zenz mean by “extrajudicial internment”?
Zenz’s use of “extrajudicial internment” as his criterion for identifying those whose detention he is challenging is improper, and therefore the estimates that apply such an improper criterion are also objectionable.
2.1. - Which persons should be considered as being subject to “extrajudicial internment”?
According to Zenz, those in “extrajudicial internment” are those designated in the Chinese official documents as “three kinds of individuals” “3类人员”.
But, “3类人员” is defined in the official sources cited by Zenz himself as referring to : “收押、判刑和’三学’人员（以下简称‘三类’人员）” i.e. those in preventive custody (pending trial on criminal charges), those convicted on criminal charges and sentenced to internment and the so-called “三学”, who are considered to be interned in “work-education camps” without any legal procedure being brought against them to impute criminal liability.
Thus Zenz includes in his estimates of people in “extrajudicial internment” those who are in “custody pending trial” (收押).
That inclusion may serve to inflate Zenz’s estimates of his numbers, but its appropriateness is hardly beyond question.
Zenz himself writes that “detention centers” (看守所) are
part of the formal criminal justice system throughout China for the temporary detention of criminal suspects ( 临时羁押犯罪嫌疑人场所) while the state determines whether to press formal charges.
Also, people held in “custody pending trial” in China do have rights under the Criminal Procedure Law. Whether those rights meet international or Western standards generally or those of any other country in particular, as well as whether they are effectively respected in China, and as regards specifically the Muslim minorities in Xinjiang, may all be questions worthy of inquiry.
Still, persons “held in custody pending trial on accusations of criminal conduct” ought not to be included in estimates of people being detained against their will for no reason other than their belonging to a specific minority ethnic group, which is actually Zenz’s target of criticism.
This linguistic slippage by Zenz has transversal consequences for the reliability of his estimates.
For instance, when considering the declarations of a witness speaking of a site of internment or in examining an aerial photo of such a site, buildings that are walled off and guarded might well be occupied by convicted criminals as well as suspects pending trial. This distinction is all the more important in practice because the sites identified by Zenz contain some buildings that are walled in and others that are not.
So Zenz’s use of the criterion “extrajudicial internment” to delimit the scope of all those whose internment is objectionable generates ambiguities and misunderstandings.
A criterion more suited to the actual target of his objections would seek to identify those in “work-education camps”, that is to say the “三学人员”.
But even then, Zenz does not make clear whether he considers that all “三学人员” are subject to “internment”.
Nor does Zenz make clear whether the population in what he identifies as the “work-education” camps is only “三学人员” or includes as well those convicted or suspected of crimes as well, and to whom education and training are being administered.
If the latter scenario were to be the case, then the observation that some such camps look like prisons would be understandable and quite normal. In such a scenario, the debate would be more usefully focused on the abuse of the criminal system to oppress the Muslim minorities and the disproportion in mixing people subject to the criminal system with those not accused or convicted of any crime.
To put it differently, it is not clear whether Zenz considers that all convicts and criminal suspects in detention are placed in the camps he identifies as implementing “extrajudicial internment” or do there continue to exist prisons for convicts and detention centers for suspects. If there continue to exist prisons and detention centers, then it would be useful to have some idea of what percentages of each of those categories go for “work-education” to the camps identified by Zenz as implementing “extrajudicial internment”.
In short, who exactly are included in Zenz’s estimates is unclear, though in each case the ambiguity generates an inflation of Zenz’s numbers.
What Zenz might legitimately and, most likely indisputably, object to, namely the internment against their wills of people who are neither convicted of criminal offenses nor accused of such and held in custody pending trial, is not actually the focus of his discussion or his estimates.
In this first regard then, Zenz’s estimates are unreliable and inaccurate.
2.2. - Which sites should be considered as implementing “extrajudicial internment”?
Zenz identifies eight categories of what (I will call) “sites” as implementing ““extrajudicial internment”:
1. Centralized transformation through education training centers (集中教育转化培训中心)
2. De-extremification transformation through education bases (去极端化教育转化基地)
3. Transformation through education and correction centers ( 教育转化及矫治中心)
4. Legal system schools or legal system training schools (法制学校 or 法制培训学校)
5. Legal system transformation through education centers (司法局教育转化培训中心)
6. Centralized closed education training centers (集中封闭教育培训中心)
7. Vocational skills education training centers (职业技能教育培训中心), or educational training centers (教育培训中心), with the latter presumably representing a short form of the former，referred to in this article as VTICs,
8. Detention centers (看守所).
But Zenz also states that sites in category 4
are not VTICs because in Xinjiang (VTICs) can typically be distinguished from other vocational facilities by the ending “center” (中心). If a facility or institution ends with the word “school”, as in “Vocational Skills School” (职业技术学校), then it is typically not a VTIC.
Does this mean that sites in Category 4 do not implement “internment” (of any kind)?
According to Zenz, in some cases they do:
Of particular concern is the fact that at least some facilities that used to be regular vocational training “schools” ( 学校), and that continue to bear innocuous naming designations, appear to also function as internment facilities. Examples include the vocational schools in Urumqi and Aksu that were mentioned above ».
But, in other cases not:
A government notice from Akdöngjemi Village (阿克墩结米村) in Sëriqbuya Township (色力布亚镇), Maralbexi (Bachu) County about political and social control work in villages mentions the use of the 4th re-education facility on the list: “strengthen re-education, send focus persons and daily management persons in separate batches to the township legal system training school ( 法制培训学校) to implement transformation through education.”
supposing that “daily management persons” might be allowed to go home overnight.
In short, Zenz takes into account in his estimates as implementing “extrajudicial internment” sites which should not be included because he himself recognizes that they are “part of the criminal justice system” (“看守所) as well as sites where not all the “students” should be considered as interned (at least some of those designated as 学校).
Zenz’s range of sites considered to be implementing “extrajudicial internment” is thus not only unclear, and to that extent unreliable, it also too wide, by his own definitions, and his estimates of persons in “extrajudicial internment” are necessarily exaggerated.
3. - Zenz’s sources
Zenz claims to rely on the Chinese “government’s own statements”.
More specifically, Zenz says he “analyzed three types of data sources”:
· “official government documents and related media reports that are publicly accessible but not designed for international audiences”,
· “local government data in the form of detailed tables and spreadsheets that list the fates of thousands of minority individuals” and
· “a confidential, classified Chinese policy document issued by the Xinjiang Uyghur Autonomous Region’s Party Political and Legal Affairs Committee (the “Confidential Classified Document”).
As will appear below, the “official government documents” and “local government data” are rarely identified by name, the links to the sites where the elements might be found on the internet frequently do not work, the copies advanced by Zenz often do not bear marks that would tie them to the Chinese Government, the original Chinese language texts are rarely quoted, and, when they are, Zenz’s translations are sometimes questionable.
The Confidential, Classified Document is said to have been issued by the Xinjiang Uyghur Autonomous Region’s Party Political and Legal Affairs Committee”.
This document details how Xinjiang’s so-called “vocational training centers” are supposed to be run”.
According to Zenz,
This classified document was passed to Uyghurs in exile from a source in Xinjiang, and then directly passed to the author. Its authenticity has been independently verified by several linguists and Xinjiang experts. Based on his experience and through comparison with numerous other government sources, the author likewise considers the language, formatting, and contents of this document to be indicative of its authenticity.
Zenz does not identify in this article who were the “Uyghurs in exile”.
But, the reliability of the Confidential, Classified Document does after all depend somewhat on how Zenz obtained it.
In an earlier article, Zenz cited information from a “Uyghur exile media organization based in Istanbul”.
The Associated Press has reported that since “2013, thousands of Uighurs… have traveled to Syria to train with the Uighur militant group Turkistan Islamic Party and fight alongside al-Qaida,” with “several hundred join[ing] the Islamic State.”
Also, while Zenz states that the document’s “authenticity has been independently verified by several linguists and Xinjiang experts”, he does not identify those “experts”, or produce any written evidence of their assessments and conclusions.
Finally, Zenz attaches importance to the “peer review” that would have been undertaken by the Journal of Political Risk that has published his articles. That Journal was founded in May 2013, and it is published by Dr. Anders Corr/Corr Analytics Inc. Its management team appears to be reputable and generally competent, but does not appear to claim any expertise in Chinese or Uyghur affairs. Since its founding, the Journal itself has published only three articles on China (other than Zenz’s).
Basically, Zenz is asking the reader to trust in the reliability of the “Confidential, Classified Document” without providing any objective reason for anyone to do so.
4. - Zenz’s count of detainees in “extrajudicial internment”
Zenz advances several lines of reasoning to justify his estimate of the number of Muslim minority people in “extrajudicial internment”.
3.1. - Estimate based on the number of extrajudicial internment camps
Relying upon the Confidential, Classified Document, Zenz claims that there are between 1,300 and 1,400 “extrajudicial internment facilities” in Xinjiang.
First, Zenz includes in this number some “119 detention centers”, that is “one per administrative unit above the township level” and opines that “likely there are more than that”.
But, in so far as Zenz himself has recognized that “detention centers” (“看守所) are “part of the criminal justice system”, any such sites, whatever their number, should not be considered as “extrajudicial internment facilities”.
Regarding the remaining 1,200 alleged sites of “extrajudicial internment”’, Zenz observes that
The classiﬁed document mandates that every region (prefecture) and county (or city) must establish a “VTIC leadership small group” (职业技能教育培训领导⼩ - zhiye jineng jiaoyu peixun lingdao xiaozu), which is to be headed by the county committee party secretary.
According to Zenz,
Xinjiang has a total of 119 city-level, prefectural and county-level administrative units, along with 1,079 township-level administrative units. If each county and township had just one re-education center or VTIC, the region’s camp network would number around 1,200 facilities.
Zenz does not claim to be quoting the exact language used in the Confidential, Classified Document.
He is apparently assuming that for each “VTIC leadership small group”, there is necessarily at least one extrajudicial internment center. But, he provides no information that would justify that assumption.
Also, according to his own interpretation, the number of “extrajudicial internment” sites would correspond to 119, i.e. one for “every region (prefecture) and county (or city)” to which should be added 1,079 “township-level administrative units”, that is some 1,200 camps in all.
But that the “township-level administrative units” are not mentioned in the Confidential, Classified Document as Zenz himself is quoting it.
So the inclusion by Zenz in his count of those administrative units where extrajudicial internment sites are to be established of 1,079 of “township-level administrative units” is dubious.
Zenz is apparently assuming “prefectures” and “counties” are situated at an equal level in the Chinese administrative structure.
In such a case, it might be reasonable to imagine that “the classiﬁed document” provides that every region (prefecture) and county (or city) should establish its own “VTIC leadership small group”. (emphasis added)
But, actually, prefectures are second-level units within a Province, and counties are a third level, subsumed under prefectures.
For example, Urumqi is a prefecture-level city, and under its jurisdiction, there is a county named Urumqi.
So, it is not clear how the Confidential, Classified Document could be interpreted as mandating the establishment of two extrajudicial internment sites, one in each of “Urumqi city-level prefecture sub-division” and another in the “county of Urumqi” within that city.
In short, despite Zenz’s omission to disclose the exact language in the alleged Confidential, Classified Document, it does appear that his interpretation of the language, as he himself presents it, entails double counting of the mandate to establish “extrajudicial internment” sites.
Either the number of such sites mandated would correspond to the number of prefecture-level sub-divisions (14) or the number of county-level sub-divisions (106), but not to the sum of the two.
Another technique used by Zenz to estimate the number of people in “extrajudicial internment” is to extrapolate from evidence in single villages.
To justify his inference that each “township-level administrative unit” would establish a VTIC, Zenz cites two other sources.
which obviously precedes by several years the inception of the VTICs. Furthermore, the report concerns “教育转化基地” which seem more like schools, than detention centers. Finally, according to the report, 88% of the inhabitants of the village had received “re-education” (“教育转化率88%”), which percentage suggests by its magnitude that it refers to all forms of “ training” as internment of 88% of any population is prima facie implausible.
Secondly, Zenz refers to a “spreadsheet completed by the Alslan Bagh Township (阿尔斯兰巴格乡) government in Yarkand (Shache) County, Kashgar Prefecture” that discusses a “system of VTICs and/or re-education camps in at least each township and urban district”. Document. But the source he cites as “Source reference code: 18204”, but the actual document is not revealed and no other method to verify its contents is stated.
Thirdly, Zenz cites a letter of February 20, 2018 to a county government, which he alleges contains a complaint about a “serious lack of cadres because they have been deployed to the VTICs”. But, in that letter, there is this sentence explaining one of several challenges in the management of schools is that many local cadres have been affected to what Zenz considers to be extrajudicial internment camps:
But, this point does not suggest that there are extrajudicial internment camps in every township, only that township-level cadres have been affected to such camps (whatever be their number and location).
Leaving aside the unreliability of extrapolations from one village out of the 8,834 in Xinjiang, Zenz in many cases does not show the original document containing the information on which he relies (see his footnote numbers 65 “Source reference code: 18204”, 70 “Source reference code: 18305”, 71: “Source reference code: 18761”, 72: “Source reference code: 21963”, and 74: ‘Source reference code: 22735”).
Nor does Zenz always quote the original Chinese language from those documents on which he is relying.
When he does provide the original Chinese, there occur translation errors.
For example, Zenz writes on page 24:
Similarly, in Oyluk Village (乌依鲁克村), Yantak Township, (央塔克乡), Makit (Maigaiti) County (Kashgar Prefecture), “three types of persons” households made up 91 of 456 or 20 percent of all households in 2018.
The associated footnote 73 refers to a document attached to Zenz’s article, which is entitled:
In that document, there is only one reference to “三类人员“。 It does relate to the districts referred to by Zenz. But, here is the content:
This means that in these districts there are 91 “三类人员 (san lei ren yuan)” households that own 455 sheep.
In short, on the above lines of reasoning, Zenz does not justify even remotely his estimate that there exist 1,400 “extrajudicial internment“ sites in Xinjiang.
3.3. - Estimate based on the amounts of Xinjiang Government expenditures
First, Zenz refers to a Xinjiang Government report that welfare payments guaranteeing minimum living standard ( 低保) to families of persons in “education and training persons” - - 教育培训人员) rose 220.6 % between January and July 2018.
It bears mentioning that these payments are stated by Zenz to be made to the “relatives” of detainees, which observation does after all run counter to his accusation of generalized persecution of Muslim minorities in Xinjiang.
According to Zenz, the alleged increase of welfare payments would at least in part be attributable to an increase in the number of people in “extrajudicial internment”.
In fact, the table presented by Zenz refers not to “ 教育培训人员”, but instead to “宗教教职人员“ (zong jiao jiao zhi ren yuan), which might be translated as “persons in religious education and work-education”.
Also, the tables Zenz presents to support his claim show the amounts of payments made in July 2018 but there are no numbers for any other period, so his comparison in unverifiable using the documents he refers to.
What is perhaps more informative is that, of the 15 乡镇 (villages and towns), the payments were made in only 9. As Zenz does not comment this point, it is a matter for speculation whether this would mean that in the remaining six towns/villages, no local inhabitant was in a VTIC.
Secondly, Zenz refers to two sources he had already used in his July 2019 JPR article.
One source is a spreadsheet entitled 表十二：2019年自治区本级一般公共预算政府预算支出经济分类明细表, in short the public budget for autonomous districts.
But, I had previously downloaded the tables while the link in the July JPR article was still active.
The tables themselves bear no markings of the Government。
But supposing the document to be authentic, a table covering “Subsidies from the Autonomous Region to Localities”， there does appear line for ‘职业教育培训中心学员伙食费补助 » corresponding to a total of 1.58 billion RMB, which are allocated as follows:
Yili Prefecture 200 million
Aksu Area 250 million
Kyzyl Suzhou 10 million
Kashgar Area 660 million
Hotan 360 million
Apparently, no such food subsidies were allocated in the other nine prefectures in Xinjiang.
Zenz does not address the question whether the absence of such subsidies in nine prefectures might indicate that there are no VTICs in those areas.
Mr. Zenz concludes on this basis that these subsidies could have sufficed to feed 395,000 people, which presumably is his estimate of a number of detainees in VTICs.
But, Zenz does not detail his calculation.
Obviously, an estimate of 395,000 detainees is less than 50% of Zenz’s lower bound estimate and not even a quarter of his “speculative upper estimate” of 1.87 million detainees.
According to Zenz,
If the cost (and quality) of the food given to VTIC detainee is only half that of the average PLA soldier, which appears more than likely, then that ﬁgure doubles
but even then the result is lower than his own lower bound estimate and less than half his speculative upper estimate”.
Further, Zenz argues that
If detainees were on a very poor diet below common calorie intake requirements for adults, and we assumed a daily food allowance of 4.5 RMB (such as 1.5 RMB per meal with three daily meals), the VTIC detainee ﬁgure could be just below one million.
But that result, even assuming it were an accurate calculation based given Zenz’s own assumptions and methods, remains at about the level his lower estimate of 900,000 detainees and almost 50% below his “speculative upper estimate” of 1.87 million detainees.
Actually, an effort to retro-engineer the calculation using Zenz’s reasoning belies his estimate of about one million detainees in “extrajudicial internment”.
More specifically, it may be noted that Zenz refers to two documents:
1. 中美俄三国军人伙食比比看 解放军设四类灶
[ 2007-07-18 09:14 ]
i.e. a comparison in China Daily of expenses for the Chinese, American and Russian militaries.
The data relate to 2007.
解放军目前的伙食费标准分别为：一类灶每人每天１.１元、二类灶１.３元、三类灶２.３元、四类灶３.９元，(i.e. food expenses would have ranged between 1,1 RMB per day per person or as high as 3.9 RMB depending on the class of the personnel),
2. A web site operated by a Taiwanese meals Management Services Limited Company that is has passed ISO9001: 2000 international certification system for food service businesses. It specializes in the construction and food canteen contractor, canteen kitchen production installation, canteen ingredients distribution, fast food distribution and banquets.
It proposes a range of meals with budgets for a balanced diet.
The budgets range between 8 and 18 RMB per day.
The crucial variable in extrapolating from the food budget to the number of detainees is the cost of the food.
Depending on whether the cost taken is 1.1 RMB per day or 3.9 RMB, the number of people that would be fed over one year varies from 372,322 to 1,320,050, the latter figure would assume a diet of the same cost as that of feeding the lowest-ranked soldier in the People’s Liberation Army in 2007.
If those costs were adjusted for inflation (21.1% over the 2007-2019 period), then the budget could have fed from 310,268 to 1,090,950 people per year.
In short, there is no apparent basis for Zenz’s “speculative upper estimate” of 1.87 million detainees.
3.4. - Estimate based on the “leaked document”
Zenz starts from his previous estimate of 1.06 million people “directly affected by Xinjiang’s extrajudicial internment and re-education drive” as advanced in one of his earlier publications.
In that prior article, Zenz recognizes that: “Unfortunately, there is no official information available on numbers of re-education detainees”.
Zenz then cites “Mizutani, N. 2018”.
Presumably, Zenz is referring to Naoko Mizutani who is a Japanese activist in favor of the Uyghur cause, considered by at least one observer to have been acting “not within an anti-Chinese context”, at least in 2013.
In a Japanese Newsweek article of March 13, 2018, Mizutani reproduces a table originally published by Isteklar TV, which is a “Uyghur exile media organization based in Istanbul”.
According to Zenz, the table was “reportedly leaked from a reliable source within (Xinjiang’s) public security agencies”.
Neither Mizutani nor Zenz produces a copy of the table allegedly published by Isteklar TV.
Mizutani does publish a table that is purported to reproduce the contents of the table published by Isteklar TV.
This table was published in Japanese, though many of the characters could be Chinese.
Mizutani states that she thinks that the information in the table dates from 2017 when the “re-education” program is said to have begun.
According the Mizutani, the table shows the number of “detained” persons.
The table shows numbers relating to 68 subdivisions in Xinjiang.
At the bottom of the column the column entitled “收监人数“，there does appear the number 892,239.
It would seem that the proper translation of “收监人数“ is “imprisoned”.
If that translation is correct, then the table relied upon by Mizutani and Zenz does not provide information on the number of those in “extrajudicial internment”.
In addition, Zenz cites two reports published by Radio Free Asia (a United States government–funded, non-profit international broadcasting corporation):
· Around 120,000 Uyghurs Detained For Political Re- Education in Xinjiang’s Kashgar Prefecture, January 22, 2018,
· Xinjiang Authorities Up Detentions in Uyghur Majority Areas of Ghulja City, March 19, 2018.
According to the first article,
The security chief of Kashgar city’s Chasa township recently told RFA on condition of anonymity that “approximately 120,000” Uyghurs are being held throughout the prefecture, based on information he has received from other area officials.
According to the second article,
· The security chief of No. 2 Village said that 254 residents out of the 1,070 households under his administration—or nearly one member of every four homes—are currently held in re-education camps, and that 62 of them had been taken into custody since March 3.
. . .
The chief said he had “received orders from above” and
was “implementing the requirements demanded by the regional government,” adding
that he was told to attain a quota of detainees, without providing further
. . .
A staff member who answered the phone at Bayanday’s No. 3 Village committee told RFA on condition of anonymity that his office had been instructed to send “10 percent” of the 4,131 residents living in 1,073 households under its supervision to re-education camps
. . .
· Officials in Hotan (Hetian) prefecture’s Qaraqash (Moyu) county earlier told RFA that they had been ordered to send 40 percent of area residents to re-education camps, and said they were having trouble meeting the quota.
From these widely varying reports from one prefecture, one township and two villages, Zenz concludes:
When assuming a Muslim adult internment rate of 10 percent for cities with a majority Muslim population share and of 5 percent for cities where this population share is below 50 percent, Xinjiang's total re-education internment figure may be estimated at just over one million (approx. 1,060,000). (page 28) (Presumably, Zenz actually means prefectures, not cities).
. . .
While there is no certainty, it is reasonable to speculate that the total number of detainees might range anywhere between several hundred thousand and just over one million.
As Zenz provides no table showing the numbers he used to make his calculations, one is left to do that research for oneself.
Using Zenz’s assumptions and his data, it is possible to “retro-engineer” the process to verify his argument that his May 2018
upper limit estimate of 1.06 million persons interned was based on a 10 percent internment share of Uyghur and Kazakh adults aged 20 to 79 years, using data from the 2010 census, and adjusted for population growth between 2010 and 2015 based on updated population figures from the 2015 mini census for Xinjiang.
In Exhibit 11, using the 2010 census and the 2015 census to gross up the numbers from the 2010 census and assuming that the population below 20 years of age corresponds to some 26% of the population, and assuming Zenz’s rates of internment, the total number of detainees would correspond to 780,636, not 1.06 million.
In other words, granting all of Zenz’s assumptions his upper estimate as of his July 2019 JPR article would appear to be overstated by about one third.
But, it takes a great act of faith to accept all Zenz’s assumptions:
· RFA is a US government-owned company, how objective is it really?
· the exact circumstances in which RFA obtained the information it reported are unknown, for example, exactly what questions did RFA ask, was it clear to respondents that they were being asked about those in “extrajudicial internment”?
· did RFA personnel directly conduct the interviews? did RFA identify itself to those whom it was interviewing?
· were those questioned asked about how the persons detained were selected? what were their answers?
· were those interviewed asked for what periods the detainees were held (days, weeks, months)? what were their answers?
· how likely is it that someone answering a telephone call at a detention center would directly discuss with RFA (or anyone else outside the chain of command for that matter) information about the number of detainees in the center?
· since RFA’s sources for the above information, , and even the authors of its articles, are unidentified, how can their reliability be assessed?
Furthermore, Zenz extrapolates from observations in a few villages to the entire Xinjiang Region.
According to a document advanced by Zenz himself, the VTICs received food subsidies in only five of the prefectures: Aksu Area, Kyzyl Suzhou, Kashgar Area, Hotan and Yili. So, if those were the only prefectures where VTICs had been established, then the total of detainees would amount to 635,499 detainees, and that is granting all of Zenz’s other assumptions.
Even granting Zenz his estimate of July 2019 of 1.6 million detainees in “extrajudicial internment”, how does he justify increasing it to 1.8 million by November 2019?
3.5. - Bases for increasing the estimate to 1.8 million detainees in VTICs
Zenz reasons as follows:
The information that has become available since (his previous publication), including the new data presented in this paper, indicate not only that internment shares in regions with a high Turkic minority population range anywhere between 10 to nearly 30 percent; numerous witness accounts indicate that internment shares in regions where Turkic minorities constitute only a small share of the population, such as Karamay or Urumqi, have risen significantly since 2017. It is no longer safe to assume that internment shares there are drastically lower than in Uyghur or Kazakh majority population areas. As stated above, the classified document mandates the establishment of VTIC administrative structures in every county in Xinjiang. Importantly, regions with high Han population shares have also seen a substantial increase in detention center capacity. Witness accounts indicate that these types of facilities are used to intern large and growing numbers of ethnic minorities for re-education purposes. Xinjiang’s domestic security spending on detention center management grew by 239 percent between 2016 and 2017, with the increase in a sample of Turkic minority regions amounting to 304 percent.
First, as noted above, Zenz’s “new data” indicating internment rates of 10 to 30% in regions with “high Turkic minority shares” of the population as well indicating significant rises in internment even in regions where such populations are in the minority refer to anecdotal accounts given by a few mostly unidentified people and Zenz provides no tangible proof of what they are alleged to have said, or even to whom, when, etc..
Secondly, while the documents relied upon by Zenz do suggest that a VTIC administrative structure should be established in each county (and assuming that document to be reliable), this does not necessarily mean that a VTIC, i.e., a physical camp, need be established in each county. In other words, the establishment of a VTIC in any county does not exclude that any one VTIC could gather detainees from several counties.
Thirdly, to support his claim that
Xinjiang’s domestic security spending on detention center management grew by 239 percent between 2016 and 2017, with the increase in a sample of Turkic minority regions amounting to 304 percent,
Zenz refers to another of his articles, this one published on November 5, 2018, on the web site entitled China Brief, operated by the Jamestown Foundation, a Washington think tank specialized on U.S. national security issues, and those in relation with China in particular.
In the earlier article, Zenz wrote that:
Expenditures on detention centers in counties with large concentrations of ethnic minorities quadrupled, indicating that re-education is not the only form of mass detainment in the XUAR.
Zenz states that the figures in his article were “manually calculated” by himself using sources from “national and provincial finance departments”.
Zenz cites no specific reports on which he relied let alone where they might be found.
Zenz does not provide copies of any of the documents he claims to have used as his sources.
The three documents referenced at the end of article lead to documents that concern social security expenditures （“社会保章“） for the period 2012-2016, and to the number of people in vocational training in 2017 and 2018 (”职业就能培训“) (Exhibits 11 and 12). There is no language in those documents even remotely suggesting that they concern “extrajudicial internment”.
Even granting the reliability of Zenz’s sources, his observation in one of his tables that expenditures for “detention center management” increased 239% in Xinjiang from 2016 to 2017 and by 307% in a “sample” of “ethnic minority prefectures and counties” raises the question of the statistical significance of his sample. Zenz provides no information on which or how many prefectures and counties were included in the “sample” or how representative they are of the entire minority population.
Furthermore, Zenz states that in the Chinese version of his source, the account in question is entitled “抱抽收教场所管理“. But, that formulation does not appear anywhere in Zenz’s various lists of “extrajudicial internment centers”.
Indeed, the expression is even questionable as corresponding to proper Chinese as a search on baidu.com turns up no entries for this expression
Zenz then turns to satellite photos to support his increase in his estimate of “extrajudicial internment” detainees from 1 million to 1.8 million.
The first photo, taken in October 2018, is of the Qaghiliq (Yecheng) County Legal System Transformation Through Education and Vocational Training School.
Zenz does not provide its name in Chinese. But it bears remembering that Zenz himself observes that establishments designated as schools (“学校”) are often genuine schools and do not implement “internment”, the designations of which centers usually end in “中心“.
Upon examination of a satellite photo of the site that I downloaded from google.earth on August 28, 2020, the buildings Zenz identified as “detention” camps appear to be walled in and to have turrets, which would of course support the conclusion that they are detention centers (or prisons for that matter).
But, the buildings that Zenz calls a “work-education camp” are clearly not walled in or otherwise enclosed. Also, these buildings are tiny compared with those that Zenz says are “detention camps”.
The buildings appear to be in a good state of repair and there are green spaces in amounts that seem inconsistent with a site that would be used to inflict inhumane treatment.
The second photo, taken in May 2019, is of the Yengishahar (Shule) County Legal System Transformation Through Education School ( 法制教育转化学校) in Baren Township (巴仁乡). Again, it bears mentioning that the site is designated as a “school” not as a “detention center”.
Zenz does not actually use the words “detention” or “internment” in referring to the buildings on this site. But he includes a photo of Alcatraz and invites the reader to compare the photos of the two sites, so the inference is obvious.
Still, upon examining a photo of the Yengishahar site that I downloaded from google earth on August 28, 2020, it is not clear that any of its buildings are walled in.
And some are clearly not walled in.
Zenz again compares the photo of the Hotan site with Alcatraz.
What Zenz designates as “detention” centers do appear to be walled in, although that is not perfectly clear.
On the other hand, the buildings that Zenz claims are “re-education centers” are clearly not walled in or otherwise enclosed. As Zenz observes, there are sports facilities, and one cannot but wonder how their presence is consistent with the supposed objective claimed by Zenz of the infliction of inhumane treatment.
Zenz does not relay any of the comments made by the New York Times journalist who visited the site.
But three in particular are quite significant with respect to the number of people who are interned at this site.
The author, Chris Buckley, writes that:
1. Inside (the Hotan site), hundreds of ethnic Uighur Muslims spend their days in a high-pressure indoctrination program, where they are forced to listen to lectures, sing hymns praising the Chinese Communist Party and write “self-criticism” essays, according to detainees who have been released. (emphasis added),
2. Former detainees that were interviewed spoke of detentions of several months,
3. Some facilities are designed for inmates who are allowed to go home at night.
It will be recalled that Zenz’s comparison with Alcatraz is no doubt intended to suggest that there many thousands of detainees at the Hotan site, not “hundreds”.
Also, Zenz never considers the possibility that the persons undergoing “re-education” might not be interned, but apparently based on Buckley’s reporting at least some are in fact not resident at the Hotan center
To reach his upper estimate of 1.8 million Uyghur and Kazakh in extrajudicial internment, Zenz proceeds in two stages.
First, Zenz explains his calculation arriving at 1.6 million detainees as follows:
Consequently, the author’s new upper limit extrajudicial internment estimate (including detention centers, excluding prisons) is based on the following assumptions: internment shares in regions with a Turkic (Uyghur, Kazakh, Kyrgyz) minority population of 40 percent or higher are assumed to reach an average adult population current extrajudicial internment of 16 percent; those with a Turkic minority population share between 30 and 40 percent have an assumed internment share of 12.5 percent; and those below 30 percent an assumed internment share of 10.0 percent. Moreover, the calculation assumes a generic internment share among the Hui, a Muslim minority group, of 4.5 percent. Despite the fact that the Hui have a long tradition of assimilation into Chinese language and culture, there are growing indications that the Hui are also being targeted.
These internment share estimates are then multiplied by adult population figures from the 2015 mini census. The results are again multiplied by adult population shares derived from the 2010 census (by county), given that the 2010 census is the most recent reliable data point for population breakdown by age cohort. The total internment estimate figure is then adjusted for the XUAR’s population increase from 23.22 million in 2015 to 25.3 million in 2019. The 2019 estimate was calculated based on a 2018 population of 24.87 million and an average reported annual population growth of 1.75 percent between 2015 and 2018.
But, there are numerous reasons to doubt the validity of Zenz’s assumptions.
First, according to the Shahit Data Base, on which Zenz himself relies:
· only 10,526 “victims of mass incarcerations of ethnic minority citizens” have been nominally identified and included in the data base (though Shahit does claim that there are ”hundreds of thousands, if not millions, being locked up in de facto concentration camps, given severe prison terms, or kept in notoriously inhumane police custody”),
· the number of “detained individuals and other victims parsed out from the large cache of internal documents obtained by scholar Adrian Zenz” was “3,304”,
· according to “a government document from Qaraqash County that was leaked abroad in the summer of 2019”, there were “584” “victims” in “education camps”,
· of the some 400 villages, subdistricts and municipalities included in the data base, only some 42 are reported to have a number of “victims” exceeding 1% of their populations (1 above 60% -160/265 inhabitants, 4 above 20% - 74/359, 112/510, 103/475, 6 above 10% below 20%, 4 above 5% and below 10%, and 27 above 1% and below 10%),
· those percentages concern males, whereas female victim percentages are a fraction thereof,
· the numbers of Kyrghiz and Hui people who are interned are an infinitesimal fraction of the total number of detainees included in the data base (182 Kyrghyz and 14 Hui out of 10,526 detainees),
· only 34% of the “victims of mass incarcerations of ethnic minority citizens” are in what Zenz designates as “extrajudicial internment”, that is 281 people in “custody” and 2,908 in (what Shahit calls) “concentration camps” and at least 8.3% are not in any form of “internment”, namely those whose documents have been withheld, those in town/house arrest, and those in forced job placement, to which might be added 3,2% qualified by Shahit as ”unclear (soft)”.
Forced job placement
No news for over a year
· on another page of the Shahit site, some 392 of the people identified as being “victims of mass incarcerations” are in “forced job placement”,
· of the 4,002 people included in the data base who responded to the question concerning the duration of their internment, it would appear that nearly all declared a period of two months,
· 2,800 of these victims’ identities were imported from the some odd 2,500 files obtained by Zenz, from which it seems reasonable to infer that Zenz has gathered only some 2,800 identities to support claims of 1.8 million detainees,
· according to the Shahit Data Base, “A number of individuals from these (Zenz) sheets have appeared in official Chinese databases, thereby confirming their validity”; but it may reasonably be questioned whether that overlap actually proves that any, let alone, all 2,800 such people were in “extrajudicial internment”,
· the Shahit Data Base indicates that “While the (Zenz) cache has unfortunately not been made public, shahit.biz has been allowed limited access for the purpose of adding victims to our database”, which underlines the importance of the question why these files are not made public and why was Shahit Data Base given only “limited access” to them, again undermining the reliability of Zenz's claims of 1.8 million detainees,
· On the Shahit Data Base, it is indicated that:
A total of 2533 people are reported as being explicitly in police custody (收押), in camp/"training"/"education" (送培，教培，转化教育，收教), sentenced (判刑), or as "special" (特殊人员) or "three kinds" (三类人员), with the latter generally indicating that the person is in one of the aforementioned three categories (custody/camp/prison), though the exact detention type is unclear. (emphasis added)
In other words, upon inspection of the Zenz lists, Shahit could not determine what shares of the identified individuals were in “extrajudicial internment” and what share were in prison; why then would Zenz’s own interpretations of the information and allocations of shares among the three categories be accepted as reliable.
Despite all those reasons for doubting the reliability of Zenz’s estimate of the numbers of people held in “extrajudicial internment”, and even if all his assumptions were granted and using his estimates of internment rates, one does still does not arrive at his estimates.
Thus, according to Zenz’s own assumptions and reasoning, the total number of detainees would be 1.483 million, not 1.6 million.
Zenz then explains how he justifies raising his higher estimate from 1.6 million detainees to 1.8 million:
In order to arrive at an estimate of all persons who are currently or have previously been in such internment, we need to estimate how many persons may have been released from internment between 2017 and 2019. This includes all forms of “release”, including forced labor placements. In the Shahit database, 9.4% (154 of 1,642) of those in internment (excluding prisoners) are marked as “released” or in “forced labor”. . . For the purposes of this publication, a release share of 10% persons is used, with the assumption that most of those would have been “released” into forced labor placements. . .
Adding 177,000 to the current internment estimate of 1.6 million results in a combined figure of 1.777 million, or approximately 1.8 million. . . 
Zenz does not cite a specific place on the Shahit Data Base web site where he found the information on which he bases his projection of 9.4% of all detainees released from “internment” being into “forced labor”.
For my part, I cannot find on the Shahit Data Base web site the information Zenz is claiming to quote.
On the other hand, on the Shahit Data Base, there does appear a number for people in “forced job placement”, which is 104 out of an alleged total of 3,226 people in “custody” (281) and in “concentration camps” (2,908).
So, the percentage of those in “forced job placement” out of all those in “extrajudicial interment” would be 3,2%. If any of those people had been placed directly in “forced job placement” and not transited through “extrajudicial internment”, then that percentage would be reduced further.
Still, even assuming that the percentage of those from released from “extrajudicial internment” to “forced job placement” were 3,2%, then Zenz’s increase to his 1.6 million base would not be 177,000 but 51,532.
Furthermore, neither Zenz nor the Shahit Data Base provide the Chinese language expression for what they respectively translate as “ forced labor“ and “forced job placement”.
Zenz might reasonably be thought to intend the reader to imagine a régime of arduous labor in a context of internment.
But the Shahit translation leaves open the possibility that this régime actually involves a placement in a job in civil society subject to obligatory presence of the person involved but without any internment.
And, in the end, Zenz admits that “An unknown subset of these persons will have been interned in the VTICs alone”, which reinforces the impression that Zenz himself does not claim to know what percentages of detainees in “extrajudicial internment” are in fact in “work-education camps”, versus being in “custody pending trial”.
In short, at this stage of Zenz’s development of his argument, the number of detainees in “extrajudicial internment” would not be 1.870 million as he claims, but instead at most (based on his own highly dubious assumptions and methods of calculation) 1.534 million, that is a base of 1.483 million to which would be added 51,532 detainees released from “extrajudicial internment” into “forced labor”.
Then, Zenz seeks to “corroborate” his estimate of 1.870 million detainees in “extrajudicial internment” as follows:
This new speculative upper limit internment estimate can be corroborated by considering the total number and possible average capacity of Xinjiang’s extrajudicial internment facilities. As discussed above, we must assume that the region has likely up to 1,300 or 1,400 extrajudicial internment facilities of all types. At least several of these have seen a massive enlargement of their capacity, and numerous witnesses testify to the fact that they are incredibly overcrowded.
But, as noted above, Zenz does not provide evidence that there are 1,300 to 1,400 “extrajudicial internment facilities of all types”.
Others, such as the Australian Strategic Planning Institute or journalists of Buzzfeed, upon examination of satellite photos, have advanced estimates of the number of facilities corresponding to mere fractions of Zenz’s estimate (some 27, and more recently 380 by the former, and some 250 by the latter). And even those estimates may be questioned, for instance:
· because some of the work-education facilities included in their estimates are not “internment” sites, but instead open, day-training type sites,
· because their estimates may include actual prisons (which would then not be “extrajudicial” as defined by Zenz himself) and
· because those estimates might include “sites for holding suspects of crimes pending their trials”, which at least arguably should not be qualified as “extrajudicial“ internment.
Zenz then undertakes calculations of numbers of detainees based on the physical capacity of the some 1,400 “internment” sites that he claims have been put into operation, but since he does not provide proof for his estimate of the number of those sites, this line of argument is unreliable.
Still, to justify his estimate of the physical capacities of the sites he claims exist, he observes that:
. . . the four or five floor buildings of a typical size for re-education camps has a floor space between 4,500 and 8,000 sqm. For example, Wusu City (Ili Prefecture) commissioned a Legal Systems Training School in July 2017 with a five-floor dormitory building featuring a floor space of 7,670sqm. The Vocational Training Center commissioned by Shuimogou District in Urumqi City in April 2018 was to have a six-floor dormitory building with 7,300sqm for males, and a 4,700sqm building for females. These camps are essentially only medium-sized in terms of total floor space.
But, upon, examination of the sources Zenz cites to support his observations, they are simply not borne out.
First, as regards the Wusu site, Zenz refers the reader to another of his articles to justify his observations about the Wusu site. But, therein, the site is identified as a “legal system training school (“法制培训学校”) not as a “中心” and it will be recalled that Zenz himself acknowledges that many sites designated as “schools - 学校” are in fact dedicated to teaching and are not “internment” sites.
Admittedly, Zenz adds to his own description of the project that it concerns the
Construction of new 3-floor teaching building (2,393 sqm) and 5-floor dormitory (7,670sqm). The government construction work report states that new security features were added to the facility, including a police station and steel-reinforced concrete walls.
But, the links to both sources Zenz cites to justify his interpretation are dead.
As regards the Shuimogou site, Zenz again refers to his prior article where his description of the project may be found. He identifies it as concerning a “Vocational training center (职业技能教育培训中心)” and more particularly:
Construction of a 36,527sqm compound, including an 8,000sqm underground facility, a 6 floor 7,300 sqm dormitory, a 4,700 sqm female student building, a 500 sqm police station, power supply and heating system, surrounding wall and fence, security monitoring system.
But, once again, the link to the source he cites to justify his description does not work.
Still, even granting Zenz the accuracy of his allegations as to the nature of the projects in question, and leaving aside that he purports to extrapolate reliably from his observations of two sites to the entire population of the 1,400 sites he alleges exist (such as to justify his estimate of the number of detainees in “extrajudicial internment”), he then goes on to estimate the number of detainees that such sites could hold.
To do so, Zenz reasons that
If 65 percent of the floor space is used for actual dorm space, they could easily intern between 2,500 and 3,900 persons when assuming a generous 2 sqm dorm floor space per person . . .
But, even taking his ratios as valid, the calculations do not yield the results he advances:
((7300+7670)/2) * 0,65 = 2,433
Zenz then postulates that, based on interviews with former detainees, the density of occupation of the dormitories could be as high as 0.5 square meter per person. But Zenz, does not specify the interviews on which he is relying, or how many.
A density of 0.5 persons per square meter imagines that 1.8 million people would be obliged to lie side-by-side packed one against another.
Zenz does cite in this context a report of the New York Times after its reporters visited a “camp” “right next to the Hotan Legal System Education and Training Center”.
But, he does not identify the article specifically.
Still, upon investigation, one such article by journalists of the NYT presents a picture that simply does not conform with Zenz’s representations of the density of occupation. The article contains a picture taken in a dormitory on which it is apparent that each occupant has his/her own bed and the beds are not stacked on top of each other.
This article, which is no way apologetic about criticizing the “indoctrination” process or the “harsh” conditions in the camp, nevertheless observes that
The impeccably neat, six-story building was built in 2017 and has a capacity of 447 people.
. . .
Detainees sleep six to room. There is a music room, an art room, a library with books mostly in Chinese, a room to learn how to give manicures and another to learn to cut hair.
. . .
By his account, Mr. Kebayir was now earning a decent wage — 2,100 renminbi last month, about $300 — stitching soles onto leather shoes at one of the new factories.
Similarly, as noted above, another article in the NYT describes the Hotan site as containing “hundreds of ethnic Uighur Muslims spend their days in a high-pressure indoctrination program”.
So, not only does Zenz fail to provide reliable evidence to support his claims about the number of “internment” sites, the sources he himself advances contradict his claims about the density of occupation of the sites (not to mention that the “forced labor” which he alleges appears to be remunerated by a “decent wage”).
Altogether, Zenz nevertheless concludes that
When considering all available sources of information, these new upper and lower limit estimates of 1.8 million and 900,000 respectively are eminently realistic, and appear to be an appropriate increase over previous estimates.
In the end, Zenz does not even clearly state whether his estimates correspond to the numbers of detainees at any one time or the sum of all those ever detained.
4 - On the use of ranges
Zenz claims a “speculative upper limit estimate of 1.8 million . . . and a new minimum estimate of 900,000”.
Zenz intends his estimates to be used for purposes of making decisions, i.e. to affect the policies of countries toward China to bring about an improvement in the treatment of Xinjiang’s Muslim minorities.
Decisions regarding what pressures to apply to China is partly a function of the risks of relying on Zenz’s estimates.
Whereas an observer unfamiliar with statistics might think that the likelihood of Zenz’s estimates being right would go up if their range is widened, the opposite is true.
Actually, if there are only two observations and they have an equal probability of occurrence, then the wider the range of observations, the greater the risk of reliance on the observations to make a decision.
To use a simple example:
probability of 0.9 is 50%
probability of 1.8 is 50%
standard deviation (risk of reliance) is 0,5
probability of gaining 0.9 is 50%
probability of gaining 1.2 is 50%
standard deviation (risk of reliance) is 0,37
In other words, the very width of the range of Zenz’s estimates is a source of risk of error, a factor decreasing their reliability.
In reality, Zenz’s estimates likely do not have equal probabilities of being accurate. If the lower one were considered to have an 80% probability of being accurate and the higher one only a 20% chance, then his “expected result” should have been 1.08 million people, with a standard deviation of 0.4, which is an indicator of the high risk of reliance on Zenz’s estimates.
5. - Conclusion
To excuse the unreliability of Zenz’s estimates of the number of Muslim minority people in Xinjiang, some observers have argued that he himself calls them “speculative”. Of course, that appears rather more to be a euphemism for “guess”.
But, more importantly, Zenz actually qualifies his estimates as “eminently realistic” and “appropriate”.
For our part, we conclude that Zenz estimates of the number of detainees in “extrajudicial internment” in Xinjiang are unverifiable and unreliable.
That some observers have qualified his articles as “transparent” or of “academic quality” is incomprehensible.
Authorities in the Western World have nevertheless relied on those articles for the adoption of policy toward China.
That Muslim-minorities are suffering from a régime that is harsh, and even violative of Western concepts of “human rights”, is evident from the numerous statements gathered by many investigators acting in good faith.
The point of this review has however been to recommend caution before accepting as true Adrian Zenz’s claims as to the numbers of detainees that are as impressive by the quantities advanced as they are suspect for want of evidence to support them.
In the end, if one were to retain only the number of detainees with respect to which Zenz has provided third parties, nominally identified in his article, access to his sources for purposes of inspection, then that number would be the one advanced by the managers of the Shahit Data Base, namely “3,304”, corresponding to the number of “detained individuals and other victims parsed out from the large cache of internal documents obtained by scholar Adrian Zenz”.
Retaining any number beyond that number requires acts of faith in Zenz’s assertions about the authenticity of the documents on which he claims to rely without providing objective evidence, as well as in his accounts of their contents for want of revealing them in their entirety. Even granting him the benefit of any doubts in those regards, his estimates are most often extrapolations from very limited sets of data, such as a handful of individual interviews of mostly unidentified officials or of victims whose accounts of their treatment could be suspected of partiality. Furthermore, those extrapolations are riddled with errors of reasoning and calculation. Even the footnotes often lead to dead links or irrelevant sources.
Still, the satellite photo evidence gathered by such organizations as the ASPI does suggest the existence of large-scale internments. But the ASPI has deliberately chosen, at least to this date, not to advance numbers of detainees. Though clearly aware of Zenz’s estimates and his arguments supporting them, the ASPI has not confirmed them.
In conclusion then, Zenz’s estimates in his JPR November 2019 article of the number of detainees in “extrajudicial internment” in Xinjiang are unreliable and should be not be used as a basis for formulating policies toward China and its treatment of the Muslim minority populations in that Province.
Section 1 – Methodology :
“The author’s second data source is a secret, classified government document, dated November 5, 2017, and issued by the Xinjiang Uyghur Autonomous Region’s Party Political and Legal Affairs Committee ( 自治区党委政法委) (Figure 6). This classified document was passed to Uyghurs in exile from a source in Xinjiang, and then directly passed to the author. Its authenticity has been independently verified by several linguists and Xinjiang experts. Based on his experience and through comparison with numerous other government sources, the author likewise considers the language, formatting, and contents of this document to be indicative of its authenticity.”
The classified document mandates that every region (prefecture) and county (or city) must establish a “VTIC leadership small group” ( 职业技能教育培训领导小组), which is to be headed by the county committee party secretary. It must also establish an ETB. This means that every single regional administrative unit at county level and above must establish the administrative infrastructure for supervising VTIC work. This is consistent with the author’s previous finding that most of Xinjiang’s regions, including those where the Han constitute the majority of the population, operate re-education facilities. That fact therefore represents an important finding for estimating the scale of the extrajudicial internment campaign.
Related information for lower levels is difficult to obtain. However, a March 2016 United Front Work Department report cited above states that in Kashgar City, every township and residential district had established a “legal school” (法制学校), while every village and urban district had set up a “transformation through education room” (教育转化室). Notably, this was almost one whole year before the start of the large-scale re-education campaign. Similarly, a 2014 news report stated that Konashähär (Shufu) County had established a three-tiered “transformation through education base” ( 教育转化基地) system at county, township and village levels. Some of these bases were also titled “legal system training schools” ( 法制培训学校).
 The article, page 2.
 Ibid, page 1.
 See various sources cited at http://www.lapres.net/exhibits090820.html.
 Adrian Zenz, China’s Own Documents Show Potentially Genocidal Sterilization Plans in Xinjiang, Foreign Policy, July 1, 2020, https://foreignpolicy.com/2020/07/01/china-documents-uighur-genocidal-sterilization-xinjiang/; for a reply in Chinese media see: Six lies in Adrian Zenz's Xinjiang report of 'genocide', CGTN, September 14, 2020, https://news.cgtn.com/news/2020-09-14/Six-lies-in-Adrian-Zenz-s-Xinjiang-report-of-genocide--TMIv2qWemA/index.html.
 For instance, Zenz emphasizes that the article here under consideration was “peer reviewed”, the Article, page 36. Actually, however, Zenz’s articles are published on web sites of “think tanks”, not in academic journals attached to any university, let alone one the reputation of which would inspire confidence. Furthermore, there is no way for a reader to know what requirements were imposed in the selection of the “peer review committee” or in the monitoring of its work.
 Nathan Ruser, Documenting Xinjiang’s detention system, Australian Strategic Planning Insstitute, September 2020, https://cdn.xjdp.aspi.org.au/wp-content/uploads/2020/09/25125443/documenting-xinjiangs-detention-system.cleaned.pdf.
 Allison Killing, Megha Rajagopalan, Christo Buschek, Blanked-Out Spots On China's Maps Helped Us Uncover Xinjiang's Camps, August 27, 2020,
 Daniel Laprès, Review of the sources relied upon by Adrian Zenz in his article the Journal of Political Risk, July 2019,(the July 2019 JPR Article) to support the claim that there are 1.5 million Muslim minority people detained in work-education centers in Xinjiang, in particular the section on footnote 54 in Zenz’s article, August 9, 2020. The July 2019 JPR Article is Brainwashing, Police Guards and Coercive Internment: Evidence from Chinese Government Documents about the Nature and Extent of Xinjiang’s “Vocational Training Internment Camps”, https://www.jpolrisk.com/brainwashing-police-guards-and-coercive-internment-evidence-from-chinese-government-documents-about-the-nature-and-extent-of-xinjiangs-vocational-training-internment-camps/; my review is at http://www.lapres.net/jprreview.html.
 村里的好帮手——志愿者服务队，June 2， 2017，
 The Article, page 20.
 For instance, article 36 provides that ” A defense lawyer may, from the day on which the people's procuratorate begins to examine and prosecute the case, consult, make abstracts of or reproduce the indictment and technical appraisal materials of the case, may meet and correspond with the crime suspect in custody. Any other defender, with permission of the people's procuratorate, also may consult, make abstracts of or reproduce the aforesaid materials, and meet and correspond with the crime suspect in custody. A defense lawyer may, from the day on which the people's court accepts to hear the case, consult, make abstracts of or reproduce the materials of the facts of the crime charged against in the case, may meet and correspond with the defendant in custody. Any other defender, with permission of the people's court, also may consult, make abstracts of or reproduce the aforesaid materials, and meet and correspond with the defendant in custody.”
Article 52 provides that: “Crime suspects and defendants already taken into custody, their legal representatives and near relatives shall have the right to apply for their release upon bail pending trial.“
Article 64 provides that “When detaining a person, the public security organ must produce a warrant of detention. The public security organ shall, within 24 hours after detaining a person , notify his family or the unit to which he belongs of the reasons for the detention and the place of custody, unless such notification would hinder the investigation or there is no way for making such notification.”
Article 71 provides that: “The public security organ must produce a warrant of arrest when arresting a person. A public security organ shall, within 24 hours after arresting a person, notify his family or the unit to which he belongs of the reasons for the arrest and the place of custody, unless such notification would hinder the investigation or there is no way for making such notification.”
Article 74 provides that: “If a case in which the crime suspect or defendant has been taken into custody could not be settled within the time limits prescribed by this Law for custody for investigation, examination for prosecution, first instance and second instance, and requires to continue the investigation and trial, the crime suspect or defendant may be subjected to release upon bail pending for trial or residential surveillance.”
Article 96 provides that: “A crime suspect may, after being interrogated for the first time or from the day on which compulsory measures are taken against him, hire a lawyer to offer him with legal consultancy or to act on his behalf in making appeal or accusation. If a crime suspect has already been arrested, the lawyer so hired may apply for his release upon bail pending trial. With respect to cases involving State secrets, if the crime suspects intend to hire lawyers, they shall seek the approval from the investigating organs. A lawyer so entrusted shall have the right to know the crime to be charged against the crime suspect from the investigating organ, may meet the crime suspect already taken into custody and get information pertaining the case from the crime suspect. When a lawyer meets a crime suspect already taken into custody, personnel from the investigating organ may, in light of the circumstances of the case and needs, be assigned to be present. With respect to a case involving State secrets, a lawyer intending to meet the crime suspect already taken into custody shall seek the approval from the investigating organ.”
Article 124 provides that: “The time limit for holding a crime suspect in custody during investigation after his arrest may not exceed two months. If a case is complex and the investigation cannot be concluded within that time limit, an extension of one month may be allowed with the approval of the people's procuratorate at the next higher level.”
Article 128 provides that: “If, during the period of investigation, a crime suspect is found to have committed any other major crime, the time limit for holding him in custody shall be re-computed pursuant to the provisions of Article 124 from the day on which such crime is found.”
Article 143 provides that: “A decision not to initiate prosecution shall be made open to the public, and the written decision not to initiate prosecution shall be delivered to the person against whom no prosecution is to be initiated and the unit to which he belongs. If the person against whom no prosecution is to be initiated is still kept in custody, he shall be promptly released.”
Criminal Procedure Law of the People's Republic of China Criminal Procedure Law of the People's Republic of China – 1996, adopted by the Second Session of the Fifth National People's Congress (NPC) on July 1, 1979, and amended pursuant to the Decision on Amending the Criminal Procedure Law adopted by the Fourth Session of the Eighth NPC on March 17, 1996)
 A debate might then be more usefully focused on the abuse of the criminal system to oppress the Muslim minorities and the disproportion in mixing people subject to the criminal system with those not accused or convicted of any crime.
 The Article, p. 19-20.
 Ibid, p. 21.
 Ibid, p. 1.
 Ibid, p.7.
 Thoroughly Reforming them Toward a Healthy Heart Attitude - China's Political Re-Education Campaign in Xinjiang, May 15, 2018, p. 15, http://www.etaa.org.au/wp-content/uploads/2018/06/Thoroughly_Reforming_
 Ajit Singh and Max Blumenthal, China detaining millions of Uyghurs? Serious problems with claims by US- backed NGO and far-right researcher ‘led by God’ against Beijing, The Grayzone, (https://thegrayzone.com/2019/12/21/china-detaining-millions-uyghurs-problems-claims-us-ngo-researcher/.
 closing paragraph to the article.
 The Article, p. 20.
 Exhibit 1, www.lapres.net/jpr1119exhibit1.pdf.
 http://archive.is/yDyEu cited at p. 20; Exhibit 2, www.lapres.net/jpr1119exhinbit2.pdf.
 The Article, p. 39-40.
 The Article, page 25.
 Page 25.
 Ibid, p. 6, line 53.
 The Article, page 25.
 "Thoroughly Reforming Them Towards a Healthy Heart Attitude" - China's Political Re-Education Campaign in Xinjiang, SOCARXIV, September 6, 2018 https://osf.io/preprints/socarxiv/4j6rq.
 Ibid, page 27.
 Ibid, page 28.
 The Uyghur Lobby: Global Networks, Coalitions Yu-Wen Chen and Strategies of the World, Routledge, 2013.
 Supra, note 50, page 27.
 Exhibit 10, www.lapres.net/jpr1119exhibit10.pdf.
 Supra, note 50, page 28.
 Ibid, page 27.
 Exhibit 11, www.lapres.net/ jpr1119exhibit11.pdf:
Kizilsu Kyrgyz Autonomous Prefecture
Ili Kazakh Autonomous Prefecture
 The Article, page 26.
 The Article, page 26.
 Xinjiang’s Re-Education and Securitization Campaign: Evidence from Domestic Security Budgets, China Brief Volume: 18 Issue: 17, November 5, 2018, https://jamestown.org/program/xinjiangs-re-education-and-securitization-campaign-evidence-from-domestic-security-budgets/. The sources of financing of The Jamestown Foundation are not revealed on its web site, https://jamestown.org/programs/cb/.
 Exhibit 12, www.lapres.net/jpr1119exhibit11.pdf.
 Exhibits 13 and 14, respectively: www.lapres.net/jpr1119exhibit13.pdf and www.lapres.net/jpr1119exhibit14.pdf.
 Supra, note 64.
 The Article, p. 26; Exhibit 15, www.lapres.net/jpr1119exhibit15.pdf.
 Supra, Section 2.2.
 Exhibit 16, www.lapres.net/jpr1119exhibit16.pdf.
 The Article, p. 28; Exhibit 17, www.lapres.net/jpr1119exhibit17.pdf.
 The Article, p. 28.
 Exhibit 18, www.lapres.net/jpr1119exhibit18.pdf.
 Exhibit 19, www.lapres.net/jpr1119exhibit19.pdf; a photo downloaded from google.earth on August 28, 2020 (Exhibit 20) is posted at www.lapres.net/jpr1119exhibit20.pdf
 The Article, p. 28.
 China Is Detaining Muslims in Vast Numbers. The Goal: ‘Transformation’, September 8, 2018, https://www.nytimes.com/2018/09/08/world/asia/china-uighur-muslim-detention-camp.html.
 The Article, p. 30.
 https://shahit.biz/eng/ and more particularly, https://shahit.biz/eng/#evidence.
 Accessible on the shahit site at https://shahit.biz/supp/list_008.pdf.
 Exhibit 21, www.lapres.net/jpr1119exhibit21.pdf
 The Article, p. 30; of course, 10% of 1.6 million is 160,000 not 177,000 and 1.6 million plus 177,000 is 1.877 million not 1.8 million, but such “rounding” errors pale in significance in the whole context of errors.
 Exhibit 22, www.lapres.net/jpr1119exhibit22.pdf.
 The Article, p. 31.
 Nathan Ruser, Documenting Xinjiang’s detention system, Australian Strategic Planning Institute, September 2020, https://cdn.xjdp.aspi.org.au/wp-content/uploads/2020/09/25125443/documenting-xinjiangs-detention-system.cleaned.pdf
 Allison Killing, Megha Rajagopalan, Christo Buschek, Blanked-Out Spots On China's Maps Helped Us Uncover Xinjiang's Camps, August 27, 2020,
 The Article, p. 31.
 The Article, p. 40, footnote 91.
 Supra, note 24, p. 41. That article does include in its list of “re-education facilities” another one in Wusu, which is designated as a “集中封闭套培训中心”, but its date is referenced as June 9-12,2017 (p.39) and its description does not correspond to that of the site referred to by Zenz.
 Supra, Section 2.2.
 https://web.archive.org/web/20180617184617/http: //www.bidchance.com/info-gonggao-21000457.html and https://web.archive.org/web/20180617184618/http: //www.xjws.gov.cn/publicity_wsszfhcxjsj/ywgz/2827, see respectively Exhibit 23 (www.lapres.net/jpr1119exhibit23.pdf), and Exhibit 24, (www.lapres.net/jpr1119exhibit24.pdf).
 Supra, note 24, p. 44.
 Exhibit 25, www.lapres.net/jpr1119exhibit25.pdf.
 The Article, p. 31.
 and , China Said It Closed Muslim Detention Camps. There’s Reason to Doubt That, August 9, 2019,
 Exhibit 26, www.lapres.net/jpr1119exhibit26.pdf.
 Chris Buckley, China Is Detaining Muslims in Vast Numbers, The Goal: ‘Transformation.’, NYT, September 8, 2018, https://www.nytimes.com/2018/09/08/world/asia/china-uighur-muslim-detention-camp.html.
 The Article, p. 31.
 Ibid, p.2.
 Supra, footnote 86.