The Spratlys: A Past Revisited*

Francois-Xavier Bonnet"

The 'Spratlys' refers to a group of islands, islets, reefs and sand banks
located in the South China Sea, off the coast of Palawan, Borneo, and Vietnam,
approximately between the longitudes 110 0 E and 118oE and the latitudes 12oN
and 6oN.' This group is composed of twenty six islands and islets and seven
groups of rocks that remain perpetually above sea level with a maritime area of
160,000 sq. kn. but an insular area of not more than 170 hectares' (the largest
island in the group is Itu Aba with fifty hectares). This insular narrowness,
however, does not seem to have disturbed the thousands of maritime birds in the
region, its only permanent inhabitants for centuries. The region has been a
dangerous one for commercial navigation, but it is on occasion temporarily
frequented by local fishermen. Within the last fifteen years, the Spratlys has
become a 'hot spot' of Southeast Asia, as the control of its resources and wide
maritime areas has become a cause of tension.

The Claimants and Their Arguments

Five Asian states have made claims of ownership, in part or in totality, over
the Spratlys group. These states have used a variety of arguments and have even
resorted to occupying it militarily:

China and Taiwan consider the whole South China Sea, including the
Spratlys (Nanshas) and the Paracels (Xishas), to have been part of their
national territory from as far back as 202 B.C. (Hans dynasty), or since
time immemorial.' The historical records, archives and maps of Chinese

Paper presented at the European-South East Asian Association (EUROSEAS) Conference,

Paris, 1 Sept. 2004 (original paper in French).
"Geographer, Phd. candidate in Geopolitics and Geography, Consultant
to the United
Nations Educational, Scientific, and Cultural Organization (UNESCO).
David Hancox & Victor Prescott, A Geographical Description of the Spradys Islands, I MARITIME
BRIEFING 2 (1995).
2
Victor Prescott, THE MARITIME POLITICAL BOUNDARIES OF THE WORLD 218 (1985).
3Frederic Lasserre, LE DRAGON ET LA MER 16 (1996).
4
Hsiao Shi-Ching, THE NANSHAs DISPUTES 10 (2"" ed. 1999).
14 World Bulletin, July-Dec. 2004

maritime expeditions have been presented as irrefutable evidences of the

Chinese sovereignty in this region. In 1883, the government of the
Qing dynasty protested vigorously against the intrusion in the Xishas
and Nanshas of a German ship in charge of a mapping mission. In 1887,
the boundary agreement between France and China in the Tonkin
Gulf, gave the South China Sea to China. The Manchu empire studied,
administered, and exploited the Xishas and Nashas in 1908 until France
and Japan annexed these archipelagoes in 1931-1933, and 1939
respectively.- Taiwan has been occupying Itu Aba since 1956. China
itself has staked a claim over dozens of islets and reefs between 1988 and
1995.
Vietnam also presents historical arguments for its claim over the
Spratlys (Truong Sa) and Paracels (Hoang Sa). Since the 18"' century, the
Hoang Sa company, specialized in the exploitation of wrecks, guano,
and fisheries, under the authority of the Nguyen lords, operated in
these two island groups. These two archipelagoes were mentioned on a
map drawn at the 14"' year of the reign of Minh Mang. Vietnam argues
that, France having annexed the Spratlys in 1933, Vietnam, as direct
successor, should inherit them."' Vietnam, to date, occupies about
twenty-four islets and reefs.
Malaysia has been claiming since 1979, twelve islets and reefs belonging
to its continental shelf and occupied three of them between 1983 and
1986.' Brunei claims Louisia Reef on its continental shelf but has not
sent troops.
The Philippines' official claim was made by virtue of a presidential
decree dated June 11, 1978,. declaring a part of the Spratlys, the
Kalayaan, as an integral part of its national territory for several policy
reasons, namely: (1) geographical proximity, (2) economical survival
and security, (3) part of the continental shelf, (4) historical reasons, vital
need, effective occupation and control, and (5) its abandonment by the
other countries.' This claim was based on the actions of a Filipino
businessman, Tomas Cloma, who made a claim to the discovery and
occupation of fifty-three islands and islets off the coast of Palawan in
1956. He would later name this group Freedomland, as distinct from
the Spratlys. During the period from 1968 to 1971, the Philippines
occupied eight islets.

'Id., at 14.
Vietnamese Foreign Ministry, White Paper, September 27, 1979.
7
Merliza Makinao, Understanding the South China Sea Dispute, 1998 OFFICE OF STRATEGIC AND
SPECIAL STUDIES, ARMED FORCES OF THE PHILIPPINEs 54.
sPresidential Decree No. 1596 (Declaring Certain Areas Part of the Philippine Territory and
Providing for their Government and Administration), June 11, 1978.
The Spratlys: A Past Re'isited 15

Despite all their historical, geographical, and legal arguments, none of these
countries have attempted to seek arbitration under the International Court of
Justice. Could it be due to some doubts on their part regarding the validity of
their claims and supporting arguments? Except the claims of Malaysia and
Brunei," the other four countries (China, Taiwan, Vietnam, and the Philippines)
have what appears to be a very confused claim over the Spratlys. All claim the
Spratlys using the same arguments as for the Paracels, while the Philippines
considers the Kalayaan group to be different from the Spratlys. To explain these
questions there is a need to study the events of the period from 1933-1940, the
period of genesis for these claims; and an embargo of geographical information
on the Spratlys imposed by the colonial powers for military reasons.

The Spratlys: An Area to Avoid

Up to the 1920's, maps of the islands, islets, and reefs of the Spratlys were
drawn to help improve security in the significant commercial routes crossing
the South China Sea. The objectives of these maps were to alert the seamen of
the dangers in the area and admonish them to avoid passing through it. The
scientific mapping of the Spratlys was undertaken by the East India Company
and the British Admiralty at the end of the 18 "' century and lasting through the
19"' century."' The results of these different expeditions were published in 1868
on the nautical chart 2660B China Sea-Southern portion. The eastern sheet was
revised in 1881 and have had practically no corrections until 1954." This map,
reproduced by several countries (France, Japan, and the United States, among
others) with the agreement of the Admiralty, became the reference not only for
navigators but also for diplomats in charge of studying the conflict in the Spratlys
in later years. This map showed two distinct geographical areas: the western part,
which had been known since the 19 "' century and included nine well-positioned
groups of islands, islets, and reefs (among them the Spratly island) and a large,
nearly empty eastern portion west of Palawan, with few reefs and sand banks
whose existence was doubted by the Admiralty, named Dangerous Ground.

The French Annexation of 1933

The French government officially claimed the western part of the Spratlys
in July 1933 in order to "avoid a foreign power from claiming sovereignty over

')For a critique of the Malaysian claim, see De Manille AManille, OUTRE TERRE, no. 6 at 172.
"'Hancox & Prescott, supra note 1, at 34.
"David Hancox & Victor Prescott, SECRET HYDROGRAPHIC SURVEYS IN THE SPnATovs ISLANDS, 26
(1997).
16 World Bulletin, July-Dec. 2004

staking the first contentious claim in the history of the area. The French
it, "12
Minister of Defense recognized the binary perception between the western and
eastern areas, noting the impossibility of taking possession of the unexplored area
because of the dangers it poses for navigations."
The strongest protests came from the Japanese, particularly the
businessmen in the fertilizer industry (guano), the media, scholars, and officials
in the Navy. However, to consider that the Spratlys claims were purely an affair
between France and Japan is overly simplistic. In fact, two other nations, China
and the Philippines, were not only closely following these events but registered
their protest to the French action too.14

Paracels or Spratlys? The Chinese Confusion

The Chinese geographical confusion between the Spratlys and the Paracels
seems to date back to the end ofJuly 1993 when the officials of the province of
Canton accused the French government of having annexed nine islands
belonging to the Hsishas (Paracels):

"These nine islands belonging to China are known under the

name of Paracels... and are located at latitude 15046' and 1705' and
longitude 110'14' and 112045'. These islands have belonged to China
for hundreds of years.""

The Chinese Consul in Manila, Mr. Kwong, was then tasked with
establishing the exact positions of the nine islands. On August 1 of the same year,
he submitted his report to the Chinese Foreign Affairs Department which
announced:

"...These islands are collectively known as Tizard Bank and are

situated at 530 miles from Hainan, 350 miles from the Paracels and
200 miles from Palawan... The reports mentioning that the nine
islands were part of the Hsishas are incorrect."

12COMMENT OF THE MINISTRE DE LA DEFENSE AU MINISTRE DES AFFAIRES ETRANGERES (1932)

reprinted in M. CHEMILLIER, LA SOUVERAINETE SUR LES ARCHIPELS PARACEIS ET SPRATLEYs, at Annex 36
(1996).
"Id.
"This is in contrast with the claims put forth in M. SAMUELS, CONTEST FOR THE SOUTH CHINA
S.A 64 (1982) and many other publications.
isChina Press, Aug. 4, 1933.
The Spratlys: A Past Revisited 17

However, he promptly added that even if these islands were not part of the
Paracels due to the great distance between the two groups, their geographical
position suggests that they could have some connections with the Chinese
national territory."
Claiming geographical proximity to the Paracels and the presence of
fishermen from Hainan, the Chinese government officially protested the
annexation by the French government." The rationale behind the protest was
clearly expressed by the Journal of the Chinese Navy of October 1933:

"...Whatever the French and Japanese positions on these islands,

China must take a definitive position: the nine islands in the China Sea
are in the jurisdiction of China. Whatever their size, we cannot tolerate
their annexation by others. We cannot authorize them to occupy these
islets lest we lose also the Paracels islands.""

To create a buffer area protecting the national territory against the rise of
Japanese imperialism (two years after losing Manchuria) seems to have been the
Chinese project. This is far from contemporary arguments which make use of
'immemorial time.' The Chinese and French projects were quite similar, relying
on preventive claims where the "geographical" dominated the "historical rights."
A number of official Chinese documents confirm this perception. The
Chinese Year Book, for example, made mention up to 1933, of the southern limit
of China extending up to the Paracels islands at latitude 18oE. " After 1933, the
points of view varied. The Shen Pao Year Book of 1934 noted that the nine islands
in the South China Sea area have served as a base for Chinese fishermen since
time immemorial and, as such, are part of the Chinese territory.20 But the China
Handbook of 1937-1943 published by the Chinese Ministry of Information still
considered the southern boundary at the Triton island in the Paracels (latitude
15o16'E).2 ' However, the China Handbook 1937-1944 noted that dominion over
the nine islands (called Tuanshas or coral islands) were contested by China,
Indochina, and the Philippines.

"The North China Herald and National News Weekly, Aug. 9, 1933.
7
1 Philippine Tribune, Aug. 31, 1933.
1"Hsi-chn Tsa-chiht (NavyJournal), Oct. 1933, at 1-4.
''The Chinese Year Book (1930), at 1.
2 11
Sheni Pao Year Book (1934), at 347.
2
China Handbook 1937-1944, Nov. 1944, at 1.
18 18II rld fl//cnnll-Di-)c. 2004I

The Forgotten Claim of the Philippines

On the dozens of books and articles written on the Spratlys by foreigners or

Filipinos, none make mention of the interest of the Philippines for this territory
between 1933 and 1940. At best, it is mentioned that in 1946, Vice President
Elpidio Quirino claimed the Spratlys for security reasons. In fact, since 1933,
when most of the Filipinos were concentrated on the negotiations with the
United States for independence after a transition period (Commonwealth), a
former Senator, Isabelo de los Reyes, was the first to protest the French
annexation. De los Reyes, well known in the Philippines for being a radical
nationalist, anti-Spanish and anti-American, and considered as the father of
unionism and communist party of the Philippines before the war, urged the
American government to claim "Las Corales" or the nine islands, in a letter of 12
August 1933, addressed to Governor General Frank Murphy. This claim was
based on the geographical proximity of these islands to Palawan and their being
part of the Treaty of Paris signed in 1898.
He also held several press conferences, developing and presenting further
arguments:

"...It would be a grave carelessness to permit that France or Japan

has power over these islets to fortify and arm them against ourselves
within our own territory

His stir reached the political administration and on September 1, 1933, a

parliamentary committee was proposed to study the question with Senator
Elpidio Quirino as chairman. Some scholars, like Father Ylla, a specialist of
Canon Law in the University of Santo Tomas, considered these islands to be
included in the Treaty of Paris and as such were res nullius.2
Facing the awakening of the Filipinos, the American answer was ambiguous to say
the least. The director ofthe Coast and Geodetic Survey in Manila, Dr. Luce, considered
that these islands, which lay outside the limits of the Treaty of Paris and had no
apparent commercial value, could be very useful as aerial bases for the
Philippines, as a link in the aerial route which could be established in the future
with Siam.' On the other hand, the State Department, answering the queries of

nLetter from Senator Isabelo De los Reyes, to Governor General Frank Murphy, Bureau of
Insuldar Affairs (Aug. 12, 1933).
2Philippine Tribune, Aug. 23, 1933, and Aug 27, 1933.
"'Id., Sept. 1, 1933.
'Id., Sept. 22, 1933.
T47d., July 22, 1933.
The Spratlys: A Past Revisited 19

the Insular authorities on October 9, 1933, laid the foundations of the American
doctrine, which would prevail up to the years from 1980-1990:

"... The islands occupied by France are located 200 miles from
the boundaries of the Philippines defined by the Treaty of Paris.
Moreover, these islands are located in the other side of a large area of
shallow sea that the nautical charts named "Dangerous Ground."
These islands are therefore at considerable distances and outside the
limits of the Philippines ...
"

This Filipino interest in the Spratlys was confirmed during the following
years and was reported in 1941 by an American Review, the Pacific Affairs, which
lauded the visionary Elpidio Quirino (who was then the Secretary of Interior) for
having officially filed a claim on the Spratlys in the name of his government in
the State Department in 1937. "Unhappily, the State Department did not see fit
to act on the question. The islands apparently had no official owners, though,
geographically the Philippines should have been their rightful claimant.""2 The

Philippine claim was, like those of China and France, made in the name of
national defense and geographical proximity.

Military Mapping of the Dangerous Ground

When the geographer of the State Department believed in 1933 that the
nine islands were too distant from Palawan, he was using a nautical chart
(USHO .799) produced from the British chart of 1881 (BA2660B), which had
practically undergone no changes since its inception. However, from 1925
onwards, the strategist of the British Admiralty started to be closely interested in
the so-called Dangerous Ground. The objectives of the Navy then were: (1) to link
as quickly and discretely as possible the naval bases of Singapore, Shanghai, Hong
Kong, and the oil fields of Borneo; (2) to find in this area discreet ports of
anchorage; and (3) to discover a secret North-South route crossing the Dangerous
Ground.2 ' Between 1925 and 1938, the Admiralty would crisscross the Dangerous
Ground, discovering this famous secret North-South route in 1934, and would
meticulously map the area in its entirety. The resultant maps of these annual
missions would be kept secret. These surveys would allow the British Admiralty

Letter from W. Carr to the Secretary ofWar (Oct. 9, 1933).

2 14 PACIFic AFFAIRS, XIV (1941).
2
"Hancox & Prescott, supra note 1, at 37.
20 World Bulktin, July-Dec. 2004

to verify that twenty-two reefs located on the commercial charts were in fact,
inexistentM (See Annex 1)
On the other hand, the Japanese Imperial Navy also explored the Dangerous
Ground from 1936 to 1938, and drew secret maps of the area as well, specifically,
Itu Aba, the future place for its submarine base. On May 1939, Commander
Unosuke Kokura wrote in the Japanese review Sozo:

-... A remarkable fact is that the whole of the Spratlys islands can
be considered as a kind of fortified area, because it is known as a
dangerous area on all the maps of the world... But because of a
laborious work of our Imperial Navy, this area is not a dangerous area
at all for us. Our warships and commercial ships can sail freely through
these groups of islands and take shelter behind the reefs..."3

Finally, in 1935, the US Navy, based in Cavite, Philippines, also started to

secretly study the Dangerous Ground. Its objective was to discover a maritime
route across the area from the island of Balabac, Palawan to Singapore. This route
was discovered in 1935 and further studied in 1937.2 Following these surveys,
the bathymetric charts were classified top secret as well. Nevertheless, the
American missions were not concerned with the whole area of the Dangerous
Ground and the twenty-two reefs, considered inexistent by the British Admiralty,
continued to appear on the American maps even up to recent years."
These secret missions demonstrate the weakness of the French control over
the area-the French government did not seem to have filed any protest note
against the Japanese mappers disguised as fishermen. Nor were there any
documents showing serious French surveying missions of the Spratlys, with the
exception of studies of the Tizard Bank and Spratly Island. The French attitude
with respect to the Spratlys seemed to have been purely formal. Moreover, the
French Defense Minister specified in 1932 that the preventive possession
exercised by France did not signify that it had plans to use the archipelago for
military matters.'

Id., at 137. See also Annex 1 of this work.

"Letter from the American Consulate ofJava to the Secretary of State (July 10, 1939).
'2 Hancox & Prescott, supra note 1, at 107.
'Id., at 189.
34Supra note 12
The Spratlys: A PastRevisited 21

The Fusion of the Dangerous Ground and the Spratlys

In 1930s, the secret geographical knowledge regarding the Spratlys, became

more and more precise, and allowed the Navy authorities to perceive the area for
the first time as a vast archipelago crisscrossed by secret maritime routes, with
real shortcuts in the South China Sea. This change of perception was used by
Japan, when it annexed the Shinnan Gunto, a fusion of the nine French islands
and the Dangerous Ground, at the door of the Philippines and Borneo, in March
1939. The Spratlys, after being dubbed as an area to avoid, was starting to be
perceived as a strategic territory with which one could control the internal sea
lanes.
Officially, only the French and British governments strongly protested the
complete annexation done by Japan. The United States declared its neutrality on
the question and reassured the parties that it had no interest whatsoever in the
small and isolated reefs. In fact, however, the United States State Department
was "double-talking," as it filed a secret note of protest, deeply influenced by a
memorandum of the United States Navy to the Japanese on April 5, 1939. The
memorandum as recalled by the author, stated that the western part of the
Spratlys (comprising one-third of the area) is well known and is disputed by
China, France, and Japan (omitting mention of the Philippines). However, the
eastern part (comprising two-thirds of the area) is less well known and is a danger
for navigation near the Philippines. The United States must pursue its research
and should feel free to develop all the islands, and reefs without any reference
to the three-mile limit (emphasis supplied). It also went on to say that in fact,
because of the secret surveys and the proximity of the Philippines, the claim of
the United States on the Dangerous Ground is not inferior to that of Japan. The
memorandum then concluded that:

"...with reference to the western third of the area, it is

recommended that the United States take no action, or assume no
attitude, which could be construed as recognizing the Japanese claim.
With reference to the eastern, two-third of the area, it is recommended
that the United States take a positive stand against the Japanese
claim."0 5

It is interesting to note that this protest was never communicated to the

government of the Philippine Commonwealth. Was this because the US Navy
intended to establish a secret naval base (for submarines) in the area of the
DangerousGround outside Philippine jurisdiction?

3
"Confidential Memorandum of the United States Navy Department (Apr. 5, 1939).
') I
World Bulletin, July-Dec. 2004

Transfer of the Secret Geographical Information

In September 1944, the British Admiralty transferred its secret charts to the
US Navy in order to prepare for landings in the Philippines. In 1945, the secret
Japanese charts of the Dangerous Ground fell into the hands of the Americans,
Australians, and Chinese naval authorities of Canton.'" The binary system of
iilitary and commercial maps was used up to the end of the Vietnam War in
1975. The civilian navigation would have in its hands the British map reproduced
abroad and left unmodified since 1881 up to 1954 when the Admiralty would
make important corrections, introducing the data of its missions before the war
but without giving any explanation in the notices to be relied on by navigators.
This detailed information would be subjected to an American embargo.17 Why
did the US Navy declare an embargo on useful information for civilians? What
was the role of the Dangerous Ground during the Vietnam War? Why did the US
Navy not correct the charts of the Spratlys? (See annex 1) These questions,
unfortunately, have yet to be answered, and will have to wait for the
declassification of the American archives.

Claims, Maps, and Tricks in the Spratlys

Being "beneficiaries" of the Japanese experience in the Spratlys during the

war and of the transfers and captures of secret charts, some States would later lay
claim, at various periods within the international political backdrop of the Cold
War and the rise of post colonial nationalisms over the totality of the area or some
of its parts.
Renaming the territory, for the sake of better appropriation and identity,
became a necessity. Thus, the Chinese name Nanshas (Southern Sands), which
was applied before the war to the Bank of Macclesfield, became, by a simple
geographical shift, the Spratlys in 1947." The name of Tuanshas, no longer useful
for the nine islands before the war, disappeared from the records.
The meaning of the Vietnamese Van Ly Truong Sa is strongly contested.
Some studies showed that during the 19 th century, Van Ly Truong Sa was the
Annamite translation of Wan Li Ch'ang sha in Mandarin and Van Li Tiong sha in a
southern Chinese dialect which, when translated meant Sand Bank of 10000 Ii.
According to experts in Chinese history, therefore, Wan Li Ch'ang sha was the

'Hancox & Prescott, supra note 1, at 144.

7Id., at 158.
'1Zoin Kevumn. Sadvrouglh Reef, IBRU BOUNDARY AND SECURrIY BULLETIN, Summer 1999, at
71I.
The Spratlys: A PastRevisited 23

name of the Macclesfield Bank in the 19' century.39 The Bank of Macclesfield
and the Paracels were well known areas by the navigators because of the dangers
they posed at the main commercial routes and the considerable number of ships
that ran aground in its waters. Such unfortunate events allowed the Annamite
company Hoang Sa to collect numerous products from the wrecks. British
explorers made no notice of any Annamite presence in the Spratlys during the
18' and 19"' centuries at the height of the great activities of this company (only
few fishermen of Hainan are mentioned on Itu Aba and Spratly island).4

"
As for the Philippines, it seemingly forgot the claim it made before the war,
and baptized the territory as the Kalayaans (Freedomland), excluding the Spratly
Island by keeping the argument of geographical proximity even if it would later
become unacceptable after World War II, and the reliance on res nullius which,
after all the activities in the area, became difficult to maintain. The islands in the
western part of the Spratlys being relatively wider, Tomas Cloma in 1956 could
not exclude them from his claim for purposes of fishing. The exclusion of the
Spratly Island was only a concession under pressure of the Taiwanese, playing on
the meaning of the term 'Spratly(s)' (which could either refer to the group or an
island) provoking a qui pro quo. This qui pro quo would be perpetuated in the
official claim of the Philippines in 1978. In fact, if the Spratly Island were to be
added to the Kalayaans, the claim of the Philippines nearly coincides with the
Japanese Shinnan Gunto.

Conclusion

The geographical arguments invoked officially or unofficially by some

States in the region before the war would later be superseded by other historical
rights considered more acceptable. The Spratlys, having been for decades an area
to avoid, suddenly became, in the last decade before the war, a secret area with
the information on the area necessarily being limited. It is not surprising then
that the two Chinas and Vietnam operated a fusion in their territorial perception,
between the Paracels (rich in historical records) and the Spratlys, as can be seen
with the numerous books on the question. These books and articles study at
length the Paracels and then conclude that the Spratlys follow the same historical
path under the political control of the Vietnamese or Chinese (according to the
involvement of the authors).
In short, we have come a long way from the doubts and uncertain claims of
the pre-war period. The claims over the Spratlys are crystallizing gradually
following the discovery of potential resources (such as the rumored oil deposits),

"See M. Samuels, supra note 14, at 50.

4
(See for example the NAUTICAL MAGAZINE and CHINA SEA PILOT OF THE ADMIRALTY.
24 World Bulletin, July-Dec. 2004

in the area. Nevertheless, the importance attached to these territorial claims vary
from nation to nation. The 'honor' of the nation, strong emotions, and even
poems are alluded to in the claims of the Chinese and the Vietnamese. In the
Philippines, the Spratlys question is essentially left to the hands of specialists,
lawyers, politicians, and military officers, as it has not yet deeply penetrated the
national consciousness. Filipino students have been familiarized with a map of
the national territory with some details of the Spratlys for the first time only in
1999. However, the Filipino sentiment of having identity with and having a stake
in the Spratlys grew stronger with the discovery of the Chinese occupation of the
Mischief Reef in 1995,"1 wherein the Filipinos did not hesitate to recall the
creeping invasion by the Japanese, and by the Scarborough Shoal affair in 1998.
As the new law of the sea, the UNCLOS (United Nation Convention on the
Law of the Sea)," which has been in force since 1994, is silent on the sovereignty
question, the resolution of the conflict can therefore only be diplomatic. The
actions of Vietnam in the beginning of 2004 (bringing some "tourists" to some
islets), however, show how the measures of confidence building, like the signing of a
code of good conduct, remain fragile.

4
See Celeste Lopez and James Conachy, Spratlys Continue to Loon as Asian Flasipoint.
December 13, 1999. Available at <http://www.wsws.org/articles/1999/decl999/spra-dl3.shtml>.
42
See Sol Jose Vanzi, Probe Of Scarborough Shoal Incident Ordered. Available at <http://www.
newsflash.org/l999/05/Aihlol 1347.htm>.
4Convention on the Law of the Sea, December 10, 1982, 1833 U.N.T.S. 3.
Entered into force
on November 16, 1994.
The Spratlys: A Past Revisited 25

ANNEX 1

The Twenty-one Non-Existent Features in the Spratlys

But Still on American and Chinese Nautical Charts

International Name' Chinese Name'

Ardasiers Breaker Xsi Po Chaio
Cornwallis Reef
Dhaulle Shoal Xsia Yao An Chiao
Director Reef Chih Hsieng Chiao
Fancy Wreck Shoal Fan Ai An Sha
Ganges Reef Heng Chiao
Ganges North Reef Pei Heng Chiao
Glasgow Bank Nan Le An Sha
Gloucester Breakers Po Lung Chiao
Len Dao
Lizzie Webber Li Wai Tao
Marino Cay Yu Lu Tao
North Viper Shoal Tu Hu An Sha
North East Shea
Pennsylvania Reef Kun Ming Chiao
Sandy Shoal Shen Hsien An Sha
Shinko Shoal
South West Shea
Stag Shoal Yin Tao An Sha
3d Thomas Shoal Ho Ping An Sha
Viper Shoal Po Wei An Sha

'According to Hancox & Prescott, supra note 11, at 17.

"According to Hsiao Shi-Ching, supra note 4, at 176.
 26 Weiold aulictin, /uih-I)c 2004
I
I
ANNEX 2

The Spratlys alid the Dangerous liround

LEGEND

/
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ON W*1AI~
0.nf4.rou.Groun~ d b
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Secre route dscovered by aa

a tf / TausF
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by Frac in 1 933 i I-

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o sosoo---

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*

o /Crna *

' MarshatM
unerW

ws PrW a S

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-

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II
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allow R
I

II

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- I
 The Spratlys: A PastRevisited 27

I
*

.
I

* - ----------

*-tw~d ~ NWS~7 /Red Uuik

2 :* W~ kh b
/ro
Tftlrw Ok
9k e.,a

*~d S*

aw ShT~ne,

* ,I *'

PALAWAN
(Philippines

SABAH
(Maiaysle)