Treaties & Conventions

Eritrea - Yemen Arbitration

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AWARD
Phase I: Territorial Sovereignty and Scope of Dispute

CHAPTER IX - Petroleum Agreements and Activities

389. It is a singular fact of the proceedings that neither party on its own motion pleaded, described, or relied upon oil contracts and concessions relating to the Red Sea and the disputed Islands. The pleadings of the parties in respect of oil contracts and concessions came in response to questions posed by a Member of the Tribunal at the close of its hearings in February 1998; in the absence of those questions, it appears that those pleadings would not have been made in this phase of the proceedings.

390. Nevertheless, in response to questions put to them, both parties submitted considerable data and argument. In the view of the Tribunal, that data and argument left some questions unanswered. It accordingly called for renewed hearings to be devoted solely to Red Sea petroleum contracts and concessions. Those hearings took place in London from July 6-8, with the benefit of substantial further written pleadings as well as oral argument, in the course of which, and after which, still further material data was introduced. In those hearings, Eritrea largely maintained that these contracts and concessions were probative of little that was relevant to the issues before the Tribunal, whereas Yemen maintained that they were of major significance in support of its position. Yemen contended that the pattern of Yemen's offshore concessions, unprotested by Ethiopia and Eritrea, taken together with the pattern of Ethiopian concessions, confirmed Yemen's sovereign claims to the disputed Islands, acceptance of and investment on the basis of that sovereignty by oil companies, and acquiescence by Ethiopia and Eritrea. Yemen stated that lack of time had been the reason for its not having pleaded the contracts and concessions on its own initiative.

The Provisions of the Pertinent Contracts and Concessions

391. Both Yemen and Eritrea have concluded contracts and concession agreements for oil exploration, development, production, and sale of commercial quantities of petroleum that might be found under the Red Sea. While in the event no such quantities have so far been found, those contracts and concessions merit the Tribunal's consideration for what they show and do not show. Of particular significance for the issues before the Tribunal may be any effectivités arising out of or associated with those contracts and concessions.

Contracts and concessions entered into by Yemen

392. Yemen has submitted information on Red Sea contracts and concession agreements as follows.

Shell Seismic Survey, 1972

393. Yemen states that, in 1972, its predecessor, the Yemen Arab Republic, entered into a contract with Shell International Petroleum Company for "a major geophysical scouting survey in the Red Sea". It maintains that the survey, carried out on Shell's behalf by Western Geophysical Company of America in March 1972, involved the shooting of seismic reconnaissance lines in the area of the Red Sea that encompassed the islands of the Zuqar-Hanish group, the Zubayr group and Jabal al-Tayr, and from that fact argues that the survey is supportive of Yemeni sovereignty over those Islands. It states that, as a result of the survey, Shell decided that the southern third of the area surveyed, a substantial zone that encompassed the Zuqar-Hanish group, was not promising, but that it would take up a concession contract for a more northerly block which included Zubayr Island.

394. Yemen has not been in a position to provide a text of the survey contract, whose existence Eritrea questions. It does provide a report of Shell International Petroleum Maatschappij N.V. of January 1977, which refers to an offshore scouting survey whose results were used to select the area of the agreement discussed below. It introduced as well in the course of the hearings on 7 July 1998 the Final Operations Report, Marine Seismic Survey, Offshore Yemen (Red Sea) by Western Geophysical Company of March 1972. That report states that the objective of the survey was to provide a preliminary seismic coverage of "the concession area" (though at that stage there was no concession), and notes that the field office and base of operations for the seismic survey were in Massawa, Ethiopia. The report attaches a map of the "approximate area covered by seismic program" (Plate I), which extends right up to the Ethiopian coast.

395. That map indicates that the survey area is irrelevant to questions of title; Yemen hardly is claiming jurisdiction over the territorial waters of Eritrea, and could not have meant to do so by the authorization or performance of the seismic survey in question. The fact that the survey area embraced Islands in dispute accordingly is not probative.

Shell Petroleum Agreement, 1974

396. The Yemen Arab Republic and Deutsche Shell Aktiengesellschaft concluded a Petroleum Agreement on 16 January 1974. The contract area was defined as meaning the specified area and its subsoil and seabed "under the jurisdiction of the Yemen Arab Republic". It comprised a Red Sea block north of the Zuqar and Hanish islands, which islands it names but does not encompass. It does not encompass Jabal al-Tayr, which is to the west of the contract area, nor does it name it. It names none of the islands it does encompass. It includes the Zubayr group among the unnamed islands within the contract area.

397. A reconnaissance survey was contracted for by Shell that entailed seismic, gravity and magnetic data acquisition in the contract area; the survey report does not state that the survey was carried out within the territorial waters of the Zubayr group. A well was drilled by Shell at a point far from the islands in dispute; oil was not found in commercial quantities; and the agreement was terminated.

398. In a Final Report on the Exploration Venture of Yemen Shell Explorations GMBH Yemen Arab Republic of May 1981, it is stated that: "The concession area granted to Deutsche Shell . . . under the terms of the Petroleum Agreement of 16 January 1974 extended from . . . the Yemen mainland in the east to approximately the median line of the Red Sea in the west."

399. In view of that statement and the fact that the concession contract speaks not of an area and its subsoil and seabed under the sovereignty but under the jurisdiction of Yemen, the Tribunal concludes that the 1974 Shell concession was granted and implemented in exercise not of Yemen's claims to sovereignty over the islands and their waters within the contract area but in exercise of its rights to the continental shelf as they then were. It further is of the view, in the light of the foregoing factors, that, since the contract does not name the Zubayr group and since Shell conducted no activities on the islands of the Zubayr group or within their territorial waters, the 1974 Shell Petroleum Agreement was entered into without particular regard to the Zubayr group. Those islands appear to have been included within the contract area because the Zubayr group fell on the Yemeni side of the median line, on a continental shelf over which Yemen could exercise jurisdiction.

400. At the same time, the Petroleum Agreement between Yemen and Shell was known to the industry, was published, and its existence and, with sufficient diligence, its terms, could have been known to Ethiopia had it followed the pertinent publications (such as Barrow's Basic Oil Laws and Concession Contracts). Ethiopia may be argued to have had notice, at any rate, constructive notice, of its existence and provisions. It made no protest about the agreement, despite its contract area including the Zubayr group to which Eritrea now lays claim. Eritrea maintains that Ethiopia in fact was unaware of the terms of the agreement; that, as a poor country locked in civil war, Ethiopia cannot be charged with gaining knowledge of it, and that, in any event, since conclusion and publication of a concession contract is not a title-generating act, there was nothing to protest in the absence of concrete and visible activities of Shell or the Yemeni Government on the Zubayr group. Yemen, for its part, attaches significance to the failure of Ethiopia to protest. Such absence of protest by Ethiopia, and later Eritrea, characterizes all the concessions granted by Yemen in the Red Sea, and will be evaluated below.

401. The area of the 1974 Petroleum Agreement between Yemen and Shell is further reproduced in a map dated December 1976. That map was prepared by Shell, and is found in a Shell Report of January 1977 marked "Confidential". It is not contended that it has been published or could or should have been known to Ethiopia. It shows the area of the agreement and the areas of detailed survey within it (which are not near the Zubayr group). To the west of the area of the agreement, there runs a line which is described as the "Approximate tentative international boundary". That boundary runs west of the Zubayr group and west of Zuqar and the Hanish islands as well. No evidence was offered about the considerations that in the view of the drawer of the line gave rise to it, nor did Eritrea specifically comment upon it. In Yemen's Comments on the Documents introduced by Eritrea after the Final Oral Argument, 29 July 1998, maps 5 and 6 prepared by Yemen are described as reproducing the line.

402. It appears to the Tribunal that the author of the Shell map was of the view that the "approximate tentative international boundary" was to be drawn on the basis of Yemeni sovereignty over most of the disputed islands and all of the larger ones. That impression is supported not only by the fact that the "approximate tentative international boundary" runs west of those islands. It is strengthened by the author's having accorded the major disputed islands, including Zuqar and the Hanish islands, an influence on the course of the boundary as drawn.

Tomen-Santa Fe Seismic Permit, 1974

403. A Seismic Permit Agreement was concluded between the Yemen Arab Republic and Toyo Menka Kaisha Ltd. ("Tomen") in 1974, which was extended to include Santa Fe International Corp. The agreement was initially characterized by Yemen in these proceedings as a "concession", which was contested by Eritrea; when its text was later introduced, it was found to be entitled, "Seismic Permit", and to provide for Tomen's conducting a marine seismic survey in the contract area. The contract area is specified by the contract to be outlined in "Exhibit A"; however, Yemen has not placed "Exhibit A" in evidence and has not offered an explanation for its absence from the text of a contract otherwise provided in full. The contract itself gives the coordinates of the contract area and Yemen has placed in evidence maps which it states were prepared for these proceedings on the basis of those coordinates.

404. Yemen affirms on the basis of those coordinates and maps that the contract area embraced the whole of Zuqar and the Hanish islands. However, in an "Exploration History Map" prepared by the United Nations Development Programme (UNDP) and the World Bank, undated but apparently prepared late in 1991, on whose probative force Yemen repeatedly has relied, the western line differs. The western line appears to run through, rather than to the west of, the southern extremity of Greater Hanish Island (the explanatory block on the map reads, "Tomen & Santa Fe, started 1974, ended 1975, seismic, 2150 km."). It may be that the line on the UNDP map runs through Greater Hanish along a median line, as two other concessions, one concluded by Yemen and another by Eritrea, appear to do.

405. The Tomen-Santa Fe Seismic Permit Agreement recites that Yemen has "exclusive authority to mine for Petroleum in and throughout" the contract area, and that the contract area "means the offshore area within the statutory mining territory of Yemen" described in the permit. The term of the contract is six months (and appears to have been extended to a year). The contract specifies that, "The execution of the work program shall not conflict with obligations imposed on the Government of Yemen by International Law". It provides that the contractor shall have the right of ingress to and egress from the contract area and adjacent areas. It further provides that Tomen shall, within the contract term, have the right to apply for a Petroleum License for all or part of the contract area for the exploration, development and production of petroleum, the terms of which are to be agreed upon guided by the terms of similar licenses in OPEC countries.

406. The Seismic Permit Agreement, while not a concession agreement, accordingly is a petroleum-related contract that looks towards the conclusion of such an agreement in certain circumstances. Its assertion of an exclusive authority of Yemen to mine for petroleum within the contract area, and its reference to the statutory mining territory of Yemen, is consistent with conclusion of a contract for exercise of Yemen's rights on its continental shelf. Decree No. 16 concerning the Continental Shelf of the Yemen Arab Republic of 30 April 1967, in proclaiming Yemeni sovereign rights over the seabed and subsoil of its continental shelf and the continental shelf of its islands, asserts the exclusive right to prospect for natural mineral resources of the shelf. The contractual reference to obligations imposed upon Yemen by international law is also of interest, and may be a reference to limited continental shelf rights. In the view of the Tribunal, the Seismic Permit Agreement of itself does not constitute a claim by Yemen to sovereignty over the islands within its contract area, nor does Eritrea's failure to protest the agreement indicate acquiescence in any such claim. However to some extent it presupposes some measure of title to any islands contained within the contract area. The contract area included the land territory and territorial waters of the islands within its extent; this would have included the land territory and also the territorial waters of some or all of Greater Hanish and all of Zuqar and Lesser Hanish.

407. Eritrea argues that in any event seismic surveys are not indicative of sovereign claims. It relies on the Law of the Sea Convention, Part XIII on "Marine Scientific Research". Article 241 provides: "Marine scientific research shall not constitute the legal basis for any claim to any part of the marine environment and its resources". Article 246 provides for the regulation by coastal states of marine scientific research in the exclusive economic zone and on the continental shelf; research which shall be conducted with the consent of the coastal state. States shall in normal circumstances grant their consent for marine scientific research projects by other states or competent international organizations "in order to increase scientific knowledge of the marine environment for the benefit of mankind." In the view of the Tribunal, these provisions do not relate to the seismic and other explorations for petroleum for commercial purposes carried out by licensees of the Parties in the circumstances of these proceedings.

408. Accordingly, activities undertaken in pursuance of the Tomen-Santa Fe Seismic Permit and other like authorizations by licensees of the Parties have a certain importance, and must be weighed by the Tribunal. In the period between 23 July 1974, when the vessel Western Geophysical I departed from Hodeidah, and the completion of its voyage on 9 September1974, a period of some six weeks, "Of the originally scheduled 1500 miles of program, only 1336 miles were recorded due to . . . dangerous shoaling in the offshore islands area". That suggests that there were difficulties in working close to the islands; there are a number of references in the report to the Zuqar and Hanish islands, but no indication is given that suggests any activity on the islands. It is not easy to deduce from the text and maps provided whether seismic work was performed within the territorial waters of the islands. One, for example, speaks of an aerial survey 2 square miles in extent "East of Little Hanish Island". But how far east  - and whether within or without the territorial waters of Little Hanish Island  - is not shown, nor was the question precisely pursued by counsel for Yemen, who confined himself to stating that operations were conducted "very close" to the islands. Figure l of the Santa Fe Report, "Location map & geophysical map", indicates that the areas of detailed survey avoided the immediate waters of the islands, but the map of itself does not show at what proximity to the islands seismic work was conducted. However, if, for example, the geographic position stated "West side Zuqar Island; southwest intersection Lines 50 and 8" is matched against the survey grid found in Figure 1 - each of the bigger blocks being 10 square kilometres - it appears that seismic activities did extend well into Zuqar's territorial waters. As far as can be determined from a review of the report, it is uncertain whether the same can be said for the waters of the Hanish islands.

409. The Santa Fe Report continues: "During the seismic survey, the Zuqar and Hanish islands were observed from aboard ship by the writer, appearing to be made entirely of volcanic rocks . . . Later, Mr. Hazem Baker, a geologist with the Yemeni government, went ashore on Zuqar Island and collected samples . . . all basaltic." It seems reasonable to presume that he believed that he was landing on an island at least under Yemeni jurisdiction.

Hunt Oil Company Offshore Production Sharing Agreement, 1984

410. Yemen and Offshore Yemen Hunt Oil Company on March 10, 1984 concluded an Offshore Area Production Sharing Agreement. It recites, "Whereas, all Petroleum in its natural habitat in strata lying within the boundaries of yemen is the property of the state; and Whereas the state wishes to promote the development of potential oil resources in the Area and the contractor wishes to join and assist the State in the exploration, development and production of the potential Petroleum resources in the Area . . ." Hunt is appointed Contractor "exclusively to conduct Petroleum Operations in the Area described . . . the state shall in its name retain title to the area covered . . .". The agreement provides that Yemeni laws shall apply to the Contractor provided that they are consistent with the agreement, and that the rights and obligations of the parties shall be governed by the agreement and can be altered only with their mutual agreement. The agreement was approved by Government Decree. The coordinates of the area covered by the agreement are set out in Annex A, to which is attached a map at Annex B showing those coordinates but not naming or showing any of the disputed islands. Yemen has prepared and submitted a map to the Tribunal which shows the Hunt concession as running in the west very close to the edge of, but not including, Jabal al-Tayr, and, at the southern end of the contract boundary, just including the Zubayr group.

411. In fulfilment of its exploration obligations under the agreement, Hunt contracted with Western Geophysical to conduct a seismic survey of the concession area. It did so in 1985, "infilling" Shell data collected a decade earlier. That operation included the area of the Zubayr islands and, it is claimed, Jabal al-Tayr even though the latter did not fall within the concession area. Seismic soundings were taken "around the Zubayr islands and Jabal al-Tayr" but it is not claimed or shown that seismic activities were conducted within their territorial waters. No activities on the Islands are alleged or shown. Aeromagnetic surveys in the contract area were conducted by an aircraft flying from Yemen, and consequently permission to fly through Yemeni airspace was sought and accorded; that fact neither supports nor detracts from Yemen's claims about the status of the contract area. Equally neutral is the fact that, in connection with well drilling, permission was sought "to enter YAR territorial waters and conduct offshore drilling operations", which were nowhere near the Islands. Two wells were drilled far from the Islands; neither produced oil in commercial quantities, and the concession was relinquished.

412. The Production Sharing Agreement does not in terms state a claim of sovereignty of Yemen over the concession area, and, as noted, it takes no notice of the Islands within it, verbally or in the annexed map. It could be interpreted as a concession issued within the area demarcated by a median line in implementation of Yemen's rights on its continental shelf, a concession which includes the Zubayr group but stops just short of including Jabal al-Tayr. It may be said that if it was the intention of Yemen in issuing the concession to assert sovereignty over the disputed islands, the concession would have included Jabal al-Tayr. What seems likelier is that this concession, as others, was issued with commercial considerations in mind and without particular regard to the existence of the Islands. The fact that title to the contract area is stated to remain in the State of Yemen is not determinative; Yemen holds title to resources on and under its continental shelf; but since the agreement specifies that Yemen retains title "to the area covered" that may be read as a reservation of sovereign title. The reference to the "boundaries of Yemen" is also suggestive of a claim of sovereignty, though "boundaries" does not exclude continental shelf boundaries. The Hunt Production Sharing Agreement was reported in the petroleum literature and gave rise to no protest on the part of Eritrea.

BP Production Sharing Agreement, 1990

413. Yemen and British Petroleum concluded a Production Sharing Agreement on October 20, 1990, whose terms are very similar and in pertinent respects identical to the foregoing Hunt Agreement. It covers the same Antufash Block offshore Yemen that Hunt operated in earlier, and thus embraces the Zubayr islands but not Jabal al-Tayr. However, and this may reflect the policy of Yemen in respect of potential petroleum blocks offered by it in the 1990s, the BP Agreement's description of the block is more specific than that found in the Hunt Agreement, providing: "Whereas, the State wishes to promote the development of potential Petroleum Resources in the Agreement Area block 8, As-Sakir, Shabwa Province, ROY . . ." The text of the agreement was published in Barrow's. It elicited no protest from Eritrea.

414. BP conducted extensive aeromagnetic surveys of the agreement area. Low-level flights, conducted with the permission of the Government of Yemen, covered the Area, including the Zubayr islands, and Jabal al-Tayr though it was outside the Area. A Yemeni military officer accompanied the aircraft during its survey. Survey results were unpromising and BP relinquished its rights in the Area in 1993.

415. The Tribunal does not attach much importance to overflights by either of the parties of the islands in dispute. In the circumstances of the case, it is not clear that overflights of these uninhabited islands are tantamount to a claim of jurisdiction, still less sovereignty, over the Islands. However the agreement's characterization of the Antufash block as comprising or being within a province of the Republic of Yemen is a factor of significance in favour of Yemen; it indicates a sovereign rather than a jurisdictional claim. At the same time, the fact that the agreement was entered into in 1990 and published about that time is noteworthy. Ethiopia was then locked in its final struggle with the Eritrean liberation movement, the Mengistu regime was close to collapse, and to suggest that Eritrea today should be taxed with Ethiopia's failure during that period to find and protest the terms of the agreement may be unreasonable.

Total Production Sharing Agreement, 1985

416. Yemen and Total-Compagnie Française des Pétroles concluded a Production Sharing Agreement in 1985, to which Texaco later became party. Its terms appear close to those of the Hunt Agreement concluded the year before, summarized in pertinent passages above. It however recites, "Whereas, all Petroleum in its natural habitat in strata lying within the boundaries of Yemen and in the seabed subject to its jurisdiction is the property of the State; . . ." Since the area of the agreement is onshore as well as offshore, this could be read as an indication of an offshore claim only to jurisdiction and not sovereignty, and could be taken as an indication of such a Yemeni assumption in other petroleum agreements. The Area is stated to be described in Annex A and shown on the map labelled Annex B, but neither Annex is attached to the text submitted by Yemen to the Tribunal. However, it is common ground between the parties that the Total Agreement's western line runs to the east of Zuqar and the Hanish islands. There is no ground for concluding that this fact suggests a lack of entitlement of Yemen to enter into agreements embracing the disputed islands. It rather again suggests that the petroleum agreements entered into by Yemen were concluded without regard to the Islands.

417. Since the agreement area does not include any of the islands in dispute, it is of limited interest for these proceedings, except in the following respects. Total commissioned seismic studies, which were concentrated between the agreement's western line (which fell short of the Hanish islands) and the coastline of Yemen. The single well drilled - which proved unproductive and led to the agreement's termination in 1989  - was distant from the Hanish islands and towards the coast. However, less detailed seismic surveys were conducted to the west of the Hanish islands, outside the contract Area, which entered territorial waters of those islands. Yemen acted as if it were entitled to authorize, and Total's agent acted as if it were entitled to conduct, those surveys in Hanish territorial waters.

418. Having come to know the Hanish islands through its offshore concession, Total in 1993 decided to become a sponsor of the French Ardoukoba scientific mission to the islands to study marine life in the reefs. Total requested and received Yemeni Government permission to establish a landing strip on Greater Hanish so that a Total aeroplane could transport equipment to it. It is also claimed that Total sought and received permission to establish a radio station on Greater Hanish and to permit visiting scientists to use its frequency; evidence in support of this claim has not been provided. Evidence has been provided showing that access to the Hanish islands, described by Total as uninhabited, was subject to authorization delivered by the "Central Operation of the Army". After the conclusion of the Ardoukoba mission, Total produced a report that referred to "les îles Hanish en république du Yemen". Thereafter it sought and received governmental authorization to improve the landing strip and fly Total personnel to Greater Hanish for rest and recreation. For a time, a Total aircraft flew frequently to Greater Hanish, carrying passengers for these purposes.

419. Incidental as it may have been to Total's Petroleum Agreement, the building and use of an airstrip on Greater Hanish is in the view of the Tribunal a material effectivité. It demonstrates the exercise by Yemen of jurisdiction over Greater Hanish, a recognition of that jurisdiction by Total, and the conduct of visible indicia of that jurisdiction - an airstrip in active use  -  over a period of time. Eritrea appears to have been unaware of it and in any event made no protest. However, Eritrea has introduced evidence showing that a report of activities of a French company in the waters around Greater Hanish was received in May 1986, the period when Total was operating in that area; that an Ethiopian patrol vessel was dispatched to the area to investigate, and that nothing was found. This evidence suggests that, in the perspective of Eritrea, sovereignty over Greater Hanish lay with it.

Adair International Production Sharing Agreement, 1993

420. Yemen and Adair International entered into a Production Sharing Agreement in 1993. The text of the agreement has not been offered in evidence and accordingly the Tribunal is not in a position to analyse it. The agreement was not ratified by Yemen and did not come into force. Yemen has, however, provided maps of the agreement area which show it as falling within Block 24 or the Al Kathib block in which the Tomen-Santa Fe area fell. It maintains that Yemen had on offer an offshore block that included the whole of the Hanish islands, and that Adair chose to take a contract area slightly less than the total block on offer. The maps of the Adair area provided by Yemen show the western line to cut through the southern portion of Greater Hanish Island, leaving the larger part, but not all, of Greater Hanish within the area of the agreement. It explains that Adair drew that western line for commercial reasons. As far as the Tribunal can judge, the Adair Agreement's western line roughly runs along a median line between the coasts of Yemen and Eritrea, drawn without regard to the islands in dispute.

Blocks Offered by Yemen

421. Beginning in 1990, Yemen no longer responded to proposals by prospective concessionaires for rights in areas drawn by them, but began offering concession blocks, dividing most of Yemen and its offshore into blocks. It states that the blocks include the Zubayr islands and the Hanish islands  - it offers no explanation for not including Jabal al-Tayr - and maintains that this is further evidence of Yemen holding itself out as the sovereign of disputed islands.

422. Such weight as the Tribunal might be disposed to give to that contention may be qualified by the evidence about the western lines of the offshore blocks provided by Yemen. Yemen has submitted not only its depiction of the blocks. It has also submitted and relied upon, as "expert opinion evidence confirming Yemen's exercise of State authority over the Hanish islands and other islands", a number of maps prepared by Petroconsultants S.A. of Geneva, illustrations of Petroconsultants' series, "Foreign Scouting Service, Current Status". The maps are dated from 1989 until November 1997. Three of these maps show a western line of Yemen's relevant block running not to the west of Greater Hanish Island but through it, as the Adair Area line does. The map for 1994 is linked to the Adair Agreement but the maps for 1996 and 1997 are not.

Petroleum Agreements and Activities of Ethiopia and Eritrea

423. Ethiopia in the 1970s entered into a number of offshore concession agreements, which stop short of the deep trough that runs through the middle of the Red Sea. At that time, oil technology was unable to support drilling in so deep a trough. While Yemen maintains that these agreements - which it rather than Eritrea introduced in these proceedings - showed a recognition by Ethiopia and the companies concerned that Ethiopia was not entitled to issue concessions embracing the disputed islands, in the view of the Tribunal these agreements simply reflect technological and commercial realities and carry no implication for the rights of the parties at issue in these proceedings. It is reinforced in this conclusion by the fact that Ethiopian concessions typically contain a formula such as the following (as, mutatis mutandis, do maps attached to Yemeni concessions): "The description of the eastern boundary of the contract area does NOT necessarily conform to the international boundaries of Ethiopia and accordingly nothing said herein above is to be deemed to affect or prejudice in any way whatsoever the rights of the Government in respect of its sovereign rights over any of the islands or the seabed and subsoil of the submarine area beneath the high seas contiguous to its territorial waters or areas within its economic zone." The Tribunal also finds unenlightening two Red Sea offshore petroleum contracts concluded by Eritrea as late as 1995 and 1996, which were promptly protested by Yemen as overlapping its waters. But Ethiopia's contract with International Petroleum/Amoco is important.

International Petroleum /Amoco Production Sharing Agreement, 1988

424. Ethiopia concluded a Production Sharing Agreement with International Petroleum Ltd. of Bermuda on May 28, 1988. The concession covered "the onshore-offshore area known as the Danakil Concession in the PDRE" (People's Democratic Republic of Ethiopia). It recites that, "WHEREAS, the title to all Petroleum existing in its natural condition on, or under the Territory of Ethiopia is vested in the State and people of Ethiopia . . . and the Government wishes to promote the exploration, development and production on, in or under the Contract Area . . .", the Government grants to the Contractor "the sole right to explore, develop and produce Petroleum in the Contract Area . . ." On November 1, 1989, 60% of the contract was assigned to Amoco Ethiopia Petroleum Company. Amoco assumed operative responsibility under the assignment.

425. The map attached to the 1988 Production Sharing Agreement shows "Ethiopia-Red Sea Acreage", onshore and offshore, the latter's eastern line running through the southwest extremity of Greater Hanish Island. The description of the Contract Area runs "To the Offshore point 13 at the intersection of LAT 14 DEG 30 with the international median line between North Yemen and Ethiopia, then along the Offshore median line". The agreement contained a force majeure clause, including wars, insurrections, rebellions and terrorist acts, during which the life of the contract would be prolonged. Apparently in view of the fighting between Ethiopian and Eritrean units, force majeure was declared on 9 February 1990 and as of June 1992 was stated to be still in effect.

426. However there is ambiguity about the extent of the Contract Area, at any rate in depictions of it on maps. Amoco Ethiopia Petroleum Company filed four Annual Reports with the People's Democratic Republic of Ethiopia which are in point.

427. The Annual Report for 1989 recounts that geologic activities were undertaken in 1989, that Delft Geophysical Company was awarded a contract to acquire marine seismic, gravity and magnetic data, and that a scout trip by Delft was completed in December. Preliminary seismic interpretation and mapping was initiated. The map attached to the 1989 Report shows virtually all of Greater and Lesser Hanish within the area of the contract, i.e., considerably more than does the map attached to the Production Sharing Agreement.

428. The Annual Report for 1990 observes that activities were suspended with the advent of force majeure on February 9, 1990; as of the end of 1990, the security situation within the Danakil area was considered to remain unsafe for normal seismic operations. It reports on considerable geologic and geophysical activity before that time, and lists some $2,000,000 in expenditures under the agreement. While the description of the Contract Area matches that in the 1989 report, two maps are attached to the 1990 Annual Report. The first map of the Danakil Contract Area shows the eastern line as running not through but rather west of the Hanish islands. The second map of that Contract Area shows virtually all of Greater and Lesser Hanish within the Contract Area, duplicating the map attached to the 1989 Annual Report.

429. The 1991 Annual Report notes that force majeure has effectively extended the initial period of the contract. While normal seismic operations were unsafe in 1991, substantial technical evaluation of existing data continued. The map of the Contract Area in the 1991 Annual Report shows virtually all of the Hanish islands within the Contract Area, duplicating the maps to that effect in the 1989 and 1990 Reports.

430. The 1992 Annual Report reports limited reprocessing work. It states that Amoco and International Petroleum representatives met with officials of newly independent Eritrea in Asmara on June 24, 1993, when assurances were received that the Danakil Production Sharing Agreement would be recognized by Eritrea. It attaches a contract summary entitled, "Eritrea Danakil Block" and gives an expiration date of February 9, 1997, "to be delayed because of force majeure". The governing law is now described as Eritrean. The Danakil Block map attached to the 1993 Annual Report shows virtually all of the Hanish islands within the Contract Area, as does a "composite magnetic map of the Danakil concession".

431. A map prepared by Petroconsultants, on whose maps Yemen has repeatedly relied, also shows the Amoco Contract Area as embracing the greater part of Greater Hanish.

432. Yemen, while not denying that it never protested the terms or geographical extent of the International Petroleum-Amoco Production Sharing Agreement, argues that it could not be charged with doing so. It observes that an article in the Petroleum Economist of October 1991 presents a map which shows an Amoco concession that does not include the Hanish islands. (The UNDP map, which is an "Exploration History Map", does not name the Amoco concession.) Yemen also maintains that the Amoco contract lasted only some three months and that, by the time it might have come to its attention, force majeure prevailed, which might have induced Yemen to take no action.

433. The Tribunal does not find Yemen's position entirely persuasive. As the Annual Reports summarized above demonstrate, the IPC/Amoco contract was extended well beyond three months and into the days of Eritrean independence; its life compares with that of the contracts on which Yemen relies. If Yemen had secured and read Amoco's Annual Reports - annual reports of American oil companies are generally publicly available for the asking - and if Yemen had evinced the alertness it did in respect of Eritrea's contracts of 1995 and 1996, it would have seen that Ethiopia claimed the right to contract for the exploration, development and production of oil in an area claimed as its territory that included some or virtually all of Greater Hanish islands. Amoco is a major player on the international petroleum scene, and in the immediate area; indeed, one of the maps introduced into evidence by Yemen, shows Amoco together with BP in the Antufash block and shows the Danakil Amoco concession angling into the Adair area in the Al Kathib block.

434. Yemen in its argument has made a great deal about what it alleges is the failure of Ethiopia or Eritrea to grant any concession contract that included disputed islands, and their failure to protest grants of Yemen that did include those islands. But it has been demonstrated that, in the lately pleaded International Petroleum-Amoco Production Sharing Agreement, Ethiopia did grant a concession including much or virtually all of the Hanish islands, and that Yemen failed to protest that agreement. It is of further interest that the map attached to the Production Sharing Agreement speaks of drawing the boundary along the international median line between Yemen and Ethiopia.

435. Eritrea also claims certain pertinent effectivités. It has submitted a copy of an Ethiopian radio transmitting license granted circa 1988-89 (the earlier date on the contract is apparently of the Ethiopian calendar) to Delft Geophysical Co. for the establishment of a station on Greater Hanish Island, presumably in connection with the seismic work which Amoco had contracted with Delft to perform. It has provided the text of a detailed order to the most senior military commanders to provide protection to a petroleum exploration expedition of the Ethiopian Ministry of Mines and Energy to be deployed to areas "including Greater Hanish Island". It has provided an Ethiopian memorandum on oil exploration in the Red Sea carrying the Ethiopian date of April 13, 1982 (which is circa 1989 AD.), stating that Amoco-Ethiopia Petroleum Company "has installed navigation beacons to enable it to conduct seismic study . . . including on Greater Hanish Island". The memorandum continues:

"An Amoco professional team of contractors will be available starting 3rd week of December to select areas for the installation as follows:

For two weeks installation of navigation beacons on the 8 selected locations;

At the end of the two-week period, conduct 6 week-long seismic tests . . . ."

and it calls for ensuring the protection of the contractors and their equipment during beacon installation and for the protection of the installed beacons. It further requests protection for the Delft Geophysical ship while it is conducting seismic tests. Another memorandum states that an Amoco contracting team will conduct helicopter patrols to select locations for the installation of navigation beacons, including locations "on Greater Hanish". It is not entirely clear whether these activities were in fact completed, although the Amoco Annual Report for 1989 does corroborate that Delft Geophysical did conduct a scout trip in December of 1989 (see para. 427, above).

* - *

436. In the light of this complex concession history, the Tribunal has reached the following conclusions:

437. The offshore petroleum contracts entered into by Yemen, and by Ethiopia and Eritrea, fail to establish or significantly strengthen the claims of either party to sovereignty over the disputed islands.

438. Those contracts however lend a measure of support to a median line between the opposite coasts of Eritrea and Yemen, drawn without regard to the islands, dividing the respective jurisdiction of the parties.

439. In the course of the implementation of the petroleum contracts, significant acts occurred under state authority which require further weighing and evaluation by the Tribunal.

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