Annex 1toOP 2003/30
CASE CONCERNING OIL PLATFORMS
(Islamic Republic of Iran v. United States of America)
RESPONSE TO THE ISLAMIC REPUBLIC OF IRAN TO THE QUESTIONS OF
JUDGE RIGAUX ADDRESSED TO BOTH PARTIES
FIRST QUESTION:
"What is the legal status of oil platforms constructed by a State on its continental shelf?
What types of jurisdiction are exercised over such installations? How does the status of
oil platforms vary depending on whether they are situated within a State's territorial
sea or outside it?"
The legal status of oil platforms is regulated by the provisions of the United Nations
Convention on the Law of the Sea, signed at Montego Bay on 10 December 1982, United
Nations Treaty Series,vol. 1833 p. 3. The Islamic Republic oflran is a signatory to the 1982
Convention, but has not yet ratified it. However, the provisions of the Convention re1ating to
installations within the Exclusive Economie Zone and continental shelf may be accepted as
reflective of general international law on the matters dea1t with. Iran possesses continental
shelf rights and has proclaimed an Exclusive Economie Zone over the area where each of the
platforms is located. Article 14 oflran' s Act on its Marine Areas of 20 April 1993 reiterates
the principles set forthn the Convention in this regard.
Under international law, a coastal State has sovereignty over the seabed, water column and
superjacent airspace within its territorial sea. This sovereignty extends to installations such as
oil platforms 1ocatedon the seabed of the territorial sea.
Within the continental shelf and exclusive economie zone, the coastal State has sovereign
rights for the purpose of exploring and exploiting the natural resources situated therein
(Articles 56(1)(a) and 77(1) of the 1982 Convention) and thus has exclusivejurisdiction to
license and to control the operation of oil platforms. This exclusive jurisdiction is clearly
recognized in Articles 56 and0 of the 1982 Convention (see also Article 80, which appliesArticle 60 mutatis mutandis to installations and structures on the continental shelf). In
accordance with Article 60(2) of the Convention, the exclusive jurisdiction includes
"jurisdiction with regard to customs, fiscal, health, safety and immigration laws and
regulations." But it is not limited to these matters: it extends, for example, to cover general
civil and criminal jurisdiction with respect to events occurring on oil platforrns. The coastal
State may also take measures necessary for the protection of its oil platforrns and the
personnel present on the platforrns. In particular, it may position defensive military
equipment and post military security personnel on the platforrns for that purpose.
Neither within the territorial sea nor the Exclusive Economie Zone do oil platforrns and other
installations and structures equate to islands, and they do not generate a territorial sea of their
own. The coastal State is however entided to establish reasonable safety zones around such
installations and structures (Article 60(4) of the 1982 Convention).
The purpose of oil platforrns is to exploit the non-living resources of the Exclusive Economie
Zone and continental shelf. These resources fall exclusively within the sovereign jurisdiction
and control of the coastal State, and that State's authority over its oil platforms is sovereign
authority which is shared with no other State.
An attack on installations situated on Iran's continental shelf and within its Exclusive
Economie Zone constitutes an attack on installations engaged in the commercial production
of petroleum resources over which Iran has sovereign rights.
In Iran's view, the United States' attack on the oil platforms, located on Iran's continental
shelf, impaired the freedom of commerce in oil between the territories of the High
Contracting Parties. lt will be recalled that, after initial processing on the platforms, the oil
extracted was conveyed to nearly Iranian islands for further processing, after which it was
exported (and susceptible to be exported) inter alia to the United States. The Court has
\
already recognized that this oil forrned part of Iran's export trade in oil and was protected by
Article X, paragraph 1, of the Treaty. See I.C.J. Reports 1996 at pp. 819-820 (paras. 50-51).
2 Annex 2 to OP 2003/30
SECOND QUESTION
"During the war between Iran and Iraq was Kuwait a neutral state, a non-belligerent
state, or a co-belligerent state with Iraq? Would the response to this question be
different depending on whether it was given during the war or today, bearing in mind
the additional information now available?"
In its contemporary communications with the Security Council, Kuwait described itself as
"not being a party to" the war between Iran and Iraq (see. e.g. S/19872, 9 May 1988).
However, it is clear that Kuwait massively supported Iraq in its war of aggression against
Iran and did not respect the obligations of abstention and impartiality, which are incumbent
upon neutral States. Iran has detailed aspects of Kuwait's support for Iraq in both its written
pleadings and in its oil pleadings (see, for example, Iran's Reply, paras. 2.12-2.26; Iran's
Further Response, paras. 3.23-3.27; and CR 2003/5, pp. 49-50). Kuwait's violations of the
laws of neutrality included inter alia financing the Iraqi war effort, opening up its ports to
allow transshipment of war material to Iraq, and assisting Iraq in its attacks against Iran by
allowing the use of its territorial waters, islands and, in particular, its airspace. Senior U.S.
officiais recognized at the time that Kuwait was defacto Iraq's ally (lran's Memorial, Exhibit
51).
During the conflict, Iran knew and always claimed that Kuwait was indeed massively
supporting Iraq. After the conflict, the extent of this support has become clear beyond
reasonable doubt. Kuwait has repeatedly asked Iran's forgiveness for its support for Iraq (see,
Iran's Reply, Exhibit 13). In additior, the Emir of Kuwait expressed his regret at the
resolutions adopted by the Gulf Cooperation Council during the conflict, severa! of which
were unfavourable to Iran. He noted that these resolutions had been passed "sous l'influence
pernicieuse de l'Irak" (Ibid.). Kuwait's own admission and apology has thus laid any doubt
to rest.
The expression "non-belligerency" may be used to describe the situation of Kuwait. In the
history of the law of war and neutrality, the expression has been used to describe a
3situation where a State has violated the rules of neutrality by supporting one party to the
conflict while at the same time claiming not to be a party to that conflict. But international
law does not confer any specifie status or rights upon a "non-belligerent". AState is either a
party to a conflict or it is not. In the latter case, it is bound to observe the law of neutrality,
subject to a decision of the Security Cotnlcil which is not relevant in the present case.
Even if the support given to Iraq did not entait Kuwait becoming a party to the conflict, it
constituted a violation of the law of neutrality. In addition, however, the extent and nature
of this support meant that Kuwait participated in Iraq's aggression. It was also an unlawful
act on that account, and was a serious violation of the Charter of the United Nations and of
ius cogens, which prohibit the use of force.
4 Annex 3 to OP 2003/30
QUESTIONS DU JUGE RIGAUX ADRESSÉES AUX DEUX PARTIES
Première question: quel est le statut juridique de plates-fonnes pétrolières
aménagées par un Etat sur son plateau continental? Quelles sont les compétences
exercéessur ces installations? Quelle est la différenceentre le statut des plates-fonnes
pétrolièresselon qu'elles sont localiséesrespectivement dans lamer territoriale d'un Etat
ou en dehors de celle-ci?
Answer:
1. International law draws a clear distinction between a coastal State's territory,
including its territorial sea, over which it enjoys sovereignty, and its continental shelf,
over which itenjoys certain, expressly enumerated sovereign rights. Article 2(1) of the
1982 UN Convention on the Law ofthe Sea ("LOS Convention"), which re.flect
customary international law, provides:
"The sovereignty of a coastal Stare extends, beyond itsland territory and internai
waters and, in the case of an archipelagie State, its archipelagic waters, to an
adjacent belt of sea, described as the territorial sea, (emphasis added).
2. A coastal State's continental shelfhas a different legalstatus. Customary international
law, as reflected inArticle 76(1) of the LOS Convention, provides that the continental
shelf of a coastal State:
"comprises the sea-bed and subsoil of the submarine areas that extend beyond its
territorial sea throughout the natural prolongation ofits land territory to the outer
edge of the continental margin, orto a distance of200 nautical miles from the
baselines from whicb the breadth of the territorial sea is measured where the outer 2
edge of the continental margin does not extend up to that distance" (emphasis
added).
(See al.soArticle l(a) of the 1958 Convention on the Continental Shelf, which refers to
the continental shelf as "adjacent to the coast but outside the area of the territorial sea.")
3. Customary intet:tationallaw, as reflected in Article 77(1) of the LOS Convention.
provides thar the coastal State:
"exercises over the continental shelf sovereign ri$ts for the purpose of exploring
it and exploiting its natural resources" (emphasis added).
(See a/so Article 2(1) ofthe 1958 Convention on the Continental Shelf, which isidentical
to Article 77(1) of the LOS Convention. This language first appeared as Article 68 of the
articles conceming the law of the sea, as adopted in 1956 by the International Law
Conunission. Cfearbook of the International Law Commission 1956, Vol. ll,
A/CN.4/SER.A/I956/Add.l, p. 264.))
4. Sovereign rights over the continental shelf are not the equivalent of sovereignry. As
the International Law Commission explained in the 1956 Conunentary to Article 68 of
the articles conceming the law of the sea:
"The Commission desired to avoid language lending itselfto interpretations alien
to an abject which the Commission considers to be of decisive importance,
namely the safeguardipg of the principle of the full freedom of the supetjacent sea
and the air space above it.Renee itwas unwilling to accept the sovereignty of the
coastal State over the seabed and subsoil of the continental shelf." 3
(Ibid., pp. 253, 297)
5. Further, the sovereign rights enumerated with respect to the continental shelfare for a
limited purpose (i.e., thatof exploring the continental shelf and exploiting its natural
resources).
6. Moreover, under international law, the exercise of enumerated sovereign rights over
the continental shelf is expressly limited, for example, by the principle that the exercise
of the rights of the coastal State over the continental shelfmust not infringe or result in
any unjustifiable interference with navigation and other rights and .freedoms of other
States as provided underintemationallaw. (SeeArticle 78 (2) ofthe LOS Convention,
which reflects customary international law on truspoint.)
7. With respect to oil platforms in particular, whereas a coastal State enjoys sovereignty
over such platforms in its territorial sea, a coastal State's rights with respect to such
platfonns not in its territory, but rather on its continental shelf, are limited in various
ways. For example, coastal States are obliged under international law to give due notice
of the construction of such platfom1s and maintain pennanent means for giving waming
of their presence. Where such platforms are abandoned or disused, international law
provides that coastal States shaHremove them or give appropriate publicity to the depth,
position, and dimensions of any structures not entirely removed. Such removal shall a1so
have due regard to fishing, the protection of the marine envirorunent and lhe rights and 4
duties of other States: This customary international law is reflected in Articles 60,
paragraph 3, and Article 80 of the LOS Convention. Annex 4 toOP 2003/30
QUESTIONS DU JUGE RICAUX ADRESSÉES AUX DEUX PARTI.ES
Deuxièmequestion: selon lesParties, durant laguerreentrel'Iranet l'Iraq,le
Koweït était·ilun Etat neutre, unEtat non-belligérantou unEtatcobelligérantd~ l'Iraq?
Laréponseà cette question serait-elledifférente,selonqu'elleaitétéformulée
durant laguerre elle-même ou aujourd'hui,compte tenudu complémentd'informations
dont on dispose?
Answer:
1. At alitimes duringthe Iran-Iraq War, Kuwait was aneutra},non-belligerent State.At
no time during the Iran-IraqWar was ita co-belligerentStatewith Iraq. The attached
DiplomatieNote from the Ministry of Foreign Affairs of theStateofKuwait to the
..
Embassy ofthe Unired States of America,dated March 16, 2003, confinns this status.
2. As is stated inthe attachedDiplomatieNote, Kuwait'sstatusas aneutra},non-
belligerent Statet ali times during thelran-TraqWar doesnotchangedepending on
whether one considersthe questionin terms of theinformationavailableat that time or
also takinginto account additiomllinfonnation availableatpresent. The information
available at the timeof the Iran-IraqWar andsubsequentlysupportsthe conclusion that,
as the MinistryofForeign Affairs ofKuwait stated in theDiplomatieNote, "[t]he State of
Kuwait remainedcompletely neutral".~o/rff~~ ii .!?'JIï.lëiJsj
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r'·'/Y''" U.S. DEPARTMENT OFSTATE
OFFICE OF LANGUAGE SERVICES
'franslating Division
LS No. VFD 03 2003 0133
Arabie
SK
In the Name of God, the Merci fu!, the Compassionate
[Emblem ofthe State ofKuwait]
MinistryofForeign Affairs
Americas Department
TO: Embassy of the United Statt!s of America
Kuwait
03/16/2003
The Ministry ofForeign Affairs ofthe State ofKuwait extends its wannest greetings to the
Embassy of the United States of America in the State ofKuwait.
The Ministry ofForeign Affairs ofthe State ofl<.uwait wishes to note that the State of
Kuwait was not a party to the Iraq-Iran War throughout its duration, between 1980 and
\988. The State ofKuwait remained completely neutra! and did not side with either ofthe
panies involved in that war.
The State ofKuwait must be considered a neutra! state. The neutrality of the Srate of
Kuwait is based on information that was wide\y known durinIraq~ Irrand on
infonnation that is available at the present time.
The Ministry of Foreign Affairs avails itsclf of this opporrunity to express its utrnost
appreciation and esteem to the distinguished Embassy [ofthe United States of America].
[illegible signature]
[Round, imprint sealf the Ministry of Foreign Affairs, State ofKuwait]
LS No. 03-2003-0\33/SK Annex 5 to OP 2003/30
QUESTIONSPUTBYJUDGE AL-KHASAWNEHTOTHEUNITEDSTATESOFAMERICA
First Question: In the opinion of counsel of the United States, are the concepts of
lex specialis, on the one band, and self-contained régimes, on the other, synonymouIf
not, what are the differences between them? This question is of course in relation to the
1955 Treaty.
Answer:
1. In his statement ofFebruary 26, 2003 (CR 2003/12, pp. 18-19, para. 17.20) Professer
Weil stated that Article XX of the Treaty of 1955 between the United States and Iran is a
lex specialis within the meaning of Article 55 of the 2001 International Law
Commission's Draft Articles on State Responsibility. Counsel for the United States
referred in this respect to the Commission's Commentaries, according ta which this
provision "makes it clear ... that the articles (of the draft] have a residual character", sa
rnuch so that ''(w]here sorne matter otherwise dealt with in the articles is govemed by a
special rule of international law, the latter will prevail to the eanyninconsistency"
(lntroductory remarks to Part IV of the Draft, pp. 355-6; see aJ.Crawford, The
lnternalional Law Commission 'sArticles on Srate Responsibility, 2002, p. 306). No
disagreement appears to exist between theParties since Iran explicitly states in its written
pleadings that "[a]s a lex specia/is in the relations between the two countries, the Treaty
supersedes the lex generalis, namely customary international law."
2. Counsel for the United St~l didenot rely on the concept of self-contained regime, but
rather on the concept of lex specialis of Article 55 of the ILC's Draft, ofwhich, so the
Commission said, the concept of self-contained regime is given as an example of "the
strong fonn"- an exarnple of the "weaker form''being ''specifie treaty provisions on a 2
single point" (para. 5 of the commentary on Article 55). While the concepts of self-
contained regime and /ex specia/is are not synonymous, they are closely related. A sr;,lf-
contained regime is a panicular fonn of lex specialis; a lex specialis, however, is not
necessarily a self-contained regime. The decisive issue in the instant case is whether
ArticleXX of the 1955 Treaty is a lex specialis, which as such supersedes rhe provisions
of the otherwise applicable customary mles as may be expressed in the Commission's
Draft; it is not whether Article creates a self-contained regime. In other words, for the
purpose of the instant case it sufficcs to note that Article XX of the 1955 Treaty is a lex
specialis within the meaning of Article 55 of the ILC's Draft, without there being any
need to detelll1ine whether it gives rise to a self-contained regime. Tallthe more so
in that the very conceptf self-contained regime, recognized as it was by the Court in the
Hosrages case, bas been disputed- and sometimes even put into question- within the
International Law Commission itself (see, e.g.,h4Report by G. Arangio-Ruiz, Yearbook
ofrhe lnrernational Law Commission, 1992, vol. II, PartI,paras.97 and ff.) and in the
literature. Professor (new Judge) B. Simma- who clearly regards self-contained regimes
as leges speciales (Self-Conrained Regimes, in Nerherlands Yearbook of lnrernational
Law., vol. XVI (1985), pp. Ill and ff., at p. 135)- points to the "high degree of
abstraction with which the tapie has been discussed" within the Conunission and "the
resulting confusion permeating this debate''(p. 118).
3. Itmay be added that the concept of lex specialis is an application of the well-known
1
and well-estabtished princip le of interpretaac~ord tiwnhich specialia generalibus
deroganl. As the Commission's commentary on Article 55 states, the question is one of
interpretation, and "[i]t will depend on the special rule to establish the extent to which the 3
more general rules on State responsibility set out in the present articles are displaced by
that rule"(op.cil.,p. 357, para. 3). Counsel for the United States bas put forth suan
interpretation when he argued. that the concept of''measures ... necessary to protec[a
Party's] essential security interests, referred to in Article XX of the 1955 Treaty provides
the basis for the Court's review of the claims in the current case. (CR 2003/12,
paras. 17.21 and ff.)
4. Likewise, D. Bodansky and J.R. Crook write in their articlSymposium:TheILC's
ScareResponsibiliryArticles:lntroducrionand Overview that
lt should be bornein mind ... that although the articles are general in coverage,
they representonly default or residual rules; they do not necessarily apply in all
cases. Particular treaty regimes or rules of customary international law can
establish theirwn special rules ofresponsibility ... that differ from those set forth
in the articlesAmericanJournalof /nternacionalLaw, vol. 96 (2002), pp. 773
and ff., at p. 780).
5. It should be added that, as Mr. (now Judge) Al-Khasawneh pointed out in his capacity
as amember of the International Law Commission, "(t)he tendency in the field ofState
responsjbility was to establish different regimes for the various types ofresponsibility",
because "[s]uch compartmentalization would bring greater precisionandclarityinto the
rules goveming instrumental ~onseque n.c"esSummary Records of the Meetings of
1
the 44h Session, Yearbookof thelmernarionalLaw Commission,1992, voL I, pp. 159-
60). 4
6. In conclusion, to determine the scope and effect of Article XX of the 1955 Treaty
there is no need to determine whether itcreates, or not, a self-contained regime. Even if,
as Professer Crawford argued, "the Treaty of Amity is not a self-contained regime" but
'·anormal bilateral treaty govemed by international law" (CR 2003/16, p. 12, para 6), it is
indisputably a lex specialis which applies in the instanr case. Annex 6 to OP 2003/30
QUESTIONSPUTBYJUDGEAL-KHASAWNEH TO THE UNITED STATES OFAMERICA
Second question: ln his statement, provided by the United States and contained at
tab C9ofthejudges' folders, General Crist explained the reason why a choice was made
to attack the cil platforms as follows: "lran could not have attacked U.S. ships without
using the cil platfonns as they bad no ether offshore means to maintain continuous
swveillance over the transit routes, other than on Farsi Island." Why did the United
States choc se the platforms and not the means of surveillance located on Farsi Island?
Answer:
1. The criteria the United States considered in selecting targets for rnilitary action
are described in the Statements of General George Crist (U.S. Exhibit 44), Rear Admirai
Harold Bernsen (U.S. Exhibit 43), and Vice Admirai Anthony Less (U.S. Exhibit 48).
TI1esecriteria included the following: the need to degrade Iran's ability to attack U.S.
vessels transiting the Gulf; the desire to avoid direct involvement in the Iran-Iraq war and
to maintain the status ofthe United States as a neutral; the desire to minimize the risk of
casualties to U.S. and Iranian armed forces; and the desire to minimize the risk of
casualties to civilians.
2. As explained in the attached Statement ofRear AdmiTal Bernsen, dated March 13,
2003, Farsi Island was a far less suitable target than lran's offshore platforms according
to these criteria.
3. First, taking action against Farsi Island would have done less to degrade Iran's
1
ability to attack U.S. shipping than would action against the platfonns. Because Farsi
Island was not within visual range of the shipping channel U.S. ships followed through
the Gulf, and provided a much lower vantage point than Iran's offshore oil platfonns, itprovided a less effective surveillance point than did the platforms. That Farsi Island
posed less of a threat to shipping than did the platfonns is also reflected in the fact that
more Iranian attacks on shipping took place within radar range ofiran's platfonns than
took place within radar range ofFarsi Island.
4. Second, because Farsi Island was Iranian land territory and was within Iran's
declared wartime exclusion zone, targeting it could have been perceived as a more
serious escalation of tension with Iran than targeting Iran's offshore oit platforms, and
could have given rise to questions whether the United States intended to remain neutral in
the Iran-Iraq War. The importance ofthese factors was indicated by the decision of the
U.S. military's National Command Authority that no facilities on Iranian land territory
were to be considered as targets for the U.S. defensive action.
5. Third, rargeting Farsi Island would have created a more serious risk of casualties
to both U.S. and Iranian persoooel. The United States believed that Parsi Island was
defended with mines, which would have posed danger to ships sailing near it.To avoid
the risks to U.S. forces posed by sucb mines, any military action against Farsi Island
would have needed to be taken from the air. Such an action still would have posed risks
to U.S. forces from anti·aircraft defenses on Farsi Island. Action from the air would also
entail using Jess precise weapons than those that could be used from closerproxirnity on
the ground. This would necessarily entail a greater risk of casualties to Iranian persoooel.
By contrast, action against the platfonns could be taken from close range, and in a 3
manner allowing advance waming ta personnellocated on the platfonns, thus creating
minimal risk of casualties to Iranian personnel.Statcment-ofReaAr dmira.Hwold J.Be:mscn1,3Mareh. 2003 STATEMENTOF
BEARADMIBAL HAROLDBE.m,SEN, U.S.NAVY(RETIIŒD)
l.I, Hatold Bemsen.retiŒdfromtheU.S. Navy withtherauk·ofRearAdmirai in
December1991. During theperiod·une 1986 toMaxch19181c 'ommanded theU: S.
Na.vy,sMiddleEast Fo~c w.h1çboperatedinand a.roun héArabian{Persian) Oulf.
2.I muicrstandthata questiobas ariseconceming the reasDil"why theUüitcd
Stateschose tdattlckte platformsandnotthe means ofswveillanoelocatedonFarsi
Islan Pa~egraphs24 and25 ofmy statemem dated26Ms.y1997,whicb MS
attachedtotheU.S.Counter-Memorial and Counter-Claim.as&lu'bit43,.provide
infolliUltirelevantto theUnitedStatesdecisio1otargetIran'soffshoreoil
pla:tfanns. ltisstatementprovidcsadditioninformatioregardingwhytheUnited
Statesdecided-nottotargetParsihl&nd Therewereseveralreasonsfor thisdecision.
3.First,Fa.WJ's.hmwdaslranianland1erritory.TheNationalComm.and Authority
directedtbatnodèfcnsivemilitaryoperationwouldbe launcbedagainstlranianland
territoey.Thisdecision:reflecteda desireto avoidesOB.ttnnecessarilthetense
situationbctweenlian andtheUnitedStatesandto avoid anypossibleundermining
ofthe neutialstatusofthUnitedStates.
4.Futth riskofbothU.S.andlraniancasualtieswasmuch.greata- inanattackon.a
groundtargetsuchasFsrsiIsland,The island's.locatiinside1ran•swartime
~uskm zone,.urrDundebdysballow water wbich·\WSvery·likelyrnincd,posed
ris'10·u.s forcesapproachingtheislandfrom 'thsea.Thiswould bavedictamdthe
useof airaaft raththansurfaceshipsforanattack,though'thistiUwoutdtave
involvedsornerisktoU.S.forcesbeŒuselran maintainedanti-aircraftdefenseson
FersiIsland.Moreover,takingactionfromtheairwauldbave enWled theuseof
bombs, !csspreciseweaponsfbau couldbeernployedfromtheground and
con:sequentlwouldbaveinvolvedincreasedriskof ci.SlW!ieso Iran{amilituy
personnelontheground.Thisriskwouldhaw beenparticularlyacutebecause
warnmgthepersonnelon tbeislandinacblanco.fanauaekwould ha~ bcen difficult.
Since-thelraniani didnot.maintainsufficientwatereraftatFmsiisl1od
accommodatethe persom1e lased.therecnsuringtbeîrevacuationendsafetwould
havebeen viit11alimpussible.
S.And finally,FarsiIslanddidnotpresentagreaathre!U toU.S.shippingtransiting
theGulfasIran'soffshoreoilpla1formsdid.Ualikethe platfoiil. hichwere
loca!ed withibathradlu -ndvisualranscof theshippingchannel that U.ships
fotlowedthrough theGulf.Fmi. wesnot witbin visuarange(If the shippiugchannel,
therebyinhibitini1Susefulnessas asUIVcillanpoint FarsiIsland1sa low-lying
lanchnassonlytlaee metef3abovesea levelln contrast.theplatfOlofferedamuch
higher position,approximatc35.metcrs.on"vhicbto mOUDa tmdaror ftom which to
obscr.vevi.sual:vesselsintheshippingchannelThe unobstru.ctview.of1hcshippingchannelfromtheplatfollD!was clcadysuperiŒtD 1hatwhichcouldbe
acbievedfromFa.rsiIsland.
Ideclareunderpenaltyofpcrjuryunder1belaws o!thc:UmŒd StatesofAmerica
1battheforegoingistrueandconect.
Response of the Islamic Republic of Iran to the questions of Judge Rigaux addressed to both parties