UNCLOS Under Pressure: Law of the Jungle or Law of the Sea?
Corona crisis or not, China is relentlessly strengthening its control over the South China Sea while not shying away from confrontation. Surprisingly, the worldwide corona crisis may also present some unexpected openings, as is illustrated by the Turkish-Cypriot maritime border conflict in the Mediterranean.1
For decades, maritime and territorial disputes have been on-going in the region, involving virtually all coastal states of the South China Sea over claims to the sandbanks, atolls, islands and the waters in between them, rich in fish and other natural resources.
Looming large over this region, China is a key player in these conflicts. Just like the other countries around the South China Sea, the country has signed and ratified the United Nations Convention on the Law of the Sea (UNCLOS).2 It is this treaty that governs the maritime claims of coastal states on the natural resources within the so-called Exclusive Economic Zone (EEZ) and the Continental Shelf.3
The Chinese claim
China also makes additional claims to the islands, waters and natural resources of practically the entire South China Sea based on what it calls ‘historic rights’.4 Controversial for legal as well as historical reasons, these claims have been displayed on Chinese maps since 1947 through the so-called ‘nine-dash line’.
This line encompasses nearly the entire South China Sea and, in so doing, overlaps with the EEZ of other coastal states (Brunei, Vietnam, the Philippines, Malaysia and even Indonesia's Natuna Islands). For this reason, the claims made by China regularly give rise to tensions. In 2016, the Chinese claim was rejected by an international arbitration tribunal in The Hague as going against the Law of the Sea Convention.5
Ever since, China has refused to recognise the arbitral award and has been more active than ever in the coastal waters of its neighbouring countries. When in early April 2020 a Vietnamese fishing boat sank following a collision with a China Coast Guard vessel, and a Chinese research vessel showed up in the coastal waters of Malaysia, only to stay there for a month, this actually meant a repetition of moves and patterns from previous years.6
A sustained presence
In 2019, a near-permanent Chinese presence was observed in the coastal waters claimed by the Philippines, Malaysia and especially Vietnam. This presence often comprised – in addition to fishing vessels – one or more China Coast Guard vessels, ships from the Maritime Militia (which is a paramilitary force on board steel-hulled fishing vessels) or even an oil exploration vessel.
Especially now that China has several forward bases on recently created artificial islands, it has become increasingly easy for China to sustain a prolonged presence in the region.7
Malaysia and Vietnam
During much of May 2019, for instance, the Chinese coastguard obstructed Malaysian oil drilling at the Luconia Shoals, an area of shallows and sandbanks in Malaysia's EEZ. This is where Sarawak Shell, a subsidiary of Royal Dutch Shell, is conducting oil exploration on behalf of Malaysia.
Not much later, in mid-June, the Chinese coastguard showed up close to a gas field in waters claimed by Vietnam, where Russian Rosneft is looking for gas on behalf of Vietnam. In early July, a Chinese research ship and escort also arrived in the area to search for oil and gas.8 The Chinese research vessel eventually left in October, only after Vietnam had completed its own drilling activities in the area, and after a sustained presence of almost four months.9
Only this summer, Vietnam cancelled its contract with an oil rig meant to explore an oil field off Vietnam’s south-eastern coast under pressure of a China Coast Guard vessel patrolling near another Vietnamese oil rig. Moreover, Spanish Repsol gave up its shares in three Vietnamese oil blocks after years of Chinese pressure.10
In early 2019, dozens of Chinese 'fishing vessels' suddenly emerged near a small Philippine island in the South China Sea. A few months later, in the summer, two Chinese research vessels showed up – without permission – within the EEZ of the Philippines.
One year later, the fishing vessels, presumably from the aforementioned Maritime Militia, are still circling the island. They do not seem to be leaving anytime soon.11
In June this year, a small wooden Philippine fishing boat sank after a collision with probably a steel-hulled Maritime Militia vessel. The 22 Filipino fishermen were left to the elements at night in the sea and were later rescued by Vietnamese colleagues.12
The new Philippine President Rodrigo Duterte, trying to avoid a confrontation with China, in 2016 pragmatically decided to 'shelve' the favourable South China Sea arbitration award in exchange for Chinese investments in his country.
China's other maritime neighbours have been increasingly seeking a more confrontational stance through the internationalisation of disputes and by means of international law
In addition, both countries started negotiations on the joint exploitation of gas fields within the Philippine EEZ.13 It appears that China, by exerting pressure on Vietnam, Malaysia and possibly even Indonesia, is seeking to enforce a similar construction of joint exploitation with these countries.14
Internationalisation and international law
Lately, China’s maritime neighbours have been increasingly seeking a more confrontational stance through the internationalisation of disputes and by means of international law.
Malaysia’s foreign minister recently called the Chinese claim to the South China Sea outright “ridiculous” and even submitted a new claim to the United Nations on waters within the Chinese nine-dash line.15 In November 2019, Vietnam also raised the idea of initiating an arbitration case against China, just as the Philippines did.16
Indonesia recently explicitly referred to the 2016 Philippines-Chinese arbitration ruling in response to Chinese violations of the Natuna Island waters.17 In June, even the Philippines hinted at resuming unilateral oil and gas exploration, possibly in response to the perceived Chinese aggression during and in the wake of the COVID-19 pandemic.18
Also in June, the leaders of the Association of Southeast Asian Nations (ASEAN) issued a joint statement, underlining in unusually strong terms the importance of the UNCLOS.19 This was followed in July by a statement from US Secretary of State Mike Pompeo rejecting China's claims to the offshore sources in “most of the South China Sea”, thus further aligning the US position on China's maritime claims with the 2016 arbitral award.20
A new normal
A 'new normal' seems to be emerging in the region. Any attempt by China's neighbours to exploit oil and gas in the area within the controversial Chinese claim line is instantly confronted and deterred by intimidation.
Nevertheless, the other countries increasingly view the South China Sea arbitration – albeit completely ignored by China – as a model to bring at least legal clarity about China’s non-compliance with international law.
A European perspective: the Eastern Mediterranean
There is good reason for Europe to monitor the South China Sea situation, as discussed earlier in 2017.21 As mentioned before, not only is the legitimate extraction of oil and gas in the area under threat, but the UNCLOS itself is structurally being undermined by Chinese claims beyond UNCLOS and by Chinese intimidation based thereon.
Closer to home, Europe itself is being confronted with the erosion of the UNCLOS in the Eastern Mediterranean Sea and the Aegean Sea. For decades a conflict has played out between Turkey and Turkish Cyprus (officially: the Turkish Republic of Northern Cyprus, or TRNC) on the one hand, and Greece and Greek Cyprus (officially: the Republic of Cyprus, or Cyprus in short) on the other.
Turkey in particular has a very unique and controversial interpretation of the law of the sea
Especially after the discovery of considerable gas reserves around Cyprus in the last decade, the Cyprus conflict has increasingly taken on a maritime dimension, and here, too, the conflict has deepened in recent years. In this context, Turkey in particular has a very unique and controversial interpretation of the law of the sea.
Cyprus gas dispute
When oil and gas were found south of Cyprus in December 2011, this discovery initially appeared to be an incentive for a peaceful resolution of the conflict on Cyprus, an island state divided since 1974 between the Republic of Cyprus on the one hand, and the TRNC – recognised only by Ankara – on the other.22
Ever since, however, the gas reserves found proved to be more of a dividing point rather than a blessing for the island state; drilling for gas has led to several confrontations which have already been likened to the conflicts in the South China Sea.23
Unlike Cyprus and Greece, Turkey is not a signatory to the UNCLOS and, as such, the country applies its very own and controversial interpretation of the law of the sea
Turkey itself has not yet found any gas in the waters it claims. The country, however, is also claiming large portions of the EEZ claimed by Cyprus. The dispute now seems to have entered a new phase with the acquisition and deployment by Turkey of three drilling vessels.24
In 2018, the Turkish navy chased away a vessel from the Italian oil company ENI that intended to operate in the waters east of the island on behalf of the Republic of Cyprus.25
Moreover, since 2019, Turkish research and drilling vessels, escorted by the Turkish navy, have themselves been searching for oil and gas within the EEZ claimed by the Republic of Cyprus. These assertions are based on a controversial double Turkish maritime claim to the sea around Cyprus.
Twofold Turkish maritime claim around Cyprus
Unlike Cyprus and Greece, Turkey is not a signatory to the UNCLOS and, as such, the country applies its very own and controversial interpretation of the law of the sea. In Turkey's view, islands opposite to the mainland produce either none or fewer entitlements to an EEZ than would be the case under the widely accepted UNCLOS – as ratified by both Cyprus and Greece.26
Consequently, Turkey may claim indirectly, via and on behalf of the TRNC large parts of the coastal waters to the north and east of the island. On the other hand, Turkey directly lays claim to large swathes of the waters to the west and even to the south of Cyprus as being part of Turkish waters with corresponding exploitation rights.27
'Mavi Vatan': A Turkish nine-dash line?
By the end of February 2019, Turkey's largest naval exercise ever was held, called ‘Mavi Vatan', which translates into English as 'Blue Homeland'.
Mavi Vatan, however, not only refers to the large-scale parallel navy exercise in the Black Sea, Aegean Sea and Mediterranean Sea, but also to a fairly new Turkish maritime geopolitical concept that seems to have gained political weight, especially in 2019, with Turkey’s President Recep Tayyip Erdogan, who is clearly not trying to hide the (maritime) aspirations he holds for his country.28
Much to the dismay of Cyprus and Greece, President Erdogan had himself photographed last September in front of a map of Turkey, entitled 'Mavi Vatan', on which large segments of the Black Sea, Aegean Sea and Mediterranean Sea seem to belong to Turkey.29
There is, however, little clarity about the exact meaning of the lines on this Mavi Vatan map, and therein lies a clear parallel with the never exactly defined Chinese claim through the diffuse nine-dash line surrounding the South China Sea.
In accordance with this Mavi Vatan doctrine, in November 2019 a controversial Turkish memorandum with the government of civil-war torn Libya once again alarmed Greece in particular, as Turkey and the Libyan government agreed to ‘divide’ a stretch of the Mediterranean Sea without taking into account the Greek maritime entitlements around Crete, Rhodes and Karpathos, thereby connecting the Cyprus issue with the Libyan – and indirectly even with the Syrian – civil war.30
Turkey, envisaging itself as a future gas hub in the region, aims among other things to hinder the planned construction of the EastMed pipeline through this agreement, which would side-line Turkey as a gas hub.31
At present, further escalation is imminent. The European Union already recently imposed limited sanctions on Turkey for drilling in Cyprus' claimed EEZ.32
In 2018, the United States sent a naval vessel to shield ExxonMobil's drilling operations near Cyprus from Turkish interference, and has recently reinforced its defence ties with both Cyprus and Greece.33
Meanwhile, Cyprus has expressed the intention to turn to the International Court of Justice in The Hague for a solution to the conflict over maritime delimitation
France has also expressed its support for Greece and Cyprus. In February the country sent the aircraft carrier 'Charles De Gaulle' into the region to highlight this.34
In July, the Greek and Turkish navies reportedly almost clashed over a planned Turkish seismic survey near the Greek island of Kastellorizo.35
To The Hague?
Meanwhile, Cyprus has expressed the intention to turn to the International Court of Justice (ICJ) in The Hague for a solution to the conflict over maritime delimitation. For the moment, Turkey does not seem to be interested in such an approach, if only because it does not officially recognise the Republic of Cyprus.
However, prior consent of Turkey is required in order to have the ICJ involved, since Turkey is not a party to the UNCLOS.36 In Greece, too, there are calls in favour of persuading Turkey to accept arbitration.37
Because of the COVID-19 outbreak, oil and gas exploration is largely halted. The current corona-induced moratorium and the low oil prices provide an excellent opportunity for all parties to buy time and – without losing face – anticipate the option of creating legal clarity on maritime delimitation through mediation, arbitration or through the ICJ.
Turkey's recent announcement that it will continue to explore and drill for gas and even step up its efforts, in spite of the corona crisis, is a missed opportunity to de-escalate and show goodwill.38 Europe needs to make this clear to Turkey and can decide whether or not to lift (or increase, for that matter) sanctions depending on Turkish cooperation.
The present position of the Republic of Cyprus is to only discuss a distribution mechanism after an eventual political solution for the divided island
Although a Turkish-Cypriot maritime delimitation is technically distinct from an internal political solution to the division of the island of Cyprus itself, such a delimitation brings to the fore the issue of distribution of potential Cypriot gas revenues between the two communities.
The present position of the Republic of Cyprus is to only discuss a distribution mechanism after an eventual political solution for the divided island. Here too, Europe could play a role in persuading Cyprus, in anticipation of such a final settlement, to already agree on a distribution formula and mechanism with the TRNC.39
A unique opportunity
Legal clarity in the Eastern Mediterranean Sea is of significant economic and political importance, not only for the parties involved, but also for the standing of the law of the sea in general.
This year, China has already made clear that it is not interested in de-escalation in the South China Sea, thereby further straining the position of the UNCLOS. However, in the Mediterranean Sea, the corona crisis is currently presenting Europe with a small yet unprecedented opportunity to de-escalate and strengthen the law of the sea. Let us not waste it.
- 1The author wishes to thank Alex Oude Elferink for his willingness to extensively share his expertise and thoughts on the implications of the United Nations Convention on the Law of the Sea (UNCLOS) for the disputes in the South China Sea and the Eastern Mediterranean Sea with the author. Also see endnote 27. Alex Oude Elferink is Director of the Netherlands Institute for the Law of the Sea (NILOS) at Utrecht University.
- 2See UNCLOS.
- 3See also: Rene Lefeber, ‘International Law and the Use of Maritime Hydrocarbon Resources’, Theme Paper, Clingendael International Energy Programme, 2015.
- 4Bill Hayton, ‘The Modern Origins of China’s South China Sea Claims: Maps, Misunderstandings, and the Maritime Geobody’, Modern China, 4 May 2018; Bill Hayton, The South China Sea: The Struggle for Power in Asia, New Haven and London: Yale University Press, 2014, p. 29 - 89.
- 5See for example: Friso Dubbelboer, ‘Zuid-Chinese Zee arbitrage verdient Europese betrokkenheid‘ (article in Dutch), Clingendael Spectator, 12 June 2017. Full award: Permanent Court of Arbitration, ‘The South China Sea Arbitration (The Republic of the Philippines v. The People’s Republic of China)’, 12 July 2016.
- 6Rozanna Latiff, ‘Chinese ship leaves Malaysian waters after month-long South China Sea standoff’, Reuters, 15 may 2020; A. Ananthalakshmi, Rozanna Latiff, ‘Chinese and Malaysian ships in South China Sea standoff: sources’, Reuters, 17 April 2020.
- 7Jaime Laude, ‘China Coast Guard entering foreign waters via artificial islands’, The Philippine Star, 1 February 2020.
- 8‘China Risks Flare-Up Over Malaysian,Vietnamese Gas Resources’, CSIS Asia Maritime Transparency Initiative, 16 July 2019.
- 9Vietnam earlier cancelled oil drillings both in 2017 and presumably again in 2018 to be conducted by Spanish Repsol following Chinese threats against Vietnamese positions on nearby islets. See: Bill Hayton, ‘South China Sea: Vietnam “scraps new oil project”’, BBC, 23 March 2018; Bill Hayton, ‘China’s intimidation in the South China Sea poses an economic threat to Vietnam’, East Asia Forum, 25 April 2018.
- 10Drake Long, ‘Oil Firm Withdraws from Vietnamese Field as Beijing Puts Squeeze on Hanoi’, Benar News, 13 July 2020.
- 11J.C. Gotinga, ‘Chinese vessels likely to stay near Pag-asa Island, says Esperon’, Rappler, 3 March 2020.
- 12Annemarie Kas, ‘Deze vissersboot werd geramd - zat China daar achter?‘ (article in Dutch), NRC Handelsblad, 28 August 2019.
- 13Helen Regan, ’Duterte says Xi Jinping offered him an oil and gas deal to ignore South China Sea ruling’, CNN, 12 September 2019.
- 14Liu Zhen, ‘Chinese survey ship returns to scene of stand-off with Vietnamese coastguard’, South China Morning Post, 15 August 2019; Teddy Ng, ‘China blocking Malaysian and Vietnamese oil and gas vessels shows greater willingness to intimidate, says think tank’, South China Morning Post, 17 July 2019.
- 15Nguyen Hong Thao, ‘Malaysia’s New Game in the South China Sea’, The Diplomat, 19 December 2019; Ted Regencia, ‘Malaysia FM: China's “nine-dash line” claim “ridiculous”’, Al Jazeera, 21 December 2019.
- 16‘Maintaining peace in South China Sea requires international efforts: Vietnamese Deputy Foreign Minister’, The World and Vietnam Report, 8 November 2019.
- 17‘Indonesia rejects China's claims over South China Sea’, Reuters, 1 January 2020.
- 18Richard Heydarian, ‘Philippines challenging China in South China Sea’, Asia Times, 27 June 2020.
- 19‘Asean leaders cite 1982 UN treaty in South China Sea dispute’, The Guardian, 27 June 2020.
- 20Press Statement Secretary of State Michael R. Pompeo, ‘U.S. Position on Maritime Claims in the South China Sea’, 13 July 2020.
- 21As previously mentioned: Friso Dubbelboer, ‘Zuid-Chinese Zee arbitrage verdient Europese betrokkenheid’ (article in Dutch), Clingendael Spectator, 12 July 2017.
- 22Jan Marinus Wiersma, ‘Gedeeld Cyprus: Een kerkhof voor diplomaten?‘ (article in Dutch), Clingendael Spectator, 15 January 2020.
- 23Metin Gurcan, ‘Eastern Mediterranean starting to resemble disputed South China Sea’, Al-monitor, 13 March 2018; Alessandro Gagaridis, ‘Rising Tensions in the Eastern Mediterranean: Another South China Sea?’, Geopolitical Monitor, 20 March 2018; Craig Hooper, ‘An Aggressive Turkey Is Raising Risks Of Conflict In The Mediterranean Sea’, Forbes, 16 February 2019.
- 24Volkan Ş. Ediger, ‘Turkey’s first drilling vessel heads to Mediterranean’, Energy-Reporters, 18 June 2018; ‘Turkey buys third drill-ship for Cypriot exploration’, Energy-Reporters, 25 February 2020.
- 25‘Turkish Navy Chases Off Eni's Drillship’, The Maritime Executive, 23 February 2019.
- 26These conflicting interpretations also play a role in the maritime-territorial dispute between Greece and Turkey in the Aegean Sea, where Turkey fears, inter alia, to be 'cut off' from the open sea on its western coast by the Greek islands with associated territorial sea and EEZ, on the basis of the same UNCLOS convention. For a brief explanation of the Aegean Sea dispute, see: ‘Wapengekletter bij rotseilandje was maar een detailkwestie’, (article in Dutch), Trouw, 2 February 1996.
- 27“As a rule, islands are entitled to the same maritime zones as the mainland. Small islands, however, may in certain cases be given less weight than other coasts when establishing bilateral boundaries between neighbouring countries, as the case law of the International Court of Justice and other tribunals has shown. That case law indicates that Turkey's position is not in conformity with the applicable law. International law also stipulates that maritime boundaries can only be established by an agreement between all the countries concerned, and not unilaterally by Turkey, or bilaterally by Turkey and Libya, in which case the rights of third states are also affected.“ - Alex Oude Elferink, as quoted from the e-mail correspondence with the author from April to June 2020, the authors private archive. For a recent overview of the case law on maritime delimitation, see: A.G. Oude Elferink, T. Henriksen and S.V. Busch, ‘Maritime Boundary Delimitation: The Case Law; Is it Consistent and Predictable?’, Cambridge: Cambridge University Press, 2018; For the Turkish claims, see also: Irina Slav, ‘Turkey Affirms Its Claim On Cyprus Oil And Gas’, OilPrice.com, 23 August 2019; Keith Johnson,’Turkey’s Big Energy Grab’, Foreign Policy, 25 July 2019; Cengiz Aktar, ‘Turkey’s expanding naval horizons’, Ahval News, 2 December 2019; Çagatay Erciyes, ‘Turkey’s off-shore activities in the eastern Mediterranean & maritime boundary delimitation in international law’, presentation Turkish Ministry of Foreign Affairs, Brussels, 27 May 2019; Turan Gafarlı, ‘Against All Odds:Turkey’s Position in the Eastern Mediterranean’, TRT World Research Centre, December 2019.
- 28‘Erdogan takes photograph in front of 'Blue Homeland' map’, Ekathimerini, 2 September 2019; Ryan Gingeras, ‘The Turkish Navy in an Era of Great Power Competition’, War on the Rocks, 30 April 2019; Christina Lin, ’Neo-Ottoman Turkey’s “String of Pearls”’, Asia Times, 14 September 2019; Robbie Warmerdam, ‘Turkije werkt meer dan ooit aan zelfstandige defensie-industrie’ (article in Dutch), Marineschepen.nl, 24 October 2019; Asli Aydıntaşbaş, ‘The Turkish Sonderweg: The New Turkey’s role in the global order’, European Council on Foreign Relations, 21 April 2020.
- 29‘Erdogan takes photograph in front of 'Blue Homeland' map’, Ekathimerini, 2 September 2019; Further reading: Ryan Gingeras, ‘Blue Homeland: The Heated Politics Behind Turkey’s New Maritime Strategy’, War on the Rocks, 2 June 2020; Can Kasapoglu, ‘The Blue Homeland’: Turkey’s largest naval drill’, Anadolu Agency, 27 February 2019; interview admiral Cem Gürdeniz, ‘Blue Homeland‘ shows Turkey has become a maritime power’, Hürriyet Daily News, 4 March 2019.
- 30Luke Baker e.a., ‘Turkey-Libya maritime deal rattles East Mediterranean’, Reuters, 25 February 2019. Further reading: International Crisis Group, ‘Turkey Wades into Libya’s Troubled Waters’, 30 April 2020; Asli Aydıntaşbaş e.a, ’Deep Sea Rivals: Europe, Turkey, and new eastern Mediterranean conflict lines’, European Council on Foreign Relations, May 2020.
- 31This pipeline is to run from the Cypriot and Israeli gas fields in the Eastern Mediterranean via Cyprus and Greece to Italy. These countries, cooperating with Egypt, Jordan and the Palestinian Authority in the East Med Gas Forum, are thus trying to circumvent an increasingly assertive Turkey for the transit of gas to Europe, see: Angeliki Koutantou, ‘Greece, Israel, Cyprus sign EastMed gas pipeline deal’, Reuters, 2 January 2020; Ali Bakeer, ‘Turkish-Libyan alliance in eastern Mediterranean: A game changer?’, The New Arab, 10 December 2019.
- 32Matina Stevis-Gridneff, ‘E.U. Punishes Turkey for Gas Drilling Off Cyprus Coast’, New York Times, 15 July 2019; Jonathan Stearns and Nikos Chrysoloras, ‘EU Walks Turkey Tightrope With Limited Sanctions on Drilling’, Bloomberg, 27 February 2020.
- 33‘ExxonMobil vessels leave port in Cyprus, eyes on Turkish response’, Ahval News, 29 March 2018; Steve Horn, Lee Fang, ‘Congress Quietly Adopts Exxon Mobil-Backed Law Promoting New Gas Pipeline, Arms to Cyprus‘, The Intercept, 6 February 2020.
- 34Tasos Kokkinidis, ‘France Sends Warships in Support of Greece Against Turkish Aggression’, Greek Reporter, 30 January 2020; ‘French aircraft carrier in Cyprus Block 8’, Kathimerini English Edition, 5 February 2020.
- 35‘Merkel hat wohl Militärkonflikt zwischen Türkei und Griechenland verhindert’ (article in German), Der Tagesspiegel, 22 July 2020.
- 36‘Cyprus petitions The Hague to safeguard offshore rights’, Reuters, 5 December 2019; Danilo Ruggero Di Bella, ‘Arbitration to Fight Piracy: Greece, France, Italy, USA, Israel, Qatar, South Korea vs. Turkey in Support of Cyprus?’, Kluwer Arbitration Blog, 27 February 2020; Todd Carney, ‘The Legal Issues Regarding Drilling Off the Northeast Coast of Cyprus’, Opinio Juris, 23 September 2019.
- 37Dora Bakoyannis, ‘The EU-Turkey special framework and the path toward The Hague’, Ekathimerini, 3 January 2020. Further reading: Moritz Neubert, Umut Yüksel, ‘What a judicial solution to disputes in the eastern Mediterranean might look like’, LSE EUROPP blog, 2 June 2020.
- 38Elias Hazou, ‘Coronavirus: Minister confirms long delay in Cyprus’ gas drilling’, Cyprus Mail, 13 April 2020; Jean Christou, ‘As govt braces for gas delays, Turkeys says it will continue drilling in Cyprus’ EEZ’, Cyprus Mail, 15 April 2020; Onur Ant, ‘Turkey ignores Greece’s dispute, moves on with Mediterranean seismic surveys’, World Oil, 22 July 2020.
- 39On obstacles and opportunities for regional cooperation, see: International Crisis Group, ‘Aphrodite’s Gift: Can Cypriot Gas Power a New Dialogue?’, 2 April 2020; Michael Tanchum, ‘Gas For Peace’, Foreign Policy, 28 May 2019.