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POSSIBLE DISPUTE SETTLEMENT FOR AMBALAT DISPUTE*

Ni Made Nungki Suardhani Giri**

Abstract Intisari Ambalat dispute occurs in the area of Ambalat, Sengketa kasus Ambalat terjadi di sekitar located off the coast of the Indonesian province wilayah Ambalat, terletak di lepas pantai of East Kalimantan and southeast of the Indonesia bagian Kalimantan Timur dan Malaysian State of . Many accidents sebelah tenggara dari Sabah, . have occurred in this area, and some of them Banyak masalah yang terjadi di wilayah ini, involving navies from both of the state. dan sebagian besar melibatkan angkatan Although this dispute has called for a need of laut dari kedua negara. Walaupun sengketa serious settlement, none of this State has taken ambalat harus diselesaikan dengan segera, an effort to solve this long-term dispute that has kedua belah pihak tidak melakukan become a problem to their harmony life as a tindakan untuk mengakhirinya, yang neighboring State. Diplomatic protest, navy hot menyebabkan terganggunya harmonisasi pursuit, and battle of natural resource hubungan antara kedua negara exploitation are the dispute that be on the list bertetangga tersebut. Protes secara of the effect of this Ambalat dispute, and if this diplomatis, pengejaran oleh angkatan laut, dispute will not be solved in any time soon, the eksploitasi sumber daya alam adalah contoh future generation of both state will still inherit dampak dari sengketa kasus Ambalat ini, and cannot use the natural resources contained apabila tidak diselesaikan dengan segera, in Ambalat area effectively. Seeing the maka generasi Indonesia mendatang tidak urgency to solve this Ambalat dispute, the bisa mengakses sumber daya alam yang author would like to analyze the possible tersedia di pulau itu secara efektif. Melihat dispute settlement of this dispute, whether it is urgensi dari sengketa ini, penulis akan through ITLOS as it is provided in UNCLOS, or menganalisis metode penyelesaian sengketa any other peaceful means. In writing this paper, yang efektif diaplikasikan dalam kasus ini. the author is using the book research method. Baik melalui ITLOS, UNCLOS, dan mekanisme damai lainnya.

Keywords: Ambalat dispute, Dispute Settlement, UNCLOS, Maritime Delimitation. Kata Kunci: Sengketa Ambalat, Penyelesaian Sengketa, UNCLOS, Batas Maritim.

* Preferred Citation Format: Giri, N. M. N. S, (2014). Possible Dispute Settlement for Ambalat Dispute. J.G.L.R., 2(1), 60-70. ** 2010; International Law, Faculty of Law, Universitas Gadjah Mada; Yogyakarta, Indonesia.

Giri, Possible Dispute Settlement for Ambalat Dispute 61

A. History of Ambalat Case The history of Ambalat case was it in their territory in their national map. This influenced by the the history of Indonesian- map of Malaysia was not recognized by Malaysian border from the colonialism era. fellow ASEAN States, and also In addition, when Malaysia was still colonialized by the the 1979 Malaysian Map that they used to Great Britain and Indonesia was still assert Ambalat has not been submitted to colonialized by the Netherland, these two the UN Secretary General pursuant to colonial States made a convention over Article 47(9) of LOSC. Hence, the 1979 Island, which was called the 1891 Malaysia’s map regarding their territorial Convention. This convention divided the water is not legitimate. (Schofield and Island into two parts the northern part Storey, 2007) belonged to The Great Britain and the After Indonesia lost to Malaysia on southern part was the . (Andi their claim of and Island Arsana, 2005) This 1891 Convention is still ownership in 2002, the Indonesian used by Malaysia as the successor of Great Government had to revised their maritime Britain and Indonesia as the successor of territory configuration, since they cannot use Netherland to define their boundary, the Sipadan and Ligitan as their baseline especially land boundary. anymore. In 2008, Indonesia redrew Pursuant to article 2 of 1891 baselines from the eastern shore of Sebatik Convention between Great Britain and Island to Karang Unarang and three other Netherland, the Indonesia-Malaysia points to the southeast. This results in the maritime boundary continued as a straight Ambalat Block no longer being entirely line along the 4° 10' North after it left the inside Indonesian internal waters. eastern land boundary terminus on the Even though the ICJ made no decision eastern shore of . Therefor on whether the features should be able to pursuant to this provision Ambalat is clearly claim maritime zones, nor on maritime in the area of Indonesia. Geographically, boundaries. But Malaysia then used these Ambalat is an area of sea block located off features as base points to make further the coast of Indonesian Province of East claims to territorial sea, EEZ and continental Kalimantan and Southeast of Sabah which is shelf. (Mark and Khalid, 2013) the area of Malaysia. This area is believed to be one of the richest natural resources spot, containing 62,000,000 barrels (9,900,000 m3) of oil and 348 million cubic meters of natural gas. (Syarifuddin, 2009) The history of dispute between Indonesia and Malaysia over this area has begun in the 1979 when Malaysia published their map showing their territorial The map of Ambalat dispute waters and continental shelf. between Indonesia and Malaysia This publication of Malaysian Courtesy of Google image National Map begun the territorial war between these two states, whereas Indonesia argued at that time that in de jure that Ambalat belonged to their territory, and they protested when Malaysia included

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B. The Most Suitable Settlement for this as what it has been regulated under Article Dispute 11 Vienna Convention on the Law of Treaty Ambalat dispute is different from the year 1969 which states. (Aust, 2002) dispute of Sipadan and Ligitan Island, thus “The consent of a State to be bound it requires different approach for by a treaty may be expressed by settlement. The difference lays lays on the signature, exchange of instruments right that is being disputed between the constituting a treaty, ratification, disputing parties. In the case of Sipadan acceptance, approval or accession, or and Ligitan case, this is a dispute of by any other means if so agreed” ownership of an island which involves the Indonesia and Malaysia have fulfilled question of full sovereignty, on the other this requirement by ratifying the UNCLOS. hand, in case of Ambalat, it is merely the Indonesia ratified UNCLOS under Law No. question of limited sovereign right which 17 Year 1985, (Kesumawardhani, 2008) on involves the right of exploration and the other hand, Malaysia ratified on 14 exploitation in the sea area. (Villanueva, October 1996 and came into force to 2013) Malaysia on 13 November 1966. Since, both Malaysia and Indonesia are the member states of the UN, and then C. Maritime Delimitation Dispute in this case The UN Charter will be In this present case, Ambalat dispute applicable to both states. Pursuant to article is included as marine delimitation dispute. 2(3) UN Charter which states that: Marine Delimitation dispute is a dispute that “All member shall settle their arises when there is an overlapping claim of international dispute by peaceful maritime zone from two or more States, and means in such a manner that no agreement can be reach on the limit of international peace and security, and each States maritime zone. (Alexander, justice are not endangered” 1986) Dispute of delimitation belongs to Basically this provision demands that international dispute, where the parties are all member of UN settle their international states and regulates by international law. dispute in a manner which does not Maritime Delimitation is a complex endanger international peace and security, subject, as it involves several types of issues meaning that the means of dispute regarding the real situations throughout the settlement shall not involve a provocation to world and the delimitation process. The the other disputing state or another state delimitation process itself involves several using of force that might end up as a war. types of issues: the authority, the principal (Shaw, 2008) method to carry out delimitation process, The Ambalat dispute fall under the and technical questions regarding the category of marine delimitation dispute, determination of the actual lines in space. since it involves an overlapping claim of a (Rosenne, 2007) territory by 2 or more states, as it is Currently, maritime delimitation is regulated under UNCLOS article 83 ruled through agreement between parties, , concerning Delimitation of the Continental meaning that if there is an overlapping Shelf between State with Opposite or claim of marine zone from 2 or more parties, Adjacent Coasts. In order for UNCLOS to be these claiming states shall come together applicable along with its dispute settlement and negotiate to set the limit of their marine mechanism, both of parties in dispute shall zone in the disputing territory. (Vukas, give their consent to be bound by that treaty 2004)

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The need of Marine Delimitation is to Indonesia, and oil concession, navy hot crucial in determining limit of a state’s pursuit and sea patrol incident regularly marine zone. Especially considering the occurs ever since. breadth of every marine zone that is claimable by a state (territorial sea, D. Dispute Settlement Provided by contiguous zone, ZEE, and Continental Shelf) UNCLOS for Delimitation State depends on the distance from that state to Boundary Dispute its neighboring state. An ideal condition for As both Indonesia and Malaysia are the marine zone division set up in UNCLOS contracting States of UNCLOS, thus dispute would be if a coastal state does not have a settlement mechanism contained in UNCLOS neighboring state located in less than 400 are relevant in this matter. United Nation on M from that state. (Sobar, 2006) The coastal the Law of the Sea or UNCLOS provides sets state will then have an ideal and undisputed of dispute settlement procedures in the part territorial sea, additional zone, ZEE and XV from article 279 to 296. Continental Shelf. To abide to United Nation charter However, this condition is somewhat article 2 (3) which requires all member state impossible in reality. For example, of UN to settle their international dispute in Indonesia as the largest archipelagic state any manner that do not threat international which has wide coastline. Its outer island is peace, security and justice, or in other hand directly adjacent to not less than 10 this charter requires an amicable and neighboring countries that are Singapore, peaceful settlement first among their , Malaysia, , East Timor, member state. This article is also inline with Papua New Guinea, Australia, and Palau. article 279 UNCLOS concerning the In terms of Ambalat dispute, pursuant obligation of member state to settle dispute to Article 47 of UNCLOS which states that, by peaceful means. This article states that: “An archipelagic state may draw “States Parties shall settle any dispute straight archipelagic baselines joining the between them concerning the outermost points of the outermost islands interpretation or application of this and drying reefs of the archipelago Convention by peaceful means in provided that within such baselines are accordance with Article 2, paragraph included the main islands and an area in 3, of the Charter of the United Nations which the ratio of the area of the water to and, to this end, shall seek a solution the area of the land, including atolls, is by the means indicated in Article 33, between one to one and nine to one” paragraph 1, of the Charter”. Based on this provision, Indonesia as In choosing the method of amicable an archipelagic States has a right to draw settlement or peaceful settlement, the a straight archipelagic baseline connecting UNCLOS does not impairs the right of any the outermost points of outermost island of member states to agree at any time to settle Indonesian territory, which also means that a dispute between them by any peaceful Ambalat region is located in Indonesian ZEE. means of their own choice. This right of (Agoes, 2006) However the overlapping every member state is guaranteed under claim occurs in Ambalat when Malaysia won Article 280 UNCLOS, which states that: the Sipadan and Ligitan Island from “Nothing in this Part impairs the right Indonesia, thus Indonesia can no longer use of any States Parties to agree at any those Islands as their baseline, which time to settle a dispute between them resulted in not all part of Ambalat belongs concerning the interpretation or

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application of this Convention by any In fact since the entry of force of the peaceful means of their own choice.” UNCLOS, there has been at least Here settlement for marine approximately 71 maritime delimitation delimitation dispute is crucial because an treaties have been negotiated by States undetermined boundary opens a possibility and only six boundaries have been brought of clash and dispute between state, which to international court. can leads to threat to international peace, The examination of the agreements and security, and on the other hand concluded in the period under review delimitation enables neighboring States to demonstrates that the most preferred properly exercise their rights, freedoms, method of delimitation has been the jurisdiction and sovereignty in their drawing of a single maritime boundary, a respective zones. From the diplomatic solution created exclusively by State standpoint, “good fences make good practice. (Qatar vs. Bahrain, 2001) Single neighbors.” (Frost, Wall, and Connery, maritime boundaries are not mentioned in 1979) the Convention, but they have broadly been There are two ways in solving the used both by States and by the international undetermined marine boundary according courts. to UNCLOS. ( Atmaja, 1997) The first is Even though government to determining the boundary directly by states, government diplomacy or negotiation is the which involves negotiation between those most common way to solve a delimitation disputing states. The second way is by the boundary dispute, but however this method involvement of a third party, either it is only work if both of the disputing states international tribunal or third state party. have at least good relation to each other The first way is the most common way out and can leave their ego behind which is for this kind of dispute, negotiations have rarely happened in the practice. ( Rothwell been the most efficient, speedy and and Stephens, 2010) Most of marine inexpensive way of establishing maritime delimitation boundary dispute caused by frontiers between States just like any other the eagerness of states to fight over the dispute settlement in International Law natural resources contained in that area. dispute in general. (Oda, 1995) Delimitation through diplomacy and If the all matter of amicable dispute negotiation is far more advantageous than settlement effort fails, Article 281(1) of adjudication, because there are no limits to UNCLOS will be applicable, which states the considerations, which States may take that: into account for the purpose of making sure “If the States Parties which are parties that they apply equitable procedures. to a dispute concerning the (North Sea Case, 1969) Furthermore, there interpretation or application of this is no legal rule, which guides negotiations on Convention have agreed to seek delimitation. (Oda, 2003) States are settlement of the dispute by a unrestrictedly free to choose any peaceful means of their own choice, circumstances (political, geographical, the procedures provided for in this strategic, environmental, defense, juridical, Part apply only where no settlement economic, etc.), irrespective of their legal has been reached by recourse to such relevance, which would not always be means and the agreement between possible in international adjudication. the parties does not exclude any further procedure”.

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Article 287 of UNCLOS has provide newspaper. (Bernard, 2011) It was several procedure and international tribunal improperly conducted and condemned as that can be chosen by member states to Malaysia ignored 36 diplomatic notes from solve their dispute, which are: 1) ITLOS, 2) the government of Indonesia. It shows that ICJ, 3) Arbitral Tribunals and 4) Special Malaysia has not good faith to settle this Arbitral Tribunals. dispute in an amicable way by diplomatic Member state can choose one of those means. listed international tribunal to solve their However, we cannot just look from dispute in writing declaration when they are Indonesian perspective, as maybe the ratifying, acceding or at any time when they government of Indonesia procrastinating this need. (Boyle, 2007) This third party dispute. A big and emergency case like this involvement is considered as a deterrent or cannot be just solved by sending diplomatic unilateral interpretation of the terms of the notes containing protest. Convention that would lose the compromise achieved during negotiations. (Klein, 2004) F. Most Suitable Dispute Settlement for Ambalat Dispute E. Indonesia and Malaysia Current Effort The first suitable dispute settlement to Settle Ambalat Dispute that author would like to suggest is the Indonesia and Malaysia has once establishment of Joint Development discussed about their marine delimitation Agreement. The delimitation of the maritime dispute and tried to figure out the solution. boundary is not necessarily a panacea for As a result, a treaty was even concluded to the dispute over offshore resources (a regulate the delimitation boundary between panacea for Disputes over offshore Indonesia and Malaysia, this treaty came resources). Both demands on oil reserves into force in 1964. (Forbes, 2001) and fish or marine mammals must respect However, the boundaries have not national boundaries. Even success the limit been fully accomplished until today. It is may still require close cooperation level if noted that there are three locations of countries are opposite or adjacent (opposite maritime boundaries between Indonesia or adjacent states) is rationally to exploit and Malaysia: Malacca Strait, South the cross-border resources. Therefore, Sea, and Celebes Sea, where Ambalat lays. necessary arrangements through joint (Prescot, 2004) Even though this negotiation development. (Low and Churchill, 2012) resulted a convention that was aimed as a As it is known that the joint dispute settlement for marine delimitation development agreement (the joint boundary, it is still not useful since the fact development agreement) covered in a that this dispute cannot solve the problem it particular segment of the UNCLOS, which was intended to solve. Due to this failure of concluded after or in agreement on the negotiation, there are other efforts taken by maritime boundary and is not intended by Indonesian and Malaysian government to Article 74 (3) and 83 (3) of UNCLOS, 1982. solve this dispute such as diplomatic way. In other words, the agreement negotiated in Indonesian government through the recognition of the resources are located Ministry of Foreign Affairs has sent more between the two countries, and the need to than 36 Diplomatic notes protesting the avoid unilateralism in international resource action by Malaysian government. Not only development and management in general. in form of note, but also diplomatic spy war Countries will also prove that the joint in the media though television or development can be negotiated without

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force (compelling) factors that limit disputed States, or is shared with an adjacent or overlapping maritime boundary claims State, the boundary shall be (disputed boundary or overlapping determined by the United States and maritime boundary claims). Demands of the State concerned in accordance coastal states over maritime areas adjacent with equitable principles.” to it along the continental shelf region, not There are many cases of claims on the only involves the region delimitation issues, continental shelf in the future is decided but also issues concerning resource based on the principle of a fair (equity / exploitation of natural resource such as equitable), as decided by the ICJ. Aasen mineral and hydrocarbon reserves. Also, elaborate as follows: "In the Cameroon / delimitation of borders is a politically Nigeria case it was held that there was no sensitive process. It has a direct effect not presumption for any one method to be used only on the rights and interests of those under Articles 74 (1) and 83 (1), putting, in countries with respect to fisheries and theory, all thinkable methods of maritime marine resources, but also oil, gas and delimitation on an equal footing. hydrocarbon resources, navigation and Yet, in the Barbados/Trinidad and other uses over the sea. Therefore, the Tobago Award, it was held that the question of delimitation of the area is so determination of the line of delimitation complex, involving a variety of interests that normally follows that of the helped determine the delimitation. (United corrective/equity approach. In the Nations, 2008) Nicaragua/ Honduras case it was held that Second most suitable settlement is on the use of another method than that of the the basis of equity principle. Equity principle corrective/equity approach would require is one of the principles of maritime a well-founded justification (as indeed was boundary delimitation determination. Ideas the situation in this case). In the or thoughts on a fair principle are at the Guyana/Surinam Award it was held that heart of the delimitation of the Continental there is presumption for the Shelf, which is based on the 1945 Truman corrective/equity approach in situations Proclamation. Dundua mentions the with opposite as well as adjacent coasts. following: And finally in the Romania/Ukraine case it “The notion of equity is at the heart of was held that there is presumption for the the delimitation of the CS and entered corrective/equity approach could be better into the delimitation process with the unless compelling make this unfeasible in the 1945 proclamation of US President particular case. Truman, concerning the delimitation of According to the ICJ, the rights of the the CS between the Unites States and coastal State with respect to the area of the adjacent States. President Truman continental shelf is the natural prolongation proclaimed that: The United States of the land territory into and under the sea regards the natural resources of the exist ipso jure and ab initio based on its subsoil and sea bed of the continental sovereignty over the land and the shelf beneath the high seas but expansion of its sovereign rights for the contiguous to the coasts of the United purpose of exploring the seabed and the States as appertaining to the United exploitation of resources nature. states, subject to its jurisdiction and ICJ decided that the continental shelf control. In cases where the continental to be restricted in accordance with "the shelf extends to the shores of another principles of fair, and considering all the

Giri, Possible Dispute Settlement for Ambalat Dispute 67 relevant circumstances (equitable principles states, as it has been started even before and taking into account all the relevant the independence of Indonesia and cırcumstances) to rule out as much as Malaysia. Ambalat is rich with natural possible from each party, all the parts of the resourches , mostly natural gas and crude continental shelf which is a natural extension oil. to the mainland territory, in, and under the Many incident and territorial dispute sea, without breaking a natural extension of occurs in this area since 2005, especially the land territory of the other country when Malaysian navy ship shot Indonesian (without encroaching on the natural navy ship and refuse to leave the Indonesian prolongation of the land territory of the territory. other). Based on these considerations as There are dispute settlements that is well, the continental shelf Ambalat can be available under UNCLOS to solve this settled. dispute, but non of them is taken by both disputing states. Only negotiation which was G. Conclusion failed and diplomatic way have been taken Ambalat is a very crucial issue for by the government of Indonesia and it is not both Indonesia and Malaysia. This is not a enough to solve this dispute. new dispute between these two neighboring

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