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TO: The Judges of the International Court of Justice The Peace P~lace, The Hague, · The Netherlands.

Amsterdam, 24 August 1993

YOUR EXCELLENCIES:

I hereby amend our Application of 20 March 1993 and our second Request for provisional measures of 27 July 1993 --and in particular Section C thereof-- by filing with the Court in support and substantiation thereof the attached article by Dr. Milan Vego, "Federal Army Deployments in ," that was published in Jane's Intelligence Review () October 1992 at pages 445 - 448. This article in a well-respected, expert, and internationally recognized authorative source provides conclusive evidence of the fact that the rump Yugoslavia ( and ) actually exercises operational command-and-control over the J.N.A or Y.P.A. forces and units as well as the various Serb militia, and paramilitary units that have beeri and still are as of today operating illegally in the Republic of Bosnia and Herzegovina and in violation of the Genocide Convention as well as this Court's Order of 8 April 1993. We hereby submit this expert article in support of our second Request for provisional measures of 27 July 1993.

Please accept, Excellencies, the assurance of my highest consideration.

Professer Francis A. Boyle General Agent for the Republic of Bosnia and Herzegovina before the International Court of Justice VIA FAX ... • EUROPE - October 1992 JANE'S"INTELLIGENCE BE.VIEW-- -J-J5 Federal AriTiy Deployments in Bosnia and Herzegovina

War in Bosnia and Herzegovina was responsibility of the 1st Military District of the strength of the federal army (a total probably inevitable given the realities of (MO) in Belgrade. Besides Bosnia and of about 140 000 men) was deployed in the situation. However, the extent and Herzegovina. this military district the republic on the eve of the current intensity of destruction, especially of encompassed a part of Serbia proper hostilities. civilian targets and populations. was and the province of Vojvodina. Belgrade's figure of the percentage of unexpected. The main but not sole culprit On the territory of Bosnia and local Serbs serving in the federal army in of the destruction and the atrocities has Herzegovina were deployed forces of the republic was immediately challenged been the Army of the Federal Republic of three army corps totalling sorne 45 000 by the government in which Yugoslavia (FRY), formerly known as the men: 17th Corps with ils headquarters in claimed thal not more than 20 per cent of Yugoslav People's Army (YPA). Tuzla, 5th Corps in , and 4th the federal army personnel were local The war in Bosnia and Herzegovina is Corps in Sarajevo. The boundary residents. This means thal out of 95 000 not a 'civil war' or 'ethnie conflict' as between the Tuzla, Banja Luka and men, only 19 000 troops were local many Western observers falsely assert. lt Sarajevo Corps was along the line Grmet Serbs. The tact was thal by then most was carefully planned by the top political Mountain - Vla~ié Mountain - non-Serbs had departed or deserted the and military leadership in Belgrade. The (see map). North of thal line was the former federal army. So by March 1992, former federal army trbops deployed in deployment area of the Tuzla and the about 97 per cent of personnel were Bosnia and Herzegovina were Banja Luka Corps, while south of it was Serbs and Montenegrins. Also, the reorganized and reinforced with ether deployed the Sarajevo Corps. The troops percentage of the conscripts was much units withdrawn from Slovenia and of the Tuzla Corps were also deployed in lower than at the beginning of the war in . The reorganization of the YPA the Croatian province of Slavonija. The Croatia because a large number of carried out in Oecember 1991 led to the units of the Banja Luka Corps were Serbian and Montenegrin reservists were establishment of a new military district responsible for the defence of western called to active service. with ils headquarters in Sarajevo. Bosnia and part of Central Dalmatia. This By 20 May about 14 000 military Additional federal troops were moved to boundary between the various corps personnel were withdrawn from Bosnia Bosnia and Herzegovina from Serbia in deployed in Bosnia and Herzegovina and Herzegovina. Specifically, transport the first few months of 1992. By then, the was one more strand of evidence to point airerait and helicopter units of the federal process of 'Serbianization' of the former to the fact thal the former federal army air force transported about 13 540 federal army, which started in the paid seant attention to the internai soldiers, 304 wounded, 43 600 civilians, aftermath of war in Slovenia, was almost borders in the deployment of its units. and 2566 tons of cargo. Most of the complete. The main aim of the personnel were apparently stationed in redeployments and reorganization of the and eastern Herzegovina. federal troops in Bosnia and Herzegovina Partial Withdrawal Thus, a total of about 80 000 former . was to ensure military control of thal federal troops were formally transferred republic_ The former federal army was ln the months prior to the formai to the 'Territorial Defence Forces of the apparently determined not to be forced. declaration .of independance. the Serbian Republic of Bosnia and to leave the territory of yet another government in Sarajevo was involved in Hèrzegovina'. republic of the former Yugoslavia. The prolongea and ultimately fruitless talks army, while professing to act to prevent with Belgrade about the status of the inter-ethnie clashes in Bosnia and federal troops on the republic's territory. Command and Control Herzegoyina, was covertfy providing Finally, the republic's state presidency large quantities of arms to the local and government ordered, in separate There is a great deal of genuine Serbian para-military forces. Jhus, the statements on 27 April 1992, thal ali confusion in the West as who actually stage was set for the Serbian attempt to (emphasis added) federal army troops contrais the Serbian forces in Bosnia and seize sorne 70 per cent of Bosnian leave Bosnian territory. For its part, the Herzegovina. To make the situation even territory, even though the local Serbs federal presidency in Belgrade more complicated, the regime in made up only about 31 per cent of the announced on 4 May the withdrawal of ali Belgrade consistently tries to do its best population. The illegally established military personnel and their dependants to muqdle the issue by denying ils own · Serbian Republic of Bosnia and who were non-residents of Bosnia and responsibility for war in the neighbouring Herzegovina' would never have been Herzegovina. Their withdrawal was to be republic. For example, the President of created without the whole-hearted completed within 15 days. The rest of the the self-proclaimed FRY, Mr Oobrica support and participation of the former federal troops were transferred to the ilisié (who is also Supreme Commander federal army. illegally established 'Territorial Defence of the Federal Army) falsely asserted on Forces of the Serbian Republic of Bosnia 15 July thal the army does not provide and Herzegovina'. any weapons and military equipment to Federal Army's Presence The government in Belgrade asserted the former 'Territorial Defence Forces of that there was a total 60 000 federal the Serbian Republic of Bosnia and Before the outbreak of hostilities in troops in Bosnia and Herzegovina, of Herzegovina', except for 'seme limited Slave nia in June 1991, the major part of whom 80 per cent were residents of the humanitarian aid'. Moreover, it does not ·he former YPA was deployed in the republic. However, the federal army has command and control these forces. But ·nilitary districts encompassing the areas deployed closer to 95 000 men on the the reality is quite different. The 31ong Yugoslavia's borders. Oefence of territory of the republic. The latter figure operational chain of command in the 3osnia and Herzegovina was the also agrees with a report that 68 per cent federal army runs from the Supreme JANE S INTELLIGENCE REVIEW October 1992- EUROPE

oerence Councit (composed of the the non-Serbian civilian targets in the are kept supplied by the Army of the president of the FRY and presidents of besieged Sarajevo. His headquarters FRY. Thus. lhere is little doubt that the the republics of Serbia and Montenegro) was re ~.ently moved from Pale (ne ar regime in Belgrade pulls ali the strings in through the General Staff in Belgrade to Sarajevo) lo more secure the employment of the federal troops in the commanders of: 1st MO (Belgrade). (sorne 55 km northeast of Sarajevo). This the war in Bosnia and Herzegovina. 4th MD (Podgorica), the 'Army of the headquarters is located in an Serbian Republic of Bosnia and underground bunker providing multi­ Herzegovina', Naval Districi (Kumbor. channel and secure communications to Ground Troops Bay of Cattaro). Air Force and Air ail subordinate corps commanders. the Defence units. General Staff in Belgrade as weil as the Currently, out of total of some 80 000 The commander of the 'Army of the president of the FRY. former federal troops deployed in Bosnia Serbian Republic of Bosnia and Formally subordinate to General Mladié . and Herzegovina, only about 35 000 are Herzegovina' is Lieutenant General Ratko are commanders of four army corps, one considered an effective military force. Mladié, the former commander of the 9th provisional 'operational group,' as weil as The Serbian ground forces in western Corps in Knin. General Mladié is air force and air defence units. General Bosnia are organized into two corps: professionally a mediocre officer, and Mladié clearly does not control ali and 1 Krajina Corps in Banja Luka (formerly extremely brutal in dealing with the every action of his subordinate corps 5th Corps) and Il Krajina Corps in Orvar Croatian and Moslem populations. ln the commanders in the field; apparently, they (formerly Bihaé Corps). ln addition, the war in Croatia he became notorious for have considerable latitude in carrying out troops of the former 9th Corps, alter their his barbarie treatment of the Croatian the ir assigned tasks .•Co-operation redeployment on the Bosnian side of the civitians and his threats to destroy the between the federal army troops and border with Croatia this Spring, were Croatian coast al city of Sibenik. He has local Serbian militia units is reportedly not provisionally organized into the Knin shawn the same brutality by giving very effective. Bath the troops of the Operational Group. · explicit orders ta bombard and burn ali former federal army and the local militias The Serbian forces deployed in eastern

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EUROPE- October 1992 JANE'S INTELLIGENCE REVIEW ~-l7

belong lo lhe Ill Nonh Bosn;ao in mid-July 1992 thal the Serbian forces even true for the Serbian and 6.Corps composed of the forces of the had 300 tanks. 231 guns. 25 combat Montenegrin reservists. despite the tact former Tuzla Operational Group and airerait and trainers. 20 helicopters. and thal they are well-paid; their salary is parts of the Sabac (Valjevo) Corps. The four surface-ta-air missile (SAM) divisions reportedly three times what an average troops deployed in central and (squadrons in the West). Tne acting Chiel worker earns. The units withdrawn from southeastern part of Bosnia are of the General Staff. General Zivota Slovenia and Croatia were poorly subordinate to IV East Bosnian Corps Panic. in a confidentiaf speech defending structured and largely unsuitable for (also called Sarajevo-Romanija Corps). the federal army against the charges of combat employment in their new They are composed of units of the former betraying the Bosnian Serbs said that the deployment areas. A similar situation 4th Corps (Sarajevo) and sorne units Serbian forces in the republic have prevails even in the units sent as from Slovenia and Croatia which were acquired control of 900 tanks and reinforcements to the former 2nd MD previously deployed to the territory of the armoured vehicles. 852 guns and from other parts of the country. The only now apparenlly defunct 2nd MD. multiple rocket launchers. one rocket troops in Bosnia and Herzegovina which On the territory of eastern Herzegovina brigade. and 48 airerait (apparenlly not have any combat effectiveness are heavy were deployed forces of the former Utice including helicopters). and rocket artillery, and the military Corps. Afler the Croatian and Moslem The Croatian sources estimate thal the police. forces liberated Mostar. the headquarters Serbs possess about 350 tanks (T54/55. of this corps was relocated to . T84), more than 200 armoured personnel ln tact. there are some reports which carriers. 1000 field guns (76, 100, 105, Air Force indicate thal major part of the Utice 122, 130, 152. and 155 mm). 800 Corps has been withdrawn to its former recoilless guns (82 and 105 mm). and The 'Army of the Serbian Republic of deployment area in Serbia. The major 1200 mortars (82 and 120 mm). Many of Bosnia and Herzegovina' has recently part of the newly established these tanks and armoured vehicles have created ils own air force and air defence Herzegovinian Corps (HO at in BileÇa) is been tost or heavify damaged in the element. Officially, the Serbian forces composed of elements of the Podgorica fighting with the Croatian forces. Other have about 48 combat aircraft and sorne Corps and the former 13th Corps. These tanks in the inventory might not be 20 helicopters. However, the number of units were previously part of Il serviceable because of the lack of spare serviceable fixed-wing airerait is Operational Group for Herzegovina (also parts and maintenance personnel. The considerably lower than indicated. This is known as the Trebinje-Bileéa Operational Serbian forces also use large number of primarily due to lack of adequate Group). The commander of the the domestically produced 128 mm maintenance and also because of Herzegovinian Corps is a colonel. a sign Plamen and Oganj multiple rocket relatively high tosses inflicted by the perhaps thal its strength does not launchers. and a small number of the Croatian air defences in western exceed severa! thousand men. joinlly developed lraqi-Yugoslav 262 mm Herzegovina. The total number of The organization and equipment of the Orkan multiple rocket launcher which can helicopters might be, however, higher federal troops ~n Bosnia and Herzegovina fire submunitions up to ranges of 50 km. than indicated. varies greally.There is also a Jack of The Serbian forces have huge quantities The principal airerait used by the reliable open sources about the real of small arms and ammunition. Serbian forces for ground support are strength of these forces. A Croatian Reportedly~ the federal army illegally domestically designed Orao-2 and source claimed thal about 70 per cent of seized about 450 000 small arms. of Jastreb. A few MiG-21s are used mostly the weapons and equipment laken away which 20 000 were in Sarajevo atone. for reconnaissance. Despite Serbian with the federal troops deployed in · The former federal troops in Bosnia deniais. the federal air force jets are Slovenia and Croatia was eventually and Herzegovina are with sorne extensively used in support of the assigned to the former 4th, 17th. and exceptions very poorly trained and led. Serbian lorces on the ground. These jets 37th Corps, white 30 percent was There is a great shortage of junior use the air bases at Batajnica (near assigned to the former 5th Corps and the officers and NCOs. The morale and Belgrade). Ni S. Ponikve (near Utice). Bihaé Corps. The FRY President claimed discipline of the troops is very low. This is PriSlina. and Podgorica for combat

An Oganf128 mm multiple rocket launcher of the Federal Army. ·J.' ,,r''!?' ,J..: JANE'S INTELLIGENCE REVIEW October 1992- EUROPE . missions over Bosnia and Herzegovina. missiles around the besieged city of and Herzegovina. Reportedly. eight ex-lraqi MiG-23 fighter Sarajevo. The Serbian troor:;c; in the field The operational chain of command in bombers are used to bomb targets in use large numbers of triple 2Qmm the former federal army has not t:ieen Bosnia from their bases in Serbia. The Oerlikon and the Czech-designed twin radically changed since the summer of most advanced airerait in the inventory of 30 mm AA guns. However. none of these 1991. However. the Serbian president, the former federal air force. the MiG-29 guns is radar-controlled. The troops in Slobodan Milosevié, exercises far more 'Fulcrum·. does not fly very olten and is the field are equipped with relatively control over the former federal army than kept in readiness for the defence of large numbers of the ex-Soviet SA-7 he did only a few months ago. Alter the. Belgrade. (Strela-1/2M) missiles. purge of more thal 40 generais and Recent reports suggest thal Serbs flew admirais in April 1992, there are no their transport airerait from Batajnica to 'Titoist' generais in office, regardless or the Udbina airport northwest of Knin and Logistical Support whether they were Serbs or non-Serbs. then to Banja Luka to carry supplies for Currently, the General Staff in Belgrade is their troops. These flights were allowed The Serbian forces have more than obedient to President Milosevié. The by the UN under the Serbian pretext of sufficient supplies of weapons and Belgrade regime not only plans the the 'humanitarian aid' as such flights ammunition to continue fighting at the actions of the Serbian forces in.Bosnia were initially used for the evacuation of current leve! of intensity for more than and Herzegovina but also keeps these federaltroops and their dependants from two years according to sorne reports. forces supplied with weapons, western Bosnia. None of the flights was The Serbian forces have control of almost equipment, and ammunition. The supervised by the UN. unlike flights to two-thirds of the 250 DOO tons of commanders of the Serbian forces in that Sarajevo airport. However. a senior UN ammunition in the possession of the republic are assigned, promoted or official in has vehemently denied former federal army. Yet. these forces are dismissed from their posts by the these reports. highly dependent on other supplies. General' Staff in Belgrade, which in turn The main base for the Serbian fixed­ .especially fuel for airerait. tanks and gets its orders from President Milosevié. wing airerait in Bosnia is at Mahovljani armoured vehiclès. and special (near Banja Luka). This base is small and equipment which can only come from Or Milan Vega was born in the former cannat accommodate large numbers of Serbia and Montenegro. Thus. the Yugoslavia but now works in the USA airerait. Moreover, its fuel capacity is only Serbian forces are supplied bath by the where he teaches East European history 500 tons. So far. the Serbian forces have air and overland. Despite the UN and politics as weil as naval operational not succeeded in seizing a refinery at sanctions. there are reports thal literally art. A full list of references used in this Bosanski Brod which would !essen their hundreds of Serbian tractor-trailers. article can be obtained from the Editor. need to rely on fuel transported overland including oil tankers move daily over the from Serbia. Because the repair facility roads from northwestern part of Serbia Notes on depl~ymÈmts {~pp~~~~~} ' 'Kozmos' at Banja Luka was evacuated across the River to and to Serbia. servicing and maintenance of then to Banja Luka and other cilies in 1. corr;Posec:t'étthe tomiër Tuila';:' the remaining aircraft is exceedingly western Bosnia. Other raad · Operational Gro'ùp {n:imriarits-ot the · . difficult. Most of the helicopters are communications to the Serbian forces 17th Corpsf and the newly established. Sabac {Vaijevo).Cofl:is.: <· · based at Zalutani, also near Banja Luka. also run across the Drina River at r-_~{( ~~- < 2. The Serbian term for the gùeirilla~type Another large base near Tuzla. used by Loznica. Bralinac. and Vi~grad. Another ~~~~ti~~ -~Oqelled ~ftër_~i~~!~~'. ::·:~~:·. ··- .. the former federal air force. is overland supply used to supply the elements in the·Tito-led-forces of the ~ surrounded by Moslem and Croatian Serbian forces runs from Séepan Polje Second World War,·- . .:.;,ë"···:·;'.'--::·.·-'-' · forces. The Butmir airport near Sarajevo (Montenegro) to Sarajevo. 3. Formeriy 5th Gorps'; '-~:-: '? ·· · ·· is currently controlled by the UN forces 4. Probably only .one battery is operable ... _ and is used exclusively for humanitarian Conclusions 5. Formerly Bihaé Corpst-','·:''' ·;.Uf •• :· · · · aid to the besieged city. The air base at s. Formerly 9th Coq)s: Attefthe aniv~ll of ,, Mostar has been evacuated as it was a .. the UNPROFOR forces to 'Sector . major part of the airerait factory 'Soko'. A The former federal troops deployed in South' (horthe,r:n palmatia), the r:najor, ..·., naval helicopter squadron (Mi-14 Bosnia and Herzegovina althdugh part of this coips wias redeployed to the • 'Haze-A' and Ka-25 'Hormone-A') based relatively large and powerfully armed are Bosnian side of the border WitlÏ•Croatia} there has been relocated to nvat (Bay of poorly organized. trained and led. Their 7.. Formerly 4m qorP$. Alsoca:iti3d thfi:~, .'i; Cattaro). successes have been almost entirely due Sarajevo-Romanija·corp's7'::;.:A~-'.~:::•<:~}- to their overwhelming superiority in s_ The Corpsl-ia. ..vas·moved troiTIMostar·, firepower over the Moslem and Croatian to Nevesinje probablyjrl":1ûne 19.~.;; : : Air Defence forces. However. whenever they have Reportedly, most if not ali uni~ of the . met a well-armed and motivated Uiice Corps have been-wittidraw·ri to Air defence of the Serbian forces in opponent they have suffered defeat or the ir previous deployment areà around : : Bosnia and Herzegovina is generally severe setback. weak and is certainly no match for any Perhaps. one of the most misleading US and allied forces, The only long-range views among sorne Western politicians io.~=~=~~:11. From.the former 4th ~~tèf~;Corps,:.:/i''·':f*< .•• · .. ~ · air surveillance radars (probably Soviet and media is thal the Serbian forces in P-35s) are located on the mountain tops Bosnia ançf Herzegovina are somehow 12. Composed of parts of the Podgorica of Jahorina (southeast of Sarajevo), beyond anyone's control. This is just Corps and .the Rijeka Corps. TJ:!e . · · .·:· Kozara (northeast of Banja Luka}. what the Belgrade regime wants the currerit strength of the corps is probably Pljesevica (west of Bihaé). and outside world to believe. But this is totally rtlJJCh lower than that shown 'with sorne· (north of Tuzla). The air base near Banja taise. The recent resubordination of the units being redeployEK! toMo~ieri,egrin ... territory: , ••:. : ... · (: ,, •· .· ·. Luka is defended by one division of the former federal army units in Bosnia and ~'; .'~:',' :~· :~~(. 13. Previouslù1art of the Il Opei'ational ·.. · SA-2 (Volkhov) and a single battery of the Herzegovina was designed to fulfil the Group fo~ Herzegovina {ais() called. the ·• · SA-6 (KUB-M) missiles. ln addition. one demands of the CSCE and EC and Bil~a-Treblnje Operational Group) •• ·.- · battery of the Swedish radar-controlled thereby avoid sanctions. white denying 14. Perhâps as· many as 20 of these aircraft . 40 mm guns is deployed around any responsibility and culpability of the L?O M have been tost in: combat so far, - -~· the base. According to sorne federal army and the Serbian leadership 15. Northwest of Knin ln the Serbian •· ·• · unconfirmed reports the Serbs have afso for the aggression against the controlled part of Croatia./ '':: '; deployed two divisions of SA-3/6/9 internationally recognized state of Bosnia