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Environmental and Economic Aspects of the West Philippine Sea

2015, National Security Review, National Defense College of the Philippines

The West Philippine Sea includes the Luzon Sea as well as the waters around, within, and adjacent to the Kalayaan Island Group (KIG) and Bajo de Masinloc also known as Scarborough Shoal. The KIG is part of what is referred to as the disputed Spratly archipelago. Our estimate is that the KIG or the Spratlys are about 281,000 km 2 in area. The South China Sea has been studied in the past by the Indochina Institute of Oceanography, the Nha Trang Institute of Oceanography of Vietnam and probably also by other agencies. The latest to make joint oceanographic studies in the area were the Philippines and Vietnam. The present paper covers the geological history of the South China Sea, the Spratlys and the Palawan Island group including parts of Mindoro and Panay Islands and their rifting from the Asian continent in the past; the physical environment of the Spratlys, including the islands, shoals, and atolls and current systems in the South China Sea; the biological resources with emphasis on the coral reefs systems and the status of fish and fishery resources; the economic values of reef and pelagic fisheries; the connectivity of the biodiversity resources of the Spratlys with the Philippines and other countries; the disturbances in the area that could have a negative impact on the sustainability of fisheries and marine biodiversity; and finally recommendations on ocean governance policy and programs needed for the maintenance of the integrity of the sea environment and its resources especially no-take marine reserves and transborder peace parks. These parks, which have been proven useful in some marine areas of the world can be instruments for cooperation for research and development in areas that are claimed by several countries. These recommendations pertain to cooperative protection and management of the 2 South China Sea by maritime countries surrounding the area under the UNCLOS.

Environmental and Economic Aspects of the West Philippine Sea Angel C. Alcala1 and Alberto A. Encomienda2 1Silliman University Angelo King Center for Research and Environmental Management, Silliman University, Dumaguete City 6200 email: [email protected] 2Former Ambassador, Republic of the Philippines and former Head of Maritime and Ocean Affairs Center, Department of Foreign Affairs, Philippines Abstract The West Philippine Sea includes the Luzon Sea as well as the waters around, within, and adjacent to the Kalayaan Island Group (KIG) and Bajo de Masinloc also known as Scarborough Shoal. The KIG is part of what is referred to as the disputed Spratly archipelago. Our estimate is that the KIG or the Spratlys are about 281,000 km2 in area. The South China Sea has been studied in the past by the Indochina Institute of Oceanography, the Nha Trang Institute of Oceanography of Vietnam and probably also by other agencies. The latest to make joint oceanographic studies in the area were the Philippines and Vietnam. The present paper covers the geological history of the South China Sea, the Spratlys and the Palawan Island group including parts of Mindoro and Panay Islands and their rifting from the Asian continent in the past; the physical environment of the Spratlys, including the islands, shoals, and atolls and current systems in the South China Sea; the biological resources with emphasis on the coral reefs systems and the status of fish and fishery resources; the economic values of reef and pelagic fisheries; the connectivity of the biodiversity resources of the Spratlys with the Philippines and other countries; the disturbances in the area that could have a negative impact on the sustainability of fisheries and marine biodiversity; and finally recommendations on ocean governance policy and programs needed for the maintenance of the integrity of the sea environment and its resources especially no-take marine reserves and transborder peace parks. These parks, which have been proven useful in some marine areas of the world can be instruments for cooperation for research and development in areas that are claimed by several countries. These recommendations pertain to cooperative protection and management of the 1 South China Sea by maritime countries surrounding the area under the UNCLOS. Introduction The South China Sea (SCS) has been described by Fang et al. (2006) as one of the largest marginal seas of the world. Marginal waters are marine waters adjacent to a state and under its jurisdiction (Fig. 1). It extends from the Karimata Strait (~3° South) to the middle of Taiwan Strait (~23.5° North), with the Asian mainland, Indo-China Peninsula, Malay Peninsula, and Sumatra as its western border and Taiwan, the Luzon Strait and the islands of Luzon, Palawan, and Borneo (Kalimantan) as its eastern border. Its area is 3.5 x 106 km2. Its deepest basin is about 5,000m in the north-central part but most of it is shallower than 4,000-5,000 meters. There are four archipelagos--- the Pratas, Macclesfield Bank, Paracels, and Spratlys --- covering an area of 800,000 square kilometres. For the Spratlys, six countries claim titles to all or parts of the archipelago (Encomienda 2008). The Philippines is one of these countries that claim sovereignty over portions of the archipelago. The name “West Philippine Sea” refers to marine areas subject to the internal Philippine Administrative Order No. 29 dated 05 September 2012 and “include the Luzon Sea as well as the waters around, within, and adjacent to the Kalayaan Island Group and Bajo de Masinloc also known as Scarborough Shoal.” The West Philippine Sea covers sea areas that are already Philippine jurisdiction (Fig. 2). This designation may need the approval of the International Hydrographic Organization for international acceptance (Encomienda 2015). The total sea area exclusive of Scarborough Shoal has been estimated by us at 281, 000 km2. Studies by scientists of the Indochina Institute of Oceanography on the corals and other organisms in the Paracel and the Spratly archipelagos in the South China Sea were made in the 1890s, the 1920s, and the 1930s. These studies were interrupted beginning in 1933 but were resumed in the 1980s up to 1996 by scientists at the Nha Trang Institute of Oceanography of Vietnam in cooperation with Russian scientists (Tuan et al. (1997). Unfortunately, the 2 authors were not able to access the reports on these earlier studies. The more recent study of the Spratlys was made in 1996-2007 by the Philippines-Vietnam Joint Oceanographic and Marine Research Expedition in the South China Sea (JOMSRE-SCS), initiated by Philippine President Fidel V. Ramos and Vietnam President Le Duc Anh. For purposes of this paper, the discussion will deal mainly with the Spratly archipelago and Scarborough Shoal, the reef systems that were surveyed by Philippine and Vietnamese scientists during the three JOMSRE-SCS expeditions in 1996-2007 as shown in Fig. 2. Plankton and oceanographic data were collected at several ocean stations aboard the Philippine research vessel on cruise from the Philippines to the Spratlys. The reef systems and their benthic components explored by these marine expeditions were Scarborough Shoal, Nares Bank, Trident Shoal, Menzies Reef, North Danger Reef, and Jackson Atoll. These expeditions were conducted in April to early May for two to three weeks, except for JOMSRE II, which was conducted for a week only because of bad weather in early June 2000. The Conference Proceedings for JOMSRE-SCS I (1997) and for JOMSRE-SCS III and IV (2008) served as sources of data for this paper. The book edited by Aliño and Quibilan titled Kalayaan Islands (2003) was also used as reference for the present paper. Geological History The Palawan archipelago (including southern Mindoro and extreme part of northern Panay [Hamilton 1979, pp. 113, 197, 212]) was part of the Asian continent some 70-62 million years ago and rifting of the continental Asia margin between 32 and 16 million years ago led to the formation of the South China Sea (Siringan 2003, Hieu et al. 1997). For over 30 million years, the Palawan archipelago moved away from the Asian continent and became closer to Luzon due to sheer and rift movement of the Pacific plate. The islands now known as the Spratly archipelago (including the KIG) became clearly formed some 10 million years ago as sea level changes and the tectonic processes 3 occurred (Aliño and Quibilan 2003). A computer-generated animation of the South China Sea basin of Robert Hall (2002) is included in the book. Physical and Biological Aspects of the Spratly Archipelago The Spratly Group of islands (including the KIG) is a marine environment characterized by low islands with generally no or sparse vegetation, shoals, atolls, and sea waters at various depths. One can right away infer the important role of ocean currents, tidal level and atmospheric processes in the dynamics of the whole archipelago. Discussions on the oceanography and climatic aspects such as the El Nino are found in the papers of Wang et al. 2006, Fang et al. 2006, and Zheng et al. 2006. The important role of the monsoons in surface water circulation and their effects in the distribution of marine propagules (larvae of marine organisms) in the South China Sea and internal seas of the Philippines is discussed by Villanoy (2003). Of special interest are the ocean currents, Luzon Gyre off western Luzon and the Nansha Gyre off western Palawan (Fig.1), both of which circulate ocean water in the counter clockwise direction during the winter months (Zheng et al. 2006). These gyres probably cause the movement of marine propagules (e.g. fish larvae) to western Luzon and the Palawan area. Other current patterns make it possible for exchange of some species of fish and invertebrates between the Spratlys and the Palawan areas (Endriga 2003, Juinio-Meñez et al. 2003, Ochavillo 2003). The vertical profiles at Stations 11 and 12 of JOMSRE-SCS I near the Philippines show tropical oceanic water stratification into three layers: the upper layer of 10 meters with 28-29°C. temperature; the next deeper layer of 200 meters as the thermocline (ca15-29°C), which prevents movement of nutrients from the deepest layer to the upper layer; and the deepest cool layer from 300 to 800 meters with temperatures of ca 1-15°C (Hung et al. 1997). The thermocline acts to limit photosynthetic processes and biological production in deep oceans. The primary productivity of the KIG in the Spratlys is 147-166 gC/m2 per year, higher than that in open oceans (San Diego-McGlone 2003). Much of this 4 productivity is due to the phytoplankton and is discussed by Vietnamese scientists who participated in JOMSRE I, III, IV. Coral reefs, estimated at 600-1,000 km2 (Aliño and Quibilan 2003) are the dominant ecosystem in the Spratlys. Seagrass meadows and algal beds are sparse. Mangroves are absent. Patches of seagrass beds consist of four species. The large variety of marine biodiversity and fishery species are generally found in the coral reefs (Fig. 3). Coral reef types include low profile reefs and high profile reefs (more than a meter high) with large surge channels due to strong wave action caused by monsoon winds, the so-called spur and groove formations (Quibilan 2003). Hard coral species found at 18 JOMSRE-SCS I, III and IV sites consisted of 250 species in 66 genera and 18 families. The number of coral species is slightly less than half of the number recorded for the Philippines, which is ca 533, according to the foremost coral expert Dr. J.E.N. Veron. At least one new hard coral species has been reported from the Spratlys and few more rare ones. Hard coral cover was 22.85% on the average and soft coral cover was 1.93% (Long et al. 2008). However, there were some areas with high live coral cover. Atolls in the Spratlys are generally roundish, oval or polygonal in shape with islands or shallow reefs that may be exposed at low tides and serve to mark the atoll outlines that enclose deeper lagoons (Fig. 4). Sea water moves in and out of lagoons mainly through deeper gaps in the ring structure. Lagoons may accumulate nutrients that are released periodically (Long and Chung 2008). The North Danger Reef and Jackson Atoll studied during JOMSRE-SCS III and IV (Cayme et al. 2008, Du et al. 2008) tend to show higher concentrations of nutrients in the upper 20 meters of the lagoons. These nutrients are dispersed to adjacent oceanic waters. Juvenile and adult fish are also found abundant in lagoons of atolls. Macroalgae were mostly the red alga Laurencia and the green coralline alga Halimeda according to Calumpong et al. (2008). Trono (2003) remarks 5 that the algal flora of the Spratlys consisted of fewer species compared to that of the Sulu Sea. It is worth noting that the JOMSRE-SCS expeditions III and IV did not observe other vertebrate species like sea turtles, sea snakes, sharks and whales and dolphins in the vicinity of surveyed areas. But it is possible that they were present in places we did not operate. Whales and dolphins could add to the value of the Spratlys in terms of incomes from ecotourism. The two most economically important macro-invertebrates found on North Danger Reef, Trident Shoal and Jackson Atoll, were four species of giant clams, five species of sea cucumbers and a few species of gastropods (Calumpong and Macansantos 2008). The rest of the 167 invertebrate species they observed on the three reef systems were sponges, molluscs and sea stars. The predatory crown-of-thorns starfish was observed in moderate numbers. Long et al. (2008) reported a smaller number of invertebrate taxa. In 2007, four species of sea cucumbers were observed being dried in the sun in the Great Danger Reef (Calumpong and Macansantos 2008). The near disappearance of these species in 2007 is a piece of evidence for the heavy exploitation of these species by fishermen. As regards giant clams, only four species were observed in Jackson Atoll in 2007. Phung et al. (1997) reported 168 species of fish in Menzies, Trident, Nares and Scarborough. Nañola et al. (1997) reported 248 species from 1991 to 1996 in the KIG. They also gave the average standing stock (biomass) of fish in the area at 114 metric tons per km2. The number of species increases to 404 species in 144 genera and 45 families if the data from JOMSRE-SCS I are added. Stockwell and Long found that the dominant families of fish were the Labridae and Pomacentridae, both of which are not really food fishes. The families Acanthuridae, Caesionidae, Lethrinidae, Lutjanidae, Siganidae and Mullidae made up the target (food) families. (Note the absence of groupers, Family Serranidae.) Stockwell and Long (2008) reported that reefs exposed to the southwest monsoon had higher fish densities compared to reefs exposed to the northeast monsoon. One probable reason is that more recruitment occurs 6 from the southern reefs. Long et al. (2008) gave the average biomass of fish at 42.1 metric tons per km2, about one-third of that reported by JOMSRE I in 1996. The drastic reduction must have been due to increased exploitation during the past 11 years (1996-2007). Economic Importance of the Spratlys The Spratlys, as far as the Philippines is concerned, is recognized as a source of fisheries and livelihoods for fishers in coastal communities. The archipelago has an important role in the sustainability of fishery species and food security in the future. Aside from fisheries, the area can be a good source of petroleum and other fossil fuels. Its unique marine biodiversity can support ecotourism and provide more livelihood and opportunities for recreational activities for Filipinos. Furthermore, the area, being part of a large ecosystem, can allow scientific research on such urgent subjects as climate change, storm surges, connectivity of marine areas, conservation of biodiversity, functional importance of atolls, sustainable development, etc. Because of limitations of space only few topics can be discussed at length in this paper, such as fisheries and future sustainability of this resource. Aliño et al. (2003) gave an estimate of 78-105 metric tons per km2 as the pelagic fish yield of the Spratly coral reefs based on the Bureau of Fisheries and Aquatic Resources (BFAR)’s 1990 report. The value of this annual catch is US Dollars 47-105 million. The average yield is about 90 metric tons per km2, way above the maximum sustainable yield. This can happen only if the whole fish biomass on reefs is swept clean by very efficient fishing gears such as muro-ami and paaling. Most of this pelagic catch consisted of caesionids (dalagang bukid) with a smaller contribution from skipjacks and yellow fin tuna. The potential catch in the areas of the Spratlys, Scarborough Shoal and Macclesfield Bank, where the paaling fishers operate, has been estimated at 5 million tons per year. However, a study by Abesamis (2003) has shown that the catch rates of muro-ami and paaling fishing have been decreasing (Fig. 5). Fish yield studies of coral reefs in the Philippines showed that good to excellent, high profile coral reefs have sustainable yields of about 15-20 metric 7 tons/ km2 per year (Alcala and Russ 1990). Only occasionally can reefs deliver about 30 metric tons/km2 per year; an example is Sumilon Island, off southern Cebu, where a no-take marine reserve was set up and fully protected from fishing for 10 years. The Spratlys most probably do not have the potential to produce more than 15-20 metric tons/km2 per year as sustainable annual yield-- as long as they do not have adequate-sized no-take marine reserves that can supply fish to the fished area through adult fish spillover. It is not surprising that catch rates declined because of fishing beyond the limits of maximum sustainable yield. Given the area of coral reefs in the Spratlys as 600-1,000 km2 with potential fish yield of 20 metric tons/km2 per year, the potential annual sustainable fishery production would be 12,000 to 20,000 metric tons. These would have a value of 12,000 to 20,000 million US dollars. The fishing gear developed to efficiently harvest coral reef fish is the muroami, which consists of a bagnet positioned downstream. Upstream, a cordon of swimmers (100-200 mostly boys), swim to drive schooling and demersal (bottom-dwelling) fishes to the bagnet using scare lines tied to rocks weighing several kilograms. By pounding the corals with these rocks to create noise and disturbance as they swim towards the bagnet, the fish at the bottom and in the water column are herded to the bagnet. Because of the finding that the method resulted in substantial damage to coral reefs (e.g. Carpenter and Alcala 1977), the scaring procedure was modified by the BFAR. Instead of heavy rocks, air bubbles (paaling) from compressed air were used to drive the fish. Paaling, like muro-ami, is such an efficient fishing method that 50% or more of the standing stock of fish on reefs are caught. The use of muro-ami to cach reef fishes began in 1948 with 15 commercial vessels, which increased to 301-309 in 1994-1995. The fish production by muro-ami has been lumped with the catch from other fishing gears in the total commercial catch making it impossible to determine catches. In 1997, the fish production from this gear was 884, 651 metric tons (Thomas 1999). What can be said is that muro-ami operations extended to the Spratlys especially after the 8 more accessible Palawan reefs became overfished. This was revealed by the seizure of three fishing vessels and 43 crewmen of Frabelle Fishing Corporation by the Malaysian Navy on the issue of jurisdiction of the fishing grounds of the Spratlys (Thomas 1999). It is, in fact, common knowledge that Chinese, Taiwanese and Vietnamese fishers operate in the West Philippine Sea. Connectivity of the Spratlys Fish larvae were sampled from 14 stations using double oblique tows on board the Philippine vessel BRP Hydrographer Presbitero during JOMSRESCS III and JOMSRE-SCS 1V. About 1,324 fish larvae out of the 1,884 were identified to belong to 43 fish families (Floren 2008). During JOMSRE III, most larvae in shallow water stations near Palawan were those of reef-associated species but larvae in deep stations were mostly those of oceanic (pelagic) species. During JOMSRE-SCS IV, 95% of the fish larvae were demersal (bottom-dwelling), especially those collected near North Danger Reef and Jackson Atoll. The deep stations yielded larvae of pelagic (open-sea) fish species. Larval connection to the Philippines could occur, particularly those of the fish families Scombridae and Myctophidae. The two gyres, Luzon Gyre and Nansha Gyre, mentioned earlier, and other current systems could distribute fish larvae to Palawan and Luzon areas. Studies at the University of the Philippines Marine Science Institute show evidence of genetic connectivity of the Spratlys with Palawan and northern Luzon (Juinio-Meñez 2003, Endriga 2003, Ochavillo 2003). Such studies can be fine-tuned in the future to show parentage relations of fish commonly found in the Spratlys and the Philippines. Environmental Disturbances in the Spratlys Recent reclamation activities in the South China Sea, particularly in the Spratlys, “constitute the most rapid rate of permanent loss of coral reef in human history” according to Professor John McManus, as reported by James Borton in Geopolitical Monitor October 30, 2015. Reclamations could kill coral reefs and fish larvae. To date some 1,000 hectares have been reclaimed on atolls causing siltation (Fig. 6). So far, the impact on reef fisheries and marine biodiversity of the West Philippine Sea remains unknown. But it is known that reclamation brings about a plethora of effects and after-effects that it is prudent 9 not to reclaim in sensitive sea areas like the South China Sea, where fish biomass and reef fishery yields have been sliding down. Another threat to the area, particularly to the atolls, resulting from human use, is chemical contamination of lagoons by a variety of metals and organic substances such as that reported in the Johnston Atoll after 70 years of US military activity (Lobel and Kerr 2000). This indicates that atolls tend to retain not only fish and nutrients but also pollutants because of their semi-enclosed structure which minimizes in and out movements of materials. Conclusion and Recommendations There is evidence that the Spratlys is a source of marine propagules for Palawan and Luzon areas, Philippines. This is indicated by the genetic similarity of some species of fish and invertebrates. The water circulation in western Palawan and western Luzon makes it highly probable that fish larvae of the fish families, Scombridae, Myctophidae and others are dispersed to the Philippines especially during the northern winter months. More genetic studies on fish and other marine species are however needed. The atolls in the Spratlys are important in that they retain nutrients needed for marine production. These nutrients which are periodically released to the surrounding open ocean are utilized in primary production by phytoplankton. Atolls also retain in their lagoons adult fish that produce larvae that are being released at times for wider distribution in the South China Sea. Some of these larvae could reach the Philippines through oceanic currents, like the Luzon and Nansha Gyres, especially during the northern winter months. The Philippines benefits from fisheries in the Spratlys. Data in the past clearly showed a substantial value in U.S. dollars of the fisheries in the Spratlys. Minor marine products, such as sea cucumbers, giant clams, etc., although of unknown monetary value, also contribute to the economic life of Filipinos. Coral reefs function to moderate extreme weather conditions and to provide cultural and aesthetic benefits to the country should also be recognized. In the case of the Scarborough Shoal, evidence exists that in the past, fishermen from the 10 Visayas and Mindanao in southern Philippines used to make regular annual journeys northward to fish in the waters of the Shoal. It is recommended that a policy on regional ocean governance be adopted by countries surrounding the South China Sea, including the Philippines under UNCLOS Part IX, which states that “States bordering enclosed and semienclosed seas should cooperate with each other in the exercise of their rights and in the performance of their duties under the Convention.” “There are areas of cooperation for immediate implementation i.e. cooperation in fisheries, the preservation and protection of the marine environment and marine biodiversity, marine scientific research, and safety and security of navigation; or regional ocean governance in general (Encomienda 2015).” Under this policy, 20-30% of the coral reefs in the area and all or part of the atolls could be established as no-take marine reserves and should be protected and managed and regularly monitored to ensure the conservation of marine biological resources in the Spratlys. This is especially urgent because, as stated earlier, fish biomass and abundance in the Spratly reefs surveyed by the JOMSRE expeditions have been shown to have been reduced by about two-thirds in 11 years (1996-2007) (Stockwell et al. 2008). The idea of no-take marine protected areas (MPA) in the Spratlys was suggested by McManus and Meñez in 1997 and by Philippine and Vietnamese scientists meeting in Ha Long Bay in 2007. As discussed above, there is good reason to be concerned about fisheries because of the recent findings that abundance and biomass of coral reef fishes have gone down (Stockwell et al. 2008) and catches from muro-ami and paaling fishing gears used on coral reefs have been reduced (Abesamis 2003). No-take marine protected areas in the Philippines have been shown to build up the abundance and biomass of coral reef fishes in no-take MPAs and to export adult fish and larvae to fishing areas for sustainable fishing (Alcala and Russ 1990, 2006). Currently, there exists a special kind of MPA that is gaining favour among policymakers who are interested in exploring alternatives that will temporarily suspend territorial claims in disputed areas, according to James Borton who 11 wrote the article “Geopolitical Monitor October 30, 2015” published by Geopolitical Monitor.com. This is the concept of Peace Parks defined by The International Union for Conservation of Nature (IUCN) as “transboundary protected areas that are formally dedicated to the protection and maintenance of biological diversity, and of natural and associated cultural resources, and to the promotion of peace and cooperation.” Borton cites five examples, four of which deal with the marine environment, as follows: 1. The Waterton-Glacier International Peace Park created in 1932 between Canada and the United States. This agreement led to collaborative research, ecotourism, and increased partnerships. 2. The Red Sea Peace Park established in 1994 between Israel and Jordan in the northern Gulf of Aqaba. This park led to normalization of relations and fostered coordination of marine biology research on coral reefs and marine conservation. The two nations and former enemies agreed to a peace treaty after many years of belligerency (material from NOAA). 3. The Torres Strait Treaty signed in 1978 between Australia and Papua New Guinea resolved, after a decade of negotiation, numerous political, legal and economic issues. 4. The Antarctic Treaty forged in 1959 is an excellent example of a multilateral peace park and solidified collaborative scientific research and conservation practices. 5. The Joint Oceanographic and Marine Scientific Research Expedition in the South China Sea signed in 1994 and carried out by the Philippines and Vietnam in the Spratlys in 1996-2007 resulted in fruitful research collaboration and promoted friendly relations among Philippine and Vietnam scientists. 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Collected Articles from Journal of Geophysical Research 111. C11S01. Washington D.C 200029: AGU. 16 Fig. 1. (Above) Chart of South China Sea (Wang et al. 2006); (Below) Ocean currents during winter months (Zheng et al. 2006). Note that the Luzon Gyre (LG) and the Nansha Gyre circulate in the counterclockwise direction bringing marine propagules (larvae) from the South China Sea to the Philippines. 17 Fig. 2. Reef systems in the Spratly Archipelago explored by JOMSRE-SCS Expeditions in 19962007, including Scarborough Shoal. Number(s) in parentheses indicate expedition number. 18 Fig. 3. Coral reefs with fish in the Spratlys. Hard coral cover was 22.85% on the average and soft coral cover was 1.93% with some areas like above close to 100% coral cover. (Photos by B. Stockwell). 19 NORTH DANGER REEF A B Fig. 4. Charts of A. North Danger Reef; B. Jackson Atoll (After Lam et al. 2008). 20 Fig. 5. Decreasing Catch Rates of Paaling and Muro-ami in the Spratlys (After Abesamis 2003). 21 A A D B Fig. 6. Reclaimed atolls showing occurrence of siltation. A. Fiery Cross Reef (www.bbc.com); B. Mischief Reef (www.nytimes.com). E 22