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The Threat of Maritime Piracy in the Malacca and Singapore Straits

Introduction
Piracy worldwide Maritime piracy in recent years had shown a disturbing trend worldwide (IMO, 2000; ICC, 2003d). According to Abhyankar (2001), Deputy Director of ICC-IMB (International Chamber of Commerce-International Maritime Bureau), piracy figures peaked at 469 incidents worldwide in year 2000, almost a 450% increase of 1991 figures. The year 2003 alone saw 103 piracy attacks in the first quarter, equivalent to the figures for the year 1993 (ICC, 2003c). The statistics below highlights the upsurge of piracy incidents worldwide during the period of 1991 to 2000. Countries Most Prone To Attacks in Year 2000 The following seven areas shared over two thirds of the total number of incidents, i.e., 331 from a total of 469 reported attacks for the period. Source: Abhyankar (2001, p. 11) Piracy in Southeast Asia Piracy attacks represents a clear and present danger to shipping worldwide as it had increased in frequency, more organised and becoming more audacious (Hunter, 1999; IMO, 2000; MacKinnon, 2000). Malacca Straits and Singapore Straits, among the busiest waterways in the world (IMO, 2000), are regarded to be one of the riskiest places for seafarers (Hunter 1999; IMO, 2000; Abhyankar, 2001). Violent piracy attacks that had occurred in South East Asian waters in recent years involved vessels such as the M V Alondra Rainbow in October 1999 and M V Cheung Son in November 1998 (IMO, 2000; MacKinnon, 2000; Abhyankar, 2001). Recently pirates attempted to board a Taiwanese trawler, Dong Yih, by firing automatic weapons fire at it for almost two hours in the Malacca Straits in broad daylight (TNP, 2003). These underscore the continuing threat to international trade particularly to littoral states such as Malaysia, Indonesia and Singapore, when vessels transiting busy waterways were subjected to piracy attacks (Jacobs, 2003). Coordinated naval patrols by Indonesian and Singapore had dramatically reduced cases of armed sea robbery and piratical attacks in the Singapore Straits since 1992 (Abhyankar, 2001; RSN, 2002; Jacobs, 2003). However, statistics collated by ICC (2003c, 2003d, 2003e, 2003f) showed that an increased frequency in piracy attacks at Malacca Straits and sporadic attacks at Singapore Straits highlighted that Singapore and her neighbouring authorities cannot take the problem of piracy lightly. The next sections will provide a holistic appraisal of the piracy problem and its effects in Malacca and Singapore Strait, and measures that can be undertaken by the Malaysia, Indonesia and Singapore authorities to reduce piracy.

Literature Review

Piracy Definitions Piracy was more popularly known as acts of robbery at sea, that might result in injuries or even death, and committed by armed bandits using vessels marked with the infamous skull and bones, Jolly Roger flag (Hunter. 1999; IMO, 2000). However the IMO (International Maritime Organisation), which is the world body for maritime regulations, navigation safety and shipping standards (IMO, 2003a), defined piracy under Article 101 UNCLOS (United Nations Convention On The Law Of The Sea) 1982 as follows: (a) any illegal acts of violence or detention, or any act of depredation, committed for private ends by the crew or the passengers of a private ship or a private aircraft, and directed: (i) on the high seas, against another ship or aircraft, or against persons or property on board such ship or aircraft; (ii) against a ship, aircraft, persons or property in a place outside the jurisdiction of any State; (b) any act of voluntary participation in the operation of a ship or an aircraft with the knowledge of facts making it a pirate ship or aircraft; (c) any act of inciting or of intentionally facilitating an act as described in subparagraph (a) or (b) Source: IMO (2003b, p.1) However, Abhyankar (2001) stressed that the current definition of piracy is archaic in the current context as most piratical attacks happened within a countrys territorial waters whilst the vessel was underway or anchored. IMO (2000) reported that 86.5% of piracy related incidents occurred within territorial waters. In addition, piracy definition under UNCLOS 1982 covered acts committed for private gains and excluded all other acts, which were for political ends (Abhyankar 2001; Menefee, 2001). Piratical attacks that occurred in areas other than the high seas would be classified as armed robbery at sea, and would be subject to local laws of the particular country (MacKinnon, 2000; Abhyankar 2001; Valencia, 2001). ICC, which had always been the leading agency in monitoring and broadcasting piracy incidents and providing assistance in the investigation and recovery of hijacked vessels, had defined piracy as: An act of boarding or attempting to board any ship with the intent to commit theft or any other crime and with the intent or capability to use force in the furtherance of that act(Abhyankar, 2001, Menefee, 2001). The purpose of the above definition was a deliberate attempt by the ICC to regard all acts of violence and theft against the seafaring community at sea as piracy per se. This would force littoral states to take notice of this alarming problem and take tougher measures to combat piracy (Abhyankar, 2001; Menefee, 2001). Looking at the local context, piracy as defined under Penal Code, Chapter 224 of the Statutes of The Republic of Singapore states that:

Piracy by law of nations. Cf. 12 and 13 Victoria c. 96 (Admiralty Offences (Colonial) Act 1849). 130B. (1) A person commits piracy who does any act that, by the law of nations, is piracy. (2) Whoever commits piracy shall be punished with imprisonment for life and with caning with not less than 12 strokes, but if while committing or attempting to commit piracy he murders or attempts to murder another person or does any act that is likely to endanger the life of another person he shall be punished with death. Act 35/93. Piratical acts. 130C. Whoever, while in or out of Singapore (a) Steals a Singapore ship; (b) Steals or without lawful authority throws overboard, damages or destroys anything that is part of the cargo, supplies or fittings in a Singapore ship; (c) Does or attempts to do a mutinous act on a Singapore ship; or (d) Counsels or procures a person to do anything mentioned in paragraph (a), (b) or (c), Shall be punished with imprisonment for a term not exceeding 10 years and shall be liable to caning. Act 35/93. Section 130B allowed Singapore jurisdiction to try offenders who commit piracy as defined under the law of nations, which is on board any ships in the high seas as defined under Article 101 of the UNCLOS 1982. However, section 130C showed that piratical acts that occurred on board non-Singapore registered vessel within Singapore territorial waters, would instead be defined under other legal definitions such as, abetment, robbery, theft in dwelling, vandalism or mischief under local laws attracting less punitive punishments. Why the Increase in Piracy Statistics? The end of the Cold War in the early 90s had progressively reduced the size of the former Soviet Navy. This in turn was reciprocated with a worldwide reduction of United States and United Kingdom naval resources, which was originally deployed to counter the Soviet threat (Sakhuja, undated). With the reduced numbers in naval forces worldwide, the deterrent effect on piracy activities was reduced considerably (Abhyankar, 2001). Increased automation levels on board merchant shipping, resulted in the employment of fewer crewmembers that can be deployed for anti piracy watches (IMO, 2000). With fewer crewmembers it would be easier for pirates to gain control of a ship (Abhyankar, 2001).

Cross border issues were also likely to contribute with this increasing trend. Valencia, (2001) cited that pirates knew of the limitations of the right of hot pursuit by the states enforcement vessels under Article 111 of the UNCLOS 1982 and the importance of preserving the primacy of national sovereignty by states (Stocker, 1998). Piracy were committed with impunity in waters of another state and the pirates could easily made good their escape back into their own countries waters (Abhyankar, 2001; Valencia, 2001; Sakhuja, undated). Indonesian territorial waters, widely regarded as the worst piracy infested area, could be due to Indonesias unstable economic and geo-political situation, such as the 1997 financial crisis and compounded by the need to fight separatist rebellion and sectarian violence in provinces such as Aceh, Irian Jaya, Kalimantan and the Malukus. As such Indonesian maritime forces are not properly allocated enough resources to combat piracy activities (Hellberg, 1999; Abhyankar, 2001; Valencia 2001).

Piracy in the Malacca and Singapore Straits


Vessels at Risk Vessels passing through the Malacca and Singapore Straits had to rely on very precise navigation due to the restricted waters and had to make way at reduced speeds therefore increasing the risk of a possible attack (IMO, 2000; Abhyankar, 2001). Typically, the pirates, armed with knives or handguns and numbering between two to five persons, would execute their attacks using high-speed boats, boarded the rear end of the vessel using ropes and grapnel hooks undetected whilst the vessel is underway during hours of darkness (Hunter, 1999; IMO, 2000; Abhyankar, 2001). Once on board the vessel, they would head for the shipmasters cabin and robbed of its contents of valuables and cash (IMO, 2000; Abhyankar, 2001). The pirates used threats of violence or might use deadly force to commit their robbery (Hunter, 1999). Current Trends However, recent trends showed that attacks were becoming more organised, well executed and the use of brute force was not uncommon (Hunter, 1999; IMO, 2000; Abhyankar, 2001; TNP, 2003). ICC (2003e) recently reported that, small oil tankers plying through northern and southern approaches to the Malacca Straits were becoming the targets of pirate gangs. These pirate gangs, armed with assault rifles and clad in military camouflage uniforms, numbering 10 persons or more, would use salvage tugs or fishing vessels as their attack platform. They would then board the target vessels by force, firing their automatic weapons at the vessels that are underway. The cargo of oil was then siphoned off whilst the crew were tied and gagged or kept locked in a cabin. The crew themselves could be taken hostage and held for ransom to be paid by the ship owners (ICC, 2003d). The vessels might even be seized and subsequently repainted, renamed and sold off to willing third party buyers locally or overseas, indicating that well-organised trans-national criminal elements were behind these well-executed hijackings (Hunter, 1999; MacKinnon, 2000; Abhyankar, 2001; ICC 2002). These seized vessels if not sold, were utilised as phantom ships by the syndicates, disguised with fake registration and hired by unsuspecting companies to ship their cargo, which would be diverted fraudulently and sold off to another unsuspecting buyer. That means the syndicates gained by the hiring fees of the first party and selling off the fraudulently obtained cargo to the

third party. The cycle of illegal activities would be repeated again by the same modus operandi (MacKinnon, 2000; Abhyankar, 2001). There were a few attempted boarding cases in the month of July and August 2003 in the waters off Bintan coast. As a result, ICC had to renew fresh warnings to vessels to maintain high vigilance when transiting through the Singapore Straits (ICC, 2003f). Likely Perpetrators This year, GAM (Gerakan Aceh Merdeka) rebels were suspected of being complicit in recent piracy attacks (ICC, 2003e). Some other pirate gangs were not opportunists or unorganized as initially thought (Abhyankar, 2001). They were well financed, using sophisticated monitoring and communications equipment, selecting the target vessel based on the value of cargo it was carrying, carrying out their attack with absolute precision. These indicated the possibility of pirate gangs colluding with organised criminal elements, rogue shipping companies and corrupted government officials to be quite plausible (Hunter, 1999; IMO 2000; MacKinnon, 2000; Abhyankar, 2001)

Analysis of Piracy Consequences in the Malacca and Singapore Straits


Direct Consequences Piracys immediate consequences would be huge financial losses to the shipping industry for the loss of shipping cargo and vessels. On the individual level, violent piracy attacks were likely to result in loss of personal belongings, serious or fatal injuries to innocent crew and passengers on board vessels. Indirect Consequences Merchant shipping making use of the Malacca and Singapore Straits might see an increase in operating costs. When cargo were stolen, ships hijacked, lives lost or serious injuries were involved, insurance companies would have to pay huge insurance compensations, forcing insurance companies to increase their premiums on the shipping industry. Shipping industry unions might also demand higher pay for risk involved and more crew might be needed to improve anti-piracy security. Most of Japans imported crude oil is currently transported via the Malacca and Singapore Straits (Hunter, 1999; Ong, 2002). If Japans national economy was affected; it could result in an adverse domino effect on Southeast Asias economy. Costs of goods and services might go up. Potential Maritime and Ecological Disaster Large vessels navigating through Malacca and Singapore Straits via the narrow two-way traffic separation lanes require precise navigation with minimum margin of error (IMO, 2000; Abhyankar, 2001). If the entire vessels crew were killed or immobilised during a piracy attack, she would be left unmanned. This might result in maritime accidents, loss of lives and major oil spills or even worse release of toxic chemicals, which could be disastrous to the coastal environment and marine life. Effect on Malaysias and Singapores Economy

Large vessels, if accidentally sunk in the Malacca or Singapore Straits due to a piracy attack, might cause the whole Straits to be closed down for weeks or months, affecting passage of merchant shipping. Shippers would have to take a longer route to bypass Malacca Straits and Singapore Straits, thus increasing costs. This can also happen if shipping companies start to avoid the risk of piracy attack at the Malacca and Singapore Straits and used other routes to countries like Japan and South Korea to transport the raw materials. Vessels calling at Malaysian and Singapore ports situated in the Malacca and Singapore Straits would be drastically reduced, resulting in Malaysias and Singapores economy to suffer badly. Criminal-Terrorism Link In light of the attacks on USS Cole, a United States navy destroyer and a French registered crude oil carrier Limburg, by suicide terrorists using boats laden with explosives in the year 2000 and 2002 respectively, the maritime security situation picture had changed (ICC, 2003b). Littoral governments realised the potential of piracy and terrorist elements collaborating together for mutual gain (Ong, 2002). Al-Qaeda, which was responsible for the September 11, 2001 attacks were believed to be acquiring extensive maritime attack capabilities (Ong, 2002). JI (Jemaah Islamiah), which is based in Indonesia, with its financial backing from its ally, alQaeda, might enlist the expertise of willing Indonesian piracy gangs to hijack vessels. These hijacked vessels, probably laden with explosives could then be used to ram United States Navy vessels plying along the narrowest point of Malacca and Singapore Straits, where evasive maneuver would be impossible to avoid a catastrophic disaster. Another plausible scenario was that terrorist elements would acquire the relevant boarding skills as mentioned by Abhyankar (2001) learned from piracy elements to hijack vessels and scuttle them in the Malacca and Singapore Straits, causing massive environmental damage and harming Malaysias and Singapores economy. In fact piracy could be akin to maritime terrorism as both operated in the same continuum, and would result in adverse effects on a countrys economy and national security interests (Ong, 2002).

Combating Piracy In The Malacca And Singapore Straits


Current Anti-Piracy Efforts Jacobs (2003) and Valencia (2001) mentioned that navy and coast guard cooperation between Indonesia and Singapore had dramatically reduced piracy in the Singapore Straits. There were calls for a regional or an international maritime peacekeeping force manned by countries such as Japan, Singapore, Malaysia and Indonesia to patrol the Malacca and Singapore Straits, under the auspices of The United Nations. However Malaysia and Indonesia opposed the idea as it would somewhat encroach upon their sovereignty and pride (Valencia, 2001). Although Hunter (1999) and Sukhuja (undated) stated that increased naval and coast guard presence could help reduce piracy, Stocker (1998) cautioned that gunboat diplomacy, had its limitations in its interventionary role in combating piracy in the littoral environment. Legal Impediments Piracy as defined within the high seas and armed robbery in territorial waters, have similar or the same similar modus operandi (Abhyankar, 2001), might result to a similar or the same degree of violence, loss and level of victimisation to the victims (Menefee, 2001). Although the piracy definition used by ICC negated the geographic limitations when investigating acts of

piracy, in reality, it would be difficult to apply it for enforcement and prosecution by littoral governments (Valencia, 2001). For example, how do Singapores authorities prosecute Indonesians committing piracy on board a Singapore registered vessel manned by Singaporeans in Indonesian territorial waters? Is it Singapore or Indonesian authorities? Another possible scenario would be, who has the rights of jurisdiction over Indonesian citizens committing piracy on board a Singapore owned vessel manned by Filipinos in the high seas, where the Malaysian Navy stops the pirate vessel? Is it the Malaysian, Singapore, Filipino or Indonesian authorities that have exclusive rights to prosecute the perpetrators? As different countries have different local definitions of piracy incidents and its punishments, it is best that piracy at any parts of the sea in the world be regarded as crime of international jurisdiction; that, as hostis humanis generis, enemies of all mankind (Menefee, 2001, p. 1) and be accorded a standardised punishment by an international tribunal. If piracy affects the common national interests of Indonesia, Malaysia and Singapore, that is the economy, environment and the safety of the wider populace, what can be suggested are the countries must be willing to cooperate and compromise in terms of enforcement and prosecution jurisdiction (Valencia, 2001). Forming a tripartite tribunal to indict piracy perpetrators and likewise maritime terrorism based on mutually agreed principles and points of law would expedite the conviction of alleged perpetrators. However to implement the above ideas may be a long drawn process as there are so many legal obstacles and complexities, national pride and sovereignty issues to settle first (Menefee, 2001).

Conclusion
At the present moment, it would be best that the shipping industry undertake risk reduction and practical reactive measures (IMO. 2000: Abhyankar, 2001). The best measure to circumvent the piracy problem is to prevent it from happening in the first place. Risk reduction should be seen as a primary form of intervention. Abyhankar (2001) cited that vigilance and anti piracy watches on board vessels transiting through high-risk areas would be the most viable option. In the event an attempted boarding by pirates is detected, reactive measures such as sounding the alarm, reporting the situation to authorities and using high pressure water hoses at the pirates would be effective to deter the pirates. Another layer of defence as a secondary form of intervention would be to install anti-boarding devices such as Secure-Ship, an electric fence surrounding the accessible areas of a ship, providing a non-lethal 9000 volts of electric shock to would be boarders (ICC, 2003a). In the event boarding and hijacking is successful, recovery of ships installed with a worldwide satellite monitoring device called ShipLoc could be expedited by law enforcement authorities (ICC, 2003a). Without doubt, piracy in the Malacca and Singapore Straits would remain a lucrative criminal activity because of the high gains involved, the presence of many uninhabited islands in the Indonesian archipelago for the criminals to hide and the lack of enforcement or resources by countries especially in Indonesia. Piracy should be battled in a holistic manner with inter-government enforcement, judiciary cooperation and the will to commit enough resources to patrol problem areas and of course risk reduction on the part of the maritime industry.

References

Abhyankar, J. (2001), Piracy - A Growing Menace, Paper Presented at the Conference "Combating Piracy and Armed Robbery at Sea "- Charting The Future in Asia Pacific Waters, Bangkok 24-25 March 2001, 31 pages (Word Document) URL: http://www.glocomnet.or.jp/okazaki-inst/doc/0319Abhyankar.DOC (Accessed on September 10, 2003) Hunter, T. B. (1999), The Growing Threat of Modern Piracy, United States Naval Institute, Proceedings, Annapolis: Jul 1999, Vol. 125, Issue 7, pp.72-74, (Web Document). ProQuest URL: http://gateway.library.qut.edu.au:2052/pqdweb? index=3&did=000000042824464&SrchMode=1&sid=11&Fmt=3&VInst=PROD&VType=PQ D&RQT=309&VName=PQD&TS=1063996042&clientId=14394 (Accessed on September 15, 2003) ICC (2000), East Asian governments must clamp down on piracy together, International Chamber of Commerce News Archives 20th March 2000, 2 pages (Web Document) URL:http://www.iccwbo.org/ccs/news_archives/2000/piracy_east_asia.asp (Accessed on September 10, 2003) ICC (2002), Organized crime takes to the high seas, ICC piracy report finds, International Chamber of Commerce News Archives 4th February 2002,2 pages (Web Document) URL:http://www.iccwbo.org/home/news_archives/2002/piracy_report.asp (Accessed on September 10, 2003) ICC (2003a), Electric Fence For Ships Steps Up Fight Against Pirates, International Chamber of Commerce News Archives 23rd January 2003, 2 Pages (Web Document) URL: http://www.iccwbo.org/ccs/news_archives/2003/electric_fence.asp (Accessed on September 15, 2003) ICC (2003b), High seas terrorism alert in piracy report, International Chamber of Commerce News Archives 29th January 2003, 3 pages (Web Document) URL: http://www.iccwbo.org/home/news_archives/2003/stories/piracy%20_report_2002.asp (Accessed on September 10, 2003) ICC (2003c), Pirate attacks have tripled in a decade, ICC report finds, International Chamber of Commerce News Archives 1st May 2003, 2 pages (Web Document) URL: http://www.iccwbo.org/home/news_archives/2003/stories/piracy-quarter-1.asp (Accessed on September 15, 2003)

ICC (2003d), Piracy soars as violence against seafarers intensifies, International Chamber of Commerce News Archives 24th July 2003, 3 pages (Web Document) URL: http://www.iccwbo.org/ccs/news_archives/2003/piracy_report_second_quarter.asp (Accessed on September 10, 2003) ICC (2003e), New brand of piracy threatens oil tankers in Malacca Straits, International Chamber of Commerce News Archives 2nd September 2003, 2 pages (Web Document) URL: http://www.iccwbo.org/ccs/news_archives/2003/piracy_ms.asp (Accessed on September 10, 2003) ICC (2003f), Weekly Piracy Report, International Chamber of Commerce Weekly Piracy Report 9-15 September 2003, 3 pages (Web Document) URL: http://www.iccwbo.org/ccs/ICC_piracy/weekly_piracy_report.asp (Accessed on September 21, 2003) IMO (2000), Piracy and Armed Robbery at Sea, Focus on IMO, January 2000, 8 pages (PDF Document). URL: http://www.imo.org/includes/blast_bindoc.asp?doc_id=433&format=PDF (Accessed on September 9, 2003) IMO (2003a), About IMO, International Maritime Organisation Home Website, 4 pages (Web Document) URL: http://www.imo.org/home.asp (Accessed on September 10, 2003) IMO (2003b), Piracy and Armed Robbery Against Ships, International Maritime Organisation Home Website, 2 pages (Web Document) URL: http://www.imo.org/home.asp (Accessed on September 10, 2003) Jacobs, K. (2003), Asian Naval Programmes 2003, Naval Forces, Austral-Asian Focus 2003, pp. 43-52, (PDF Document). Proquest URL: http://gateway.library.qut.edu.au:2052/pqdweb? index=3&did=000000354300001&SrchMode=1&sid=12&Fmt=4&VInst=PROD&VType=PQ D&RQT=309&VName=PQD&TS=1063996148&clientId=14394 (Accessed on September 15, 2003) MacKinnon, D. (2000), Transnational Dimensions Of Maritime Crime, Paper presented at conference organised by the Australian Institute of Criminology in association with the

Australian Federal Police and the Australian Customs Service, Rydges Lakeside, Canberra, 9 10 March 2000, 13 pages (PDF Document) URL: http://www.aic.gov.au/conferences/transnational/mackinnon.pdf (Accessed on September 15, 2003) Menefee, S. M. (2001), Crossing The Line?: Maritime Violence, Piracy, Definitions And International Law (1st Draft) Paper Presented at the Conference "Combating Piracy and Armed Robbery at Sea "- Charting The Future in Asia Pacific Waters, Bangkok 24-25 March 2001, 12 pages (Word Document). URL:http://www.glocomnet.or.jp/okazaki-inst/doc/0324MenefeeCrossing.doc (Accessed on September 10, 2003) Ong, G. G. (2002), Pre-empting maritime terrorism in Southeast Asia, Viewpoints, Institute of South East Asian Studies, 4 pages (PDF Document) URL: http://www.iseas.edu.sg/viewpoint/ggonov02.pdf (Accessed on September 15, 2003) Penal Code (1985), , Sec 130B and Sec 130C, Chapter 224, The Statutes of the Republic of Singapore, Revised Edition 1985, Singapore: Government Printers. Sakhuja, V. (undated), Maritime Order and Piracy, IDSA Research Fellow, 12 pages (Web Document). URL: http://www.idsa-india.org/an-aug-500.html (Accessed on September 10, 2003) Stocker, J. (1998), Nonintervention: Limited operations in the littoral environment, Naval War College Review. Washington: Autumn 1999, Vol. 51, Issue 4, pp. 42-62, (PDF Document). ProQuest URL: http://gateway.library.qut.edu.au:2052/pqdweb? index=34&did=000000034621697&SrchMode=1&sid=6&Fmt=6&VInst=PROD&VType=PQ D&RQT=309&VName=PQD&TS=1063995746&clientId=14394 (Accessed on September 15, 2003) RSN (2002), Celebrating Ten Successful Years of Partnership - IndoSin Coordinated Patrol (ISCP), July Issue of Navy News Online, (Web Document). URL: http://www.mindef.gov.sg/navy/navynews/07_jul/020707.html (Accessed on September 10, 2003) TNP (2003), Latest High Seas Drama off Aceh- Pirates fire 200 shots at Taiwan Ship, The Electric New Paper August 13, 2003, 3 pages (Web Document)

URL: http://newpaper.asia1.com.sg/top/story/0,4136,32776-1060790340,00.html (Accessed on September 10, 2003)

Valencia, M. J. (2001), International Co-Operation In Anti-Piracy Efforts In Asia: Some Considerations (2nd Draft), Paper Presented at the Conference "Combating Piracy and Armed Robbery at Sea "- Charting The Future in Asia Pacific Waters, Bangkok 24-25 March 2001, 14 pages (Word Document). URL: http://www.glocomnet.or.jp/okazaki-inst/doc/0313ValenciaPaper.doc (Accessed on 10th September 2003)

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