Law of the Sea and Migration: Authority and Responsibility of Stakeholders, Rescue at Sea and Stowaways Vita Onwuasoanya Associate Ocean Affairs and Law.

Law of the Sea and Migration: Authority Law of the Sea and Migration: Authority and Responsibility of Stakeholders, and Responsibility of Stakeholders,

Rescue at Sea and StowawaysRescue at Sea and Stowaways

Vita OnwuasoanyaVita OnwuasoanyaAssociate Ocean Affairs and Law of the Sea OfficerAssociate Ocean Affairs and Law of the Sea Officer

DIVISION FOR OCEAN AFFAIRS AND THE LAW OF THE SEADIVISION FOR OCEAN AFFAIRS AND THE LAW OF THE SEAOffice of Legal Affairs, United Nations Office of Legal Affairs, United Nations

Mixed migrationMixed migration

Mixed migrationMixed migrationMovements of Movements of

people increasingly people increasingly mixed: asylum mixed: asylum seekers & refugees; seekers & refugees; trafficked/ smuggled trafficked/ smuggled persons; migrantspersons; migrants

Similar routesSimilar routesSimilar modes of Similar modes of

transporttransport

Migration Flows

Stakeholders

Flag States

States of Origin

Transit States

States of Destination or disembarkation

Migration by seaMigration by seaOutline of PresentationOutline of Presentation

Law of the seaLaw of the sea

Rescue of persons in distress at seaRescue of persons in distress at sea

Trafficking and smuggling by seaTrafficking and smuggling by sea

Interception/Interdiction at seaInterception/Interdiction at sea

StowawaysStowaways

Law of the seaLaw of the sea

1982 United Nations Convention on the Law of the 1982 United Nations Convention on the Law of the Sea (UNCLOS)Sea (UNCLOS)

Maritime zones under UNCLOSMaritime zones under UNCLOS

Jurisdiction and duties of flag StatesJurisdiction and duties of flag States

Overview of UNCLOSOverview of UNCLOS

United Nations Convention on the Law of the Sea , United Nations Convention on the Law of the Sea , adopted in 1982. Entered into force in 1994adopted in 1982. Entered into force in 1994

““Constitution for the oceans” - legal regime Constitution for the oceans” - legal regime governing all ocean spacegoverning all ocean space

Balance struck in UNCLOS between competing Balance struck in UNCLOS between competing interests regarding the uses of the oceans and interests regarding the uses of the oceans and resources of the oceansresources of the oceans

Limits of maritime zonesLimits of maritime zones

Territorial Sea Territorial Sea

Sovereignty of a coastal State extends beyond its Sovereignty of a coastal State extends beyond its land territory and internal waters to an adjacent belt land territory and internal waters to an adjacent belt of sea: the territorial sea. of sea: the territorial sea.

Breadth: up to 12 nautical miles, measured from the Breadth: up to 12 nautical miles, measured from the baselines.baselines.

Entitlement: inherent part of the territory of a coastal Entitlement: inherent part of the territory of a coastal State- State- Legislative and enforcement jurisdictionLegislative and enforcement jurisdiction

Scope: sea; air space; seabed; and subsoil.Scope: sea; air space; seabed; and subsoil.

Innocent passage through territorial seaInnocent passage through territorial sea

Foreign ships have the right of innocent passage Foreign ships have the right of innocent passage through the territorial sea of a coastal State through the territorial sea of a coastal State (article 19):(article 19):

Continuous and expeditious passage through Continuous and expeditious passage through territorial sea or to/from internal watersterritorial sea or to/from internal waters

Subject to certain laws of coastal State (eg Subject to certain laws of coastal State (eg prevention of infringement of customs, fiscal, prevention of infringement of customs, fiscal, immigrationimmigration or sanitary laws) or sanitary laws)

Innocent passage through territorial seaInnocent passage through territorial sea(cont.)(cont.)

Passage of a foreign ship is innocent so long as it is not Passage of a foreign ship is innocent so long as it is not prejudicial to the good order, or security of the coastal prejudicial to the good order, or security of the coastal State (article 19)State (article 19)

Passage considered to be prejudicial if foreign ship Passage considered to be prejudicial if foreign ship engages in certain activities including:engages in certain activities including: the loading or unloading of any commodity, currency the loading or unloading of any commodity, currency

or or personperson contrary to the customs, fiscal, contrary to the customs, fiscal, immigration immigration or sanitary laws or regulations of the coastal Stateor sanitary laws or regulations of the coastal State

Coastal State has right to take necessary steps in its Coastal State has right to take necessary steps in its territorial sea to prevent passage which is not innocent territorial sea to prevent passage which is not innocent (article 25)(article 25)

Contiguous ZoneContiguous Zone

Maritime zone contiguous and seaward of the territorial Maritime zone contiguous and seaward of the territorial sea, from the outer limit of the territorial sea to up to 24 sea, from the outer limit of the territorial sea to up to 24 nautical miles, measured from the baselines.nautical miles, measured from the baselines.

Entitlement: the coastal State may proclaim it.Entitlement: the coastal State may proclaim it.

The coastal State may exercise the control necessary to The coastal State may exercise the control necessary to prevent and punish infringement of prevent and punish infringement of customs, fiscal, customs, fiscal, immigrationimmigration or sanitary laws within the territory or or sanitary laws within the territory or territorial sea (article 33)territorial sea (article 33)

Exclusive Economic Zone (EEZ)Exclusive Economic Zone (EEZ)

The exclusive economic zone (EEZ) is an area beyond The exclusive economic zone (EEZ) is an area beyond and adjacent to the territorial sea (articles 55-58).and adjacent to the territorial sea (articles 55-58).

Breadth: from the outer limit of the territorial sea to up to Breadth: from the outer limit of the territorial sea to up to 200 nautical miles, measured from the baselines.200 nautical miles, measured from the baselines.

Entitlement: the coastal State may proclaim it.Entitlement: the coastal State may proclaim it.

Scope: sea; seabed; and subsoil.Scope: sea; seabed; and subsoil.

EEZ (cont.)EEZ (cont.)

A coastal State has certain sovereign rights, including:A coastal State has certain sovereign rights, including:

Exploring and exploiting, conserving and managing Exploring and exploiting, conserving and managing natural resources, whether living or non-livingnatural resources, whether living or non-living

A coastal State has exclusive jurisdiction, including A coastal State has exclusive jurisdiction, including regarding regarding the establishment and use of artificial the establishment and use of artificial islands, installations and structures over which it islands, installations and structures over which it may exercise jurisdiction including may exercise jurisdiction including with respect to with respect to customs, fiscal, health, safety and customs, fiscal, health, safety and immigrationimmigration laws laws

High seasHigh seas

High seas: parts of the sea which are not included in High seas: parts of the sea which are not included in the exclusive economic zone, in the territorial sea or in the exclusive economic zone, in the territorial sea or in the internal waters of a State, or in the archipelagic the internal waters of a State, or in the archipelagic waters of an archipelagic Statewaters of an archipelagic State

High seas are not subject to the jurisdiction of any StateHigh seas are not subject to the jurisdiction of any State

Open to all States, whether coastal or land-lockedOpen to all States, whether coastal or land-locked

High seas are reserved for peaceful purposesHigh seas are reserved for peaceful purposes

Freedoms of high seas include navigation (article 87)Freedoms of high seas include navigation (article 87)

Flag State jurisdictionFlag State jurisdiction

Every State has the right to sail ships flying its flag & Every State has the right to sail ships flying its flag & ships have the nationality of the flag flown (article 91)ships have the nationality of the flag flown (article 91)

Flag State has exclusive jurisdiction over ships on the Flag State has exclusive jurisdiction over ships on the high seas (article 92). Exceptions under UNCLOS high seas (article 92). Exceptions under UNCLOS include:include: PiracyPiracy Unauthorized broadcastingUnauthorized broadcasting Slave tradingSlave trading Illicit drug traffickingIllicit drug trafficking Ships without nationalityShips without nationality Ships hiding real nationalityShips hiding real nationality

Flag State Jurisdiction (cont.)Flag State Jurisdiction (cont.)

Another exception to exclusive flag State jurisdiction - Another exception to exclusive flag State jurisdiction - right of hot pursuit (article 111):right of hot pursuit (article 111): Violations by foreign ship of a coastal State’s laws in Violations by foreign ship of a coastal State’s laws in

internal waters or the territorial sea. Right also applies internal waters or the territorial sea. Right also applies in other zones in certain cases.in other zones in certain cases.

Exercised by warships or military aircraftExercised by warships or military aircraft Pursuit must begin in internal waters, territorial sea, Pursuit must begin in internal waters, territorial sea,

the contiguous zone, EEZthe contiguous zone, EEZ Must give signal to stop Must give signal to stop Pursuit must be continuousPursuit must be continuous Cease pursuit if pursued ship enters territorial sea of Cease pursuit if pursued ship enters territorial sea of

another coastal Stateanother coastal State

Duties of Flag StatesDuties of Flag States

Duties of the flag State (article 94): Duties of the flag State (article 94): Exercise effective control over ships flying its flagExercise effective control over ships flying its flagMeasures to ensure safety at seaMeasures to ensure safety at sea Measures must conform with generally accepted Measures must conform with generally accepted

international regulations (eg IMO Conventions)international regulations (eg IMO Conventions) The operation of substandard ships is not permitted The operation of substandard ships is not permitted Ensure that their vessels comply with international law Ensure that their vessels comply with international law

and not be used for illicit purposesand not be used for illicit purposes

Rescue of Persons in Distress at SeaRescue of Persons in Distress at SeaOverviewOverview

Legal regime relating to rescue of persons in Legal regime relating to rescue of persons in distressdistressObligation to assist and rescue persons in Obligation to assist and rescue persons in

distressdistressObligations in respect of disembarkation and Obligations in respect of disembarkation and

delivery to a place of safetydelivery to a place of safety

Rescue of persons in distress at sea Rescue of persons in distress at sea Legal RegimeLegal Regime

Obligation of masters of ships to render assistance to Obligation of masters of ships to render assistance to persons in distress at sea is long-established maritime persons in distress at sea is long-established maritime tradition and obligationtradition and obligation

A number of Conventions contain obligations to provide A number of Conventions contain obligations to provide assistance and to rescue:assistance and to rescue: obligations of masters of ships, flag States, and obligations of masters of ships, flag States, and

coastal Statescoastal States

Focus on UNCLOS and IMO Conventions and Focus on UNCLOS and IMO Conventions and instruments instruments

Duty to Render Assistance under Article 98 of Duty to Render Assistance under Article 98 of UNCLOSUNCLOS

Obligation of a master of a ship to :Obligation of a master of a ship to : render assistance to any person found at sea in render assistance to any person found at sea in

danger of being lostdanger of being lost proceed with all possible speed to the rescue of proceed with all possible speed to the rescue of

persons in distress, if informed of their need of persons in distress, if informed of their need of assistance, in so far as such action may reasonably assistance, in so far as such action may reasonably be expected of himbe expected of him

Obligation applies in all maritime zones - the high seas, Obligation applies in all maritime zones - the high seas, territorial sea, EEZ and other zonesterritorial sea, EEZ and other zones

Duty of Coastal States (search and rescue ) Duty of Coastal States (search and rescue ) under Article 98 of UNCLOSunder Article 98 of UNCLOS

Obligation of coastal States to:Obligation of coastal States to:““promote the establishment, promote the establishment, operation and maintenance of operation and maintenance of an adequate and effective an adequate and effective search and rescue service search and rescue service regarding safety on and over regarding safety on and over the sea and, where the sea and, where circumstances so require, by circumstances so require, by way of mutual regional way of mutual regional arrangements cooperate with arrangements cooperate with neighbouring States for this neighbouring States for this purpose.”purpose.”

..

International Convention for the Safety of Life International Convention for the Safety of Life at Sea, 1974 (SOLAS)at Sea, 1974 (SOLAS)

Obligation of masters:Obligation of masters:““The master of a ship at sea which is in a position The master of a ship at sea which is in a position to be able to provide assistance, on receiving to be able to provide assistance, on receiving information from any source that persons are in information from any source that persons are in distress at sea, is bound to proceed with all speed distress at sea, is bound to proceed with all speed to their assistance, if possible informing them or the to their assistance, if possible informing them or the search and rescue service that the ship is doing search and rescue service that the ship is doing so…”so…”

Coastal States required to establish search and Coastal States required to establish search and rescue services to ensure safety of navigation around rescue services to ensure safety of navigation around its coastits coast

International Convention on Maritime Search International Convention on Maritime Search and Rescue, 1979 (SAR Convention)and Rescue, 1979 (SAR Convention)

International framework for search and rescue International framework for search and rescue operations worldwideoperations worldwide

Objective: no matter where an accident occurs, Objective: no matter where an accident occurs, rescue will be coordinated by a SAR organization rescue will be coordinated by a SAR organization and, when necessary, by cooperation between and, when necessary, by cooperation between neighbouring SAR organizationsneighbouring SAR organizations

Parties agree to be responsible for search and Parties agree to be responsible for search and rescue in specified areasrescue in specified areas

Rescue Coordination Centres and Rescue Sub-Rescue Coordination Centres and Rescue Sub-centrescentres

SAR Convention (cont.)SAR Convention (cont.)

Obligation to provide assistance to any person in Obligation to provide assistance to any person in distress at sea applies regardless of the nationality distress at sea applies regardless of the nationality or status of such a person or the circumstances in or status of such a person or the circumstances in which the person is found (paragraph 2.1.10)which the person is found (paragraph 2.1.10)

Definition of rescue: an operation to retrieve persons Definition of rescue: an operation to retrieve persons in distress, provide for their initial medical treatment in distress, provide for their initial medical treatment or other needs, and deliver them to a place of safety or other needs, and deliver them to a place of safety (paragraph 1.3.3)(paragraph 1.3.3)

2004 Amendments to SOLAS and SAR 2004 Amendments to SOLAS and SAR ConventionsConventions

IMO review of the SOLAS and SAR Conventions. Object IMO review of the SOLAS and SAR Conventions. Object of the review- take action to ensure that:of the review- take action to ensure that: survivors are provided assistance regardless of survivors are provided assistance regardless of

nationality or status or the circumstances in which nationality or status or the circumstances in which they are foundthey are found

ships are able to deliver the survivors to a place of ships are able to deliver the survivors to a place of safetysafety

survivors treated in accordance with relevant survivors treated in accordance with relevant international agreements and long-standing international agreements and long-standing humanitarian maritime traditionshumanitarian maritime traditions

Led to adoption of amendments, which entered into force Led to adoption of amendments, which entered into force on 1 July 2006on 1 July 2006

2004 Amendments to SOLAS and SAR 2004 Amendments to SOLAS and SAR Conventions (cont.)Conventions (cont.)

States to coordinate and cooperate to ensure that States to coordinate and cooperate to ensure that masters of ships are released from their obligations with masters of ships are released from their obligations with minimum further deviation from the ship’s intended minimum further deviation from the ship’s intended voyagevoyage

The State The State responsible for the SAR region in which the responsible for the SAR region in which the survivors were recovered has survivors were recovered has primary responsibilityprimary responsibility for for ensuring that such coordination and cooperation occurs, ensuring that such coordination and cooperation occurs, so that survivors are disembarked and delivered to a so that survivors are disembarked and delivered to a place of safetyplace of safety

Arrange for disembarkation from the assisting ship as Arrange for disembarkation from the assisting ship as soon as reasonably practicablesoon as reasonably practicable

IMO Guidelines on the Treatment of IMO Guidelines on the Treatment of Persons Rescued at SeaPersons Rescued at Sea

Non-binding IMO Guidelines provide guidance to Non-binding IMO Guidelines provide guidance to Governments and shipmasters Governments and shipmasters

Rescue Coordination Centre to obtain information from Rescue Coordination Centre to obtain information from the master of the assisting shipthe master of the assisting ship

Shipmasters should seek to ensure that survivors are not Shipmasters should seek to ensure that survivors are not disembarked to a place where safety would be disembarked to a place where safety would be jeopardizedjeopardized

Guidance on a “place of safety”Guidance on a “place of safety”

Non-SAR considerations, e.g. status of survivors; security Non-SAR considerations, e.g. status of survivors; security or law enforcement concerns or law enforcement concerns

Further IMO consideration of the treatment Further IMO consideration of the treatment of persons rescued at seaof persons rescued at sea

IMO Facilitation Committee Circular (FAL.3/Circ.194) - Principles IMO Facilitation Committee Circular (FAL.3/Circ.194) - Principles relating to administrative procedures for disembarking persons relating to administrative procedures for disembarking persons rescued at sea:rescued at sea: Coordination between relevant national authoritiesCoordination between relevant national authorities Procedures after disembarkation to a place of safety, e.g. Procedures after disembarkation to a place of safety, e.g.

screening and status assessmentscreening and status assessment Coordination-if swift disembarkation elsewhere not possible, then Coordination-if swift disembarkation elsewhere not possible, then

party responsible for SAR region should accept disembarkation party responsible for SAR region should accept disembarkation of persons rescued into a place of safetyof persons rescued into a place of safety

Cooperation to facilitate return or repatriation of persons rescued. Cooperation to facilitate return or repatriation of persons rescued. For asylum seekers, international protection principles should be For asylum seekers, international protection principles should be observedobserved

Maritime Safety Committee also examining issue of disembarkationMaritime Safety Committee also examining issue of disembarkation

Also consulting on further action to protect safety of persons rescued Also consulting on further action to protect safety of persons rescued at sea (MSC 87/WP.10/Add.1- draft report)at sea (MSC 87/WP.10/Add.1- draft report)

Trafficking and SmugglingTrafficking and Smuggling

United Nations Convention on Transnational United Nations Convention on Transnational Organized Crime, 2000Organized Crime, 2000Protocol Against the Smuggling of Migrants by Protocol Against the Smuggling of Migrants by

Land, Sea and Air, 2000Land, Sea and Air, 2000Protocol to Prevent, Suppress and Punish Protocol to Prevent, Suppress and Punish

Trafficking in Persons, Especially Women and Trafficking in Persons, Especially Women and Children, 2000Children, 2000

Trafficking vs smugglingTrafficking vs smuggling

Smuggling ProtocolSmuggling Protocol

States are required to cooperate to prevent and States are required to cooperate to prevent and suppress the smuggling of migrants, including by sea suppress the smuggling of migrants, including by sea (article 7)(article 7)

A State party, other than the flag State, can board, A State party, other than the flag State, can board, search or take other appropriate action against a vessel search or take other appropriate action against a vessel suspected of being engaged in smuggling (article 8):suspected of being engaged in smuggling (article 8): Action must be authorized by the flag State, unless Action must be authorized by the flag State, unless

necessary to take action to relieve imminent dangernecessary to take action to relieve imminent danger

States can take measures against ships without States can take measures against ships without nationalitynationality

Smuggling ProtocolSmuggling Protocol

Safeguards when action taken to board and inspect Safeguards when action taken to board and inspect a vessel suspected of engaging in smuggling a vessel suspected of engaging in smuggling include (article 9): include (article 9): Action can only be taken by military warships or Action can only be taken by military warships or

other government ships or aircraft other government ships or aircraft Boarding State must ensure the humane Boarding State must ensure the humane

treatment of the persons onboardtreatment of the persons onboardThe rights of the coastal State or the authority of The rights of the coastal State or the authority of

the flag State are not affectedthe flag State are not affected

Smuggling ProtocolSmuggling Protocol

Nothing is to affect the rights and duties of States Nothing is to affect the rights and duties of States and individuals under international law, including and individuals under international law, including (article 19):(article 19):

international humanitarian law international humanitarian law international human rights law and international human rights law and the Refugee Convention and its Protocol and the Refugee Convention and its Protocol and

the principle of the principle of non refoulementnon refoulement

IMO Interim Measures re Trafficking and IMO Interim Measures re Trafficking and Transport of MigrantsTransport of Migrants

IMO Interim Measures for Combating Unsafe IMO Interim Measures for Combating Unsafe Practices Associated with the Trafficking or Practices Associated with the Trafficking or Transport of Migrants by Sea, 1998Transport of Migrants by Sea, 1998

Focus on preventing the operation of ships that Focus on preventing the operation of ships that violate IMO Conventions regarding safety at sea by:violate IMO Conventions regarding safety at sea by:

preventing ships in port from sailing;preventing ships in port from sailing; intercepting ships on the high seas and in intercepting ships on the high seas and in

EEZsEEZs

Reported Incidents (IMO)Reported Incidents (IMO)

2009:2009: Total reported incidents: 381Total reported incidents: 381 Total number of migrants: 9057Total number of migrants: 9057 Middle East- 5266; Africa- 1372; Asia-47; Europe-34Middle East- 5266; Africa- 1372; Asia-47; Europe-34

No comprehensive statistics available, only what is reported to IMO.No comprehensive statistics available, only what is reported to IMO.

Interception/InterdictionInterception/Interdiction

Distinction between rescue and interception/interdictionDistinction between rescue and interception/interdiction

Concerns regarding preserving the legal framework Concerns regarding preserving the legal framework regarding rescue regarding rescue

Enforcement action must be taken in accordance with Enforcement action must be taken in accordance with international law of the sea and other applicable international law of the sea and other applicable principles of international lawprinciples of international law

StowawaysStowaways

Definition of a stowaway:Definition of a stowaway:

““person who is secreted on the ship or in cargo person who is secreted on the ship or in cargo which is subsequently loaded onto the ship, which is subsequently loaded onto the ship, without the consent of the shipowner or the without the consent of the shipowner or the master or any other responsible person, who is master or any other responsible person, who is detected on board after the ship has departed detected on board after the ship has departed from a port and reported as a stowaway by the from a port and reported as a stowaway by the master to the appropriate authorities”master to the appropriate authorities”

Stowaways (cont.)Stowaways (cont.)

IMO Convention on Facilitation of International IMO Convention on Facilitation of International Maritime Traffic contains:Maritime Traffic contains:security measures for preventing stowaways; andsecurity measures for preventing stowaways; andmeasures regarding the disembarkation of measures regarding the disembarkation of

stowawaysstowaways

IMO Guidelines on Resolution of Cases of IMO Guidelines on Resolution of Cases of Stowaways Stowaways

IMO Convention on Facilitation of International IMO Convention on Facilitation of International Maritime TrafficMaritime Traffic

Cooperation to prevent stowaways from embarking Cooperation to prevent stowaways from embarking on shipson ships

Stowaways on board ships must be treated fairly Stowaways on board ships must be treated fairly and humanelyand humanely

Masters must not deviate from the planned voyage Masters must not deviate from the planned voyage to seek the disembarkation of stowaways to seek the disembarkation of stowaways discovered on board, except in certain casesdiscovered on board, except in certain cases

Migration by seaMigration by seaChallengesChallenges

Clandestine migration by sea Clandestine migration by sea Situations of people in distress at sea & loss of lifeSituations of people in distress at sea & loss of lifeLegal framework for search and rescue – participation Legal framework for search and rescue – participation and implementationand implementationInadequate search and rescue facilitiesInadequate search and rescue facilitiesReported cases of delayed rescueReported cases of delayed rescueProblems with disembarkation of those rescued at sea Problems with disembarkation of those rescued at sea and finding a place of safetyand finding a place of safetyProtection needs of asylum seekers & refugeesProtection needs of asylum seekers & refugeesOrigin and transit States – capacity to combat trafficking Origin and transit States – capacity to combat trafficking and smuggling and stop unseaworthy boats from and smuggling and stop unseaworthy boats from departing from their shoresdeparting from their shores

International forumsInternational forums

General Assembly of the United NationsGeneral Assembly of the United Nations

International Maritime OrganizationInternational Maritime Organization

United Nations High Commissioner for RefugeesUnited Nations High Commissioner for Refugees

International Organization for MigrationInternational Organization for Migration

Inter-agency group on the treatment of persons rescued Inter-agency group on the treatment of persons rescued at sea. Includes: UNHCR, United Nations Office on at sea. Includes: UNHCR, United Nations Office on Drugs and Crime, Office of the High Commissioner for Drugs and Crime, Office of the High Commissioner for Human Rights, International Labour Organization, IMO, Human Rights, International Labour Organization, IMO, IOM, and DOALOSIOM, and DOALOS

General Assembly

Annual resolutions on oceans and the law of the sea Resolution 64/71 (2009):Paras. 103-106 calls relating to Flag State

duties and search and rescue responsibilities of all States

Para. 104- take effective action to address unseaworthy ships and small craft within their national jurisdiction

Para. 106- all States to continue to cooperate in developing comprehensive approaches to international migration and development

Resources and further informationResources and further information

Reports of the Secretary-General on oceans and the law of the sea available at http://www.un.org/Depts/los/index.htm

IMO and UNHCR, “Guide to principles and practice as applied to migrants and refugees”, available at http://www.imo.org/Facilitation/mainframe.asp?topic_id=1437

UNHCR, “Selected Reference Materials on Rescue at Sea, Maritime Interception and Stowaways”, available at http://www.unhcr.org/refworld/pdfid/45b8d8b44.pdf