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Abstract
The Saharawi Arab Democratic Republic (SADR) is a founding member of the African Union (AU) and is the sovereign governing authority in Western Sahara. The SADR government believes that the territory's significant natural resources will play an important part in the development of a viable, self-reliant and democratic nation which will contribute to peace, stability and progress of the Maghreb region. The paper examines the SADR's efforts to manage its natural resources through the establishment of the SADR Petroleum and Mines Authority, the launch of licensing rounds, its claim to an exclusive economic zone in the Atlantic Ocean and the recent enactment of a Mining Code. The paper discusses the SADR's efforts to protect its natural resources in a territory that is under occupation, and examines the SADR oil and gas licensing rounds as an example of SADR's assertion of sovereignty. The SADR natural resources strategy has two basic goals: to deter Morocco's efforts to exploit the country's natural resources and to prepare for the recovery of full sovereignty.
Acknowledgments
The author gratefully acknowledges the comments of Jeffrey Smith, barrister, on drafts of this paper.
Disclosure statement
No potential conflict of interest was reported by the author.
Notes on contributor
Fadel Kamal, a Saharawi lawyer, is a senior executive in the Saharawi Republic (SADR) Petroleum and Mines Authority. He currently serves as the Frente Polisario representative in Australia and New Zealand.
Notes on contributor
Fadel Kamal, a Saharawi lawyer, is a senior executive in the Saharawi Republic (SADR) Petroleum and Mines Authority. He currently serves as the Frente Polisario representative in Australia and New Zealand.
Notes
1 Questions of the sovereignty of the Saharawi people to the natural resources of Western Sahara, while awaiting the exercise of self-determination (as a basic right in international law and specifically assured in their case by the United Nations), have been contentious in recent years. The basis for the Saharawi people to assert resource sovereignty flows from UN General Assembly Resolution 1803 (XVII), ‘Permanent sovereignty over natural resources’ (December 14, 1962). For a useful discussion of the development of that right in modern decolonization, see Nico Schrijver, Sovereignty Over Natural Resources: Balancing Rights and Duties (Cambridge: Cambridge University Press, 1997). The application of international law in this regard to the resources of Western Sahara was the particular concern of the United Nations jurisconsult, Hans Corell, in an opinion to the UN Security Council delivered in 2002, discussed below.
2 Frente Popular de Liberación de Saguía el Hamra y Río de Oro; the Popular Front for the Liberation of Saguia el-Hamra and Río de Oro (Frente Polisario). The United Nations deals singularly with the Saharawi people through the Frente Polisario, although it de facto accepts SADR governance in the refugee camps and the liberated zone within Western Sahara proper. Annual reports of the UN Secretary-General to the UN Security Council, read in their entirety, reveal UN policy on Western Sahara. See that for 2015, ‘Report of the Secretary-General on the Situation Concerning Western Sahara' (April 10, 2015) UN doc. S/2015/246.
3 Saharawi constitutional norms, the functioning of the state and democratic structures are discussed below. The Frente Polisario and the SADR (its government) may be viewed simply as two entities that for a Saharawi civil society which they represent are concerned with national liberation on the one hand and governance (and the conduct of some international relationships, but not with the UN) on the other. See also the discussion below in footnote 30.
The liberated area east of the separation wall or ‘berm' constructed by Morocco in the 1980s extends over a third of Western Sahara's land area of 266,000 square kilometers within territorial frontiers established between 1900 and 1912. The SADR has signed contracts with six oil and mining companies. A mineral company, Hanno Resources, is currently undertaking exploration activities in the liberated area.
4 An example is a letter dated June 12, 2014 from the SADR foreign minister to the foreign minister of New Zealand about the import of Saharawi phosphate rock into the latter country (unpublished, on file with the author). See also Law no. 3 of January 21, 2009 Establishing the Maritime Zones of the Saharawi Arab Democratic Republic, discussed below.
5 The Frente Polisario is the accepted representative organization of the Saharawi people, particularly for those under occupation in Western Sahara, in the refugee camps near Tindouf inside Algeria and among the diaspora. The Saharawi, who were the exclusive inhabitants of Spanish Sahara and when the process for a UN-delivered self-determination referendum began in September 1991, were definitively identified in the UN's December 1999 census-registration. For a useful discussion of the UN census-registration process, see Erik Jensen, Western Sahara: Anatomy of a Stalemate (Boulder, CO: Lynne Rienner, 2005).
The Frente Polisario and the SADR government assert sovereignty over all of Western Sahara on several grounds, including the settled rule (jus cogens) of international law which confers the right of self-determination (with a choice of independence) on non-self-governing peoples, the declared position of the colonial power, Spain, for Saharawi self-determination (declared in 1974), the Advisory Opinion of the International Court of Justice 1975 on Western Sahara denying any other state title or legal claim to the territory, and the commitments to ensure self-determination made by the United Nations upon entering into the 1990–91 ceasefire and referendum agreement with the Frente Polisario. It is these factors which ground an overwhelming (i.e. legally exclusive) sovereign right to the territory.
The term ‘pillage' (interchangeable with plunder) is used here in its ordinary legal meaning, as defined by the Fourth Geneva Convention 1949 and the Rome Statute 1998 of the International Criminal Court. The SADR government employs the term on the basis that a part of Western Sahara is under armed occupation the International Court of Justice having concluded that the occupying power has no legal claim to the territory. The ICJ's 1975 Western Sahara Advisory Opinion is discussed below. The decision of Spanish courts in 2014 and 2015 to apply international humanitarian and criminal law in Western Sahara is also considered below.
6 The SADR government accepts that Saharawi under occupation west of the berm must subsist through some form of a functioning economy. However, the overwhelming participation in the Atlantic fishery, phosphate rock mining and transport, agriculture and aquaculture (at Dakhla) is by a settler population introduced after 1975. For example, in numerous personal conversations with Saharawi from the occupied area and after studying available information, the author concludes that no more than 400 of the 2014 workforce of 2200 persons were Saharawi with some original tie, residency or citizenship in the territory.
7 Phosphate rock mining and exports are controlled through the Office Chérifien des Phosphates SA (OCP SA), a state corporation of the occupying power. In 2014 the company issued a securities financing prospectus which noted that the highest quality top layer of phosphate rock at the Bu Craa mine site would be worked to exhaustion that year. 50 million tonnes of phosphate rock were exported from occupied Western Sahara between 1975 and 2014. Reserves of perhaps 500 million tonnes remain. See OCP SA Prospectus of 17 April 2014 (debt financing on the Irish Stock Exchange), which may be found with a similar 2015 prospectus at the website of the Irish Stock Exchange, http://www.ise.ie (accessed July 24, 2015)
8 ‘We call on the United Nations to establish a UN Council for the Natural Resources of Western Sahara. The UN Council for Namibia which, among other things, legislated for and oversaw the development of natural resources in occupied Namibia until 1990 is a good example and precedent. The UN should retain the revenues received from the exploitation of the natural resources of Western Sahara in trust until the Saharawi people exercise their right to self-determination and decide their future.' Statement by Fadel Kamal, Representative of the Frente Polisario-Western Sahara at the Seminar of the UN Special Committee of Decolonization (C-24) Fiji, May 21–23, 2014.
9 The SADR government estimates the current (2014) direct rent (revenue) from the coastal fishery at US$60 million. (The author derives this from personal conversations in 2014 and 2015 with government officials and by reconciling estimates with known payments made by the European Union and Russia to Morocco for fishing in the Saharan Atlantic area.) In September 2014 fishing resumed by European vessels under a renewed EU–Morocco Fisheries Partnership Agreement, by which the occupying power is annually paid €30 million, the remainder being from Russia under an agreement renewed in 2013, a local offshore commercial fishery, and in October 2014 a seasonal tuna fishery conducted by Japanese vessels. Academic commentary on the economic and legal aspects of what in recent years has been a controversial EU fishery remains limited. See notably Jeffrey Smith, ‘Fishing for Self-Determination: European Fisheries and Western Sahara – The Case of Ocean Resources in Africa's Last Colony', Ocean Yearbook 27 (2013): 267.
10 For current details of phosphate rock exports from occupied Western Sahara, see Western Sahara Resource Watch, P for Plunder (Brussels: Western Sahara Resource Watch, 2015). The FAO's Canary Current Large Marine Ecosystem Project of fisheries and ecosystem assessment (and the building of governance capacity in participating states) is detailed at http://www.canarycurrent.org (accessed March 15, 2015).
11 See African Union Peace and Security Council Communiqué of March 27, 2015, AU doc. PSC/PR/COMM./1 (CDXCVI). The Council called on ‘the UN Security Council to address the issue of the illegal exploitation of the Territory's natural resources, bearing in mind the call made in the UN Secretary-General report of 10 April 2014, for all relevant actors, in the light of the increased interest in the natural resources of Western Sahara, to “recognize the principle that the interests of the inhabitants of these territories are paramount”, in accordance with Chapter XI, article 73 of the Charter' and recommended ‘consideration of a strategy of global boycott of products of companies involved in the illegal exploitation of the natural resources of Western Sahara as a way of further sustaining the attention of the international community on the situation in Western Sahara'. Ibid., para. 11.
12 See Case Concerning East Timor (Portugal v Australia), ICJ Reports 1995, 90.
13 The SADR government engages the law where it can, asserting permanent sovereignty of the Saharawi people to their resources under the UN Charter and UN General Assembly Resolution 1803 (XVII), December 14, 1962 (most famously applied by Hans Corell in his 2002 legal opinion for the UN Security Council on the subject of petroleum exploration in Western Sahara), as well as international humanitarian law with its prohibition against pillage under the Fourth Geneva Convention 1949. The Saharawi government also pursues the enforcement of national criminal, civil and regulatory law throughout Western Sahara and accepts that the criminal law of Spain as the colonial-administering power may have a protective role, including after a 2014 Audencia Nacional decision concluded that Spanish criminal law has continued in at least the occupied area of the territory. On April 9, 2015, a judge of the same court determined that a criminal prosecution case on the basis of genocide could be pursued against eight Moroccan military and three civilians for acts in Western Sahara from 1976 to 1991. See Fernando J. Pérez, ‘Ruz procesa 11 mandos militares marroquies por genocidio en el Sáhara’, El País, April 9, 2015.
14 For an historical background, see Tony Hodges, Western Sahara: The Roots of a Desert War (Westport, CT: Lawrence Hill, 1983).
15 Western Sahara may be unique among nations in that it routinely has no surficial water courses. Most wadi are dry for a majority of the year, and there are no appreciable sized bodies of fresh water.
16 The SADR government considers the construction and continued operation of the berm unlawful, and a criminal act within the relevant provisions of the Geneva and Hague Conventions and the Rome Statute (International Criminal Court). By comparison, the International Criminal Court has concluded that part of Israel's security fence which passes through lands of the State of Palestine to violate international law, concluding that in such places it must be removed. See Legal Consequences of the Construction of a Wall in the Occupied Palestinian Territory (Advisory Opinion), ICJ Reports 2004, 136.
17 Mine action organizations estimate the number of land mines throughout the territory, principally along the inland length of the berm, at more than 7 million. See e.g. http://unrec.org/default/index.php/en/2012-08-14-15-04-20/2013-10-30-09-26-03/conventional-arms-issues (accessed April 7, 2015).
18 The SADR government conducts aquifer studies and regulates groundwater use in the liberated area, which is lightly populated including permanent residents and units of the Saharawi People's Liberation Army as well as, in one location east of the berm, a UN MINURSO site. (Personal conversations and field observations of the author in the presence of Saharawi officials, 2014–15.)
19 The largest use of water in the occupied area is for human consumption, although agriculture applications are considerable, for example in hydroponic farms around Dakhla. Water use for fish processing and phosphate rock washing is comparatively small. In addition to the Saharawi population and around 200,000 Moroccan settlers, there are also over 100,000 occupying troops mostly deployed all along the berm. (Personal conversations of the author with UN officials, Saharawi residents of the occupied part of Western Sahara, and Saharawi officials, 2014–15.)
20 Letter dated January 29, 2002 from the Under-Secretary-General for Legal Affairs, the Legal Counsel, addressed to the President of the Security Council, UN doc. S/2002/161. The letter is routinely misquoted by petroleum companies and corporations which purchase phosphate rock. The operative conclusion and therefore legal guidance to the Security Council is at paragraph 25: ‘[I]f further exploration and exploitation activities were to proceed in disregard of the interests and wishes of the people of Western Sahara, they would be in violation of the principles of international law applicable to mineral resource activities in Non-Self-Governing Territories.' This requirement has its origins in UN General Assembly Resolution 1803 of December 14, 1962 declaring the right of non-self-governing peoples to sovereignty over their natural resources.
21 The Maritime Zones statute, above, was remarked upon by the UN Secretary-General in his 2009 report to the Security Council and appears to have caused the EU Parliament to reconsider the 2007 EU–Morocco Fisheries Partnership Agreement, resulting in its rejection in December 2011. See Johann Schoo, ‘Letter – Fisheries Partnership Agreement between the European Community and the Kingdom of Morocco – Declaration by the Saharawi Arab Democratic Republic (SADR) of 21 January 2009 of jurisdiction over an Exclusive Economic Zone of 200 nautical miles off the Western Sahara – Catches taken by EU-flagged vessels fishing in the waters off the Western Sahara' (European Union/Commission Legal Service Opinion), July, 13 2009. The letter was made public in February 2010 and can be found on the website of Western Sahara Resource Watch, http://www.wsrw.org.
22 The two areas are from Dakhla south to the Cape Blanc peninsula (Groupe Total SA) and the Boujdour Offshore Block (Kosmos Energy Ltd.) where the Gargaa/El Khayr website was drilled in Q1 2015. The Saharawi government protested to both companies.
23 Letter of January 26, 2015, http://www.spsrasd.info (accessed March 2, 2015). The UN Secretary-General noted the protest in his annual report to the Security Council, ‘Report of the Secretary-General on the situation concerning Western Sahara' (April 10, 2015) UN doc. S/20-15/246, para. 62. And see para. 80: ‘In the light of increased interest in the natural resources of Western Sahara, it is timely to call upon all relevant actors to “recognize the principle that the interests of the inhabitants of these territories are paramount”, in accordance with Chapter XI, Article 73 of the Charter of the United Nations.'
24 In January 2014 the SADR detailed a compensation claim to the largest purchaser of Saharawi phosphate, Potash Corporation of Saskatchewan Inc., noting the claim then to be a minimum of US$400 million. (A copy of the Saharawi Republic's unpublished letter is on file with the author.)
25 ‘Burden or Benefit? Morocco in the Western Sahara', lecture given at the Middle East Studies Centre, Oxford University, February 18, 2005 by Toby Shelley (author of Endgame in the Western Sahara:
What Future for Africa's Last Colony? (London: Zed Books, 2004)). The text of the lecture is available at http://www.arso.org/TSh180205.htm (accessed April 8, 2015).
26 Energy security in a future Western Sahara has been studied by the SADR government with a view to alternative energy sources given the cost of petroleum and desired national contributions to reducing greenhouse gases from the use of fossil fuels.
27 This is the author's calculation, arrived at through the following methodology. The net present annual revenue-taxation return from the territory's present four leading resources is calculated over a 25-year period. 250 million barrels of petroleum is assumed to be available at a market price of US$60 per barrel and extracted at 10 million barrels annually, for a revenue stream of $600 million per annum. The second resource, the fishery, is accepted as having a $60 million taxation (rent) revenue, unchanged from 2014 when EU fishing resumed. The amount is then doubled to account for secondary economic production in the sector, notably processing and services to vessels, for a fisheries sector total of $120 million. Third, phosphate mineral rock exports are put at 2.5 million tonnes per year, up slightly from the five-year average (2010–14) of 2.1–2.2 million tonnes, at $120 per tonne for a total market (commodity) payment to government of $300 million annually. (From this amount would be deducted the cost to operate the mine and transport infrastructure, about $100 million per year.)
It is the fourth resource, iron ore, that has the greatest variability in making estimates. Details about the volume and quality of reserves in the occupied area are not available or lack credibility. However, enough is known from the experience of the high value site at Kedia d'Idjil-Zouerate nearby in Mauritania and recent prospecting in the liberated area that estimates can be done with confidence. A future iron ore mine with reserves of 300 million tonnes yielding recoverable ore at 35% and an annual net production of four million tonnes at $60 per tonne results in revenue of $240 million.
The four annual revenue streams total ($600 million + $120 million + $300 million + $240 million) US$1260 million.
28 Examples of this policy stance include legislation and governing mechanisms for resource development in the liberated zone, the general maintenance and improvement of rule of law measures in the SADR government such as initiatives for transparency in decision-making and civil society participation in resource planning, the call for United Nations involvement in current resource exports, and continual protests over the taking of resources (and environmental protection concerns) in the occupied area of Western Sahara.
29 ‘Proposal of the Frente Polisario for a mutually acceptable political solution that provides for the self-determination of the people of Western Sahara', UN doc. S/2007/210 (April 16, 2007), at para. 9.3.
30 The political economy of the Saharawi state must be considered in the context of the setting of the Saharawi refugee camps and the pursuit of national liberation through the Frente Polisario. The SADR assumes a form closest to a classically Western (i.e. Global North) democratic ideal in the electoral mandate it receives to govern for the maintenance of civil society in the camps. That mandate, when it comes to self-determination, and engaging external entities such as the United Nations, is conferred through the Saharawi parliament (the National Council) upon government for exercise by the Frente Polisario. ‘The Sahrawi National Council is the legislative organ of the SADR. Its fifty-three members are elected each eighteen months. The council meets in two annual sessions with commissions functioning between times. It considers the programme put forward by the government and if two-thirds of the members consistently oppose it, the head of state must choose between dissolving the council or choosing a new cabinet. The council can censure the government. Along with the prime minister, deputies of the National Council can propose legislation.' Shelley, Endgame in the Western Sahara, 183. For a discussion of governance in Saharawi refugee camps see Stephen Zunes and Jacob Mundy, Western Sahara: War, Nationalism, and Conflict Resolution (Syracuse, NY: Syracuse University Press, 2010).
31 An Arabic language version of the Constitution is available at http://www.20may.org/ar/wp-content/uploads/2014/06/دستور-الجمهورية-العربية-الصحراوية-الديمقراطية-الصادر-عن-المؤتمر-13-للجبهة.pdf (accessed March 5, 2015).
Accountability of the Saharawi government to its citizens is realized for the most part through the dialogue and review of government programs and decisions by the National Council, as noted above. There is not a tradition of judicial review of executive action or government decision-making, or commentary by third parties including external entities such as the Office of the UN High Commissioner for Refugees. Human rights organizations are routinely invited into the refugee camps for open-access visits, such as a delegation from the Robert F. Kennedy Center in the summer of 2012, but they have not considered governance institutions or the adequacy of democratic norms in Saharawi society.
32 The just allocation of water in a society (Qu'ran 16:65) and the conservation of resources from past generations for future ones (Qu'ran 89:19) are relevant tenets of Islam.
33 SADR Constitution, Article 17.
34 Ibid., Articles 75–123.
35 The experience of Timor-Leste after 24 years of occupation during which there were significant changes of property ownership (and expropriation by the occupying state) is instructive.
36 The SADR government is sensitive to cultural heritage, and has studied and regulated the protection of historic sites in the liberated zone, for example the rock gallery paintings west of Tifariti. Provisions of the 2014 Mining Code restrict government grants of mining license areas (‘Tenements’) over certain types of private property and provide for expropriation compensation.
37 Law No. 02/2014. The Code was adopted on May 26, 2014 after considerable review by elected legislators and revisions to satisfy their public policy concerns. It had latterly been revised by the Economic Committee of the National Council after consultation with the SADR executive branch. A principal goal was a statute drafted to international standards including with the assistance of legal firms with extensive experience in advising governments on mining law. See http://www.sadrpma.com (accessed March 2, 2015).
38 In July 2011 Hanno Resources Limited (formerly Excalibur Resources Group Limited) presented the results of its work under the Technical Cooperation Agreement (TCA), noting that Western Sahara is highly prospective for iron ore, gold, base metals and uranium. The results of more detailed assessments were provided in March 2015 and are discussed below.
39 The Mining Code also establishes the state royalty on extracted, marketable minerals. It was first thought that royalty rates should be governed though a flexible scheme of government regulations and ministerial directions; however, the need for commercial certainty under a National Council (parliament) created statute was eventually preferred.
40 This role extends to the fisheries although shared with the SADR Ministry of Foreign Affairs because of the international relations implications of European and other states’ treaty fisheries on the Saharan coast.
41 The SADR government granted a Technical Cooperation Agreement to Fusion Oil and Gas in 2000 which enabled that company to assess the potential of the territory.
42 The El Aauin basin is also known as the Coastal basin. See Nasser Ennih and Jean-Paul Liégeois, The Boundaries Of The West African Craton, With Special Reference To The Basement Of The Moroccan Metacratonic Anti-Atlas Belt (London: Geological Society, 2008) and Jean Fabre, Géologie du Sahara occidental et central (Tervuren: Musée royal de l'Afrique centrale – Belgique, 2005).
43 See http://metalexventures.com (accessed March 1, 2015). The company claims possible deposits of gold, zinc, lead and other metals, and diamonds in kimberlite in what is the Mauritanides Thrust Belt of the Reguibat Shield which extends 50–80 km west of the berm.
44 The PMA has assessed data made available to it, and accepts a general statement made in 2014 by Kosmos Energy Ltd. that the Boujdour Offshore permit area may contain up to 1 billion Barrels of Proved Oil Equivalent (BPOE). Following the decline in petroleum prices in the second half of 2014, the PMA assigned a figure of $70 per barrel as the threshold for return of viable deepwater petroleum recovery on the Saharan coast.
45 The SADR entered into a TCA with Hanno Resources in March 2007. Under the terms of the agreement Hanno undertook to provide a technical appraisal of the mineral potential of the SADR. See http://www.hannoresources.com/ (accessed July 24, 2015)
46 Much of the liberated area was surveyed in the seven years of the TCA, including assessments of how extracted ore can be transported for export. A significant challenge was ensuring the safety of prospecting teams working near unmarked, unexploded munitions, particularly land mines deployed by the occupying power east of the berm. Studies to assess mineral deposits in the occupied area continue, including literature surveys, analysis of satellite data, and appraisal of samples.
47 The exploration permits cover the Oum Abana Greenstone Belt, an area highly prospective for gold and base metals, and the Tiris Iron Ore Province noted above as prospective for iron ore.
48 Nouadhibou is a possible industrial harbour for exports, located on the Cape Blanc peninsula, the seaward side of which is the southernmost part of the SADR liberated area, including the town of Laguera.
49 Four of the licenses are in the ore province, and three are 60–80 km to the north.
50 The SADR government and the Frente Polisario have noted for decades that Saharawi territorial integrity is settled, in part by customary international law through the uti posseditis principle and the African Union Charter, and by the conclusion of the International Court of Justice in 1975 that neither Mauritania nor Morocco had any tenable claim to the territory of the then Spanish Sahara. See Western Sahara Advisory Opinion, ICJ Reports 1975, 12 at para. 162.
While no court of competent jurisdiction has declared Western Sahara to be occupied as such, the combination of the ICJ's 1975 opinion, resolutions of the UN General Assembly which declare the territory to be occupied, the positions of neighbouring states such as Algeria and Mauritania, and, crucially, the facts on the ground (a sustained armed occupation and the military partitioning of the territory by construction of the berm) make clear the legal status of the territory. Moreover, it must be recalled that the occupying power has always committed to relinquishing possession of Western Sahara on the completion of a referendum for self-determination of the Saharawi people, should they choose independence. The commitments made by the occupying power under the 1990–91 UN sponsored ceasefire and referendum agreement remain unchanged.
51 Two sources of law apply to the pillage of resources from Western Sahara: Resolution 1803 permanent sovereignty rights (requiring consent and benefit of resource extraction exclusively to the Saharawi people) much discussed after the 2002 Corell–UN Security Council opinion, and international humanitarian law with its criminal law prohibition on pillage except for resources for the needs of a civil population under occupation. The SADR government routinely asserts both sources of law in its protests about resource development and exports. Letters of protest are occasionally made public, such as that of January 26, 2015, referred to above.
52 The Frente Polisario is presently challenging the legality of the EU–Morocco Fisheries Partnership Agreement in the European Court of Justice, in part on the basis that the 2009 Treaty on the Functioning of the European Union prohibits an arrangement contrary to international law. See EJIL Talk (blog of the European Journal of International Law) ‘Trade Agreements, EU Law, and Occupied Territories – A Report on EU Council' (July 1, 2015) at http://www.ejiltalk.org (accessed July 3, 2015).
53 The challenges to transparent, accountable and democratic control of resources in post-conflict states are manifold, and go to the core of establishing the rule of law. The design of institutions, the reviewing role of courts, and then engagement of civil society in resource planning are a part of this. For extensive useful commentary in the case of Timor-Leste after that country's 2002 independence, see the website of the Timor-Leste Institute for Development Monitoring and Analysis, http://www.laohamutuk.org (accessed April 1, 2015).
54 SADR PMA executives and others in Saharawi civil society, galvanized after 2012 by the prospect of petroleum in the Saharan seabed, have started to consider how a permanent, transparent and well-governed sovereign resource fund can be created along the lines of those in Norway and Timor-Leste. The policy analysis about that has usefully informed appeals for UN oversight or trust administration of resources while under occupation.