C.

CHINA’S ACTIONS IN RESPECT OF TRADITIONAL FISHING AT

SCARBOROUGH SHOAL (SUBMISSION NO. 10)

Claim of the Philippines:

1. China's nine-dash line claim is invalid under the United Nations Convention on
the Law of the Sea (UNCLOS).
2. China's activities in the South China Sea, including the construction of artificial
islands, have caused severe harm to the marine environment and violated the
Philippines' sovereign rights.
3. China has unlawfully interfered with the Philippines' exercise of its sovereign
rights and freedoms in its exclusive economic zone (EEZ) and continental
shelf.
4. China has unlawfully prevented Philippine fishermen from exercising their
traditional fishing rights at Scarborough Shoal.
5. China has violated its obligations under UNCLOS to respect the rights and
freedoms of other states in the South China Sea and to settle disputes by
peaceful means.

D. ALLEGED FAILURE TO PROTECT AND PRESERVE THE MARINE

ENVIRONMENT (SUBMISSIONS NO. 11 AND 12(B))

Claim of the Philippines:

1. The Philippines claims that China's construction of artificial islands,

installations, and structures in the South China Sea has breached its
obligations to protect and preserve the marine environment. They have
presented evidence of China's increasing construction activities and
expressed concerns over the degradation of the marine environment.
2. The Philippines filed an expert report by reef ecologist Professor Kent E.
Carpenter, highlighting the environmental consequences of China's land
reclamation activities on various reefs in the South China Sea. They argue
that China's actions have caused serious harm to the marine environment.
3. The Philippines alleges that China's artificial island-building activities at
various features in the Spratly Islands, including Cuarteron Reef, Fiery Cross
Reef, Johnson Reef, Hughes Reef, Gaven Reef, and Subi Reef, have violated
 several articles of the United Nations Convention on the Law of the Sea
(UNCLOS), including Articles 123, 192, 194, 197, 205, and 206.
4. The Philippines argues that China's decision not to appear in the arbitration
should not exempt it from the burden of proof. They believe that China should
have made its evaluation available to the Tribunal and that its non-
appearance does not absolve it from providing evidence to support its
assertions.
5. The Philippines raises concerns about China's harmful fishing practices and
the harvesting of endangered species in the Scarborough Shoal. They cite
instances where Chinese officials acknowledged the environmental concerns
raised by the Philippines but asserted Chinese sovereignty over the area.

VIII. AGGRAVATION OR EXTENSION OF THE DISPUTE BETWEEN THE

PARTIES (SUBMISSION NO. 14)

Claim of the Philippines:

1. China's activities in the South China Sea, including its land reclamation and
construction of artificial islands, have caused severe harm to the marine
environment and violated the Philippines' sovereign rights and jurisdiction.
2. China's interference with the Philippines' exercise of its sovereign rights,
including its fishing rights and exploration for oil and gas, is unlawful.
3. China's law enforcement activities, including the seizure of Philippine vessels
and harassment of Philippine fishermen, are unlawful.
4. China's occupation of certain features in the South China Sea, including
Mischief Reef and Second Thomas Shoal, is unlawful.
5. China's actions have aggravated and extended the dispute between the
parties, in violation of its obligation to refrain from such actions under
UNCLOS.