The Understanding of the United States Government Regarding the Geography ofTakeshima Immediately After the San Francisco Peace Treaty Came into Effect-Drawing on US Government-Issued Aeronautical Charts Published in 1953 and 1954-

Rikinobu Funasugi, Associate Professor,
Faculty of Law and Literature, Shimane University

1. Introduction(1) Purpose of this paper(2) Views of the governments of Japan and the Republic of Korea on the treatment
of Takeshima in the San Francisco Peace Treaty
2. Details of textual and other information provided on aeronautical charts(1) USAF JET NAVIGATION CHART, (JN-25), YELLOW SEA(1954)(2) USAF JET NAVIGATION CHART, (JN-26), SEA OF JAPAN(1954)(3) USAF PILOTAGE CHART, (379D) G, TO DONG, JAPAN-KOREA(1953)
3. Comparison with previous editions of relevant aeronautical charts
4. Conclusion

11. Introduction(1) Purpose of this paper
This paper examines the understanding of the United States government regarding thegeography of Takeshima immediately after the San Francisco Peace Treaty came into
effect. Taking international law into account, I use aeronautical charts compiled by theUnited States government and published immediately after the peace treaty came into
force to consider the views of the United States from the perspectives of historical
geography and cartographical history.1
After World War II, Japan’s postwar territory was defined by the San Francisco Peace
Treaty, which was signed in September 1951 and came into effect in April 1952. A peace
treaty is generally accompanied by a map or maps, but this was not the case with the San
Francisco Peace Treaty. Instead, the treaty merely listed the territories over which Japan
was to relinquish sovereignty under the terms of the peace. As we shall see, Japan and theRepublic of Korea differ in their interpretations of how Takeshima was to be treated in
the San Francisco Peace Treaty.
In territorial disputes, official maps compiled by a third country generally do not forma basis for territorial claims under international law2. Since the United States was one of
the main drafters of the San Francisco Peace Treaty, official maps drawn up by the US
government are valuable sources of information that can help to supplement and clarify
the content of the San Francisco Peace Treaty. These official maps are important resources
for research on the Takeshima issue when analyzing the geographical views of the US
government soon after the peace treaty came into effect. In spite of their importance, theseofficial US maps, drawn up shortly after the peace treaty, have been mostly overlooked

1

This paper represents the personal views of the author and does not necessarily represent

the views of the Japan Institute of International Affairs.
2

Norio Araki, a professor in international law at Hakuoh University, has written about official

maps produced by a third-party country as follows: “Although maps printed and published bya third country do not have as much value compared to the fact of governance as evidence forclaims to sovereignty, nevertheless, in a case for example where newly independent countries
are involved in a dispute over international boundaries, maps produced by the former colonial
power are regarded as official maps produced by a third nation, but the value of such maps
cannot be discounted entirely.” Norio Araki, “Ryodo/kokkyo funso ni okeru chizu no kino”(The function of maps in disputes over territory and boundaries), in Waseda Hogaku, 74-3,
1999, p.13
2

in research to date on the question of territorial sovereignty over Takeshima.
On the Korean side, Li Jin-mieung, professor emeritus at the Université Jean Moulin
Lyon 3 in France, included in a study on Dokdo (the Korean name for Takeshima) a
photograph of an aeronautical chart dated March 22, 1951, which he describes as a “Mapof KADIZ (Korea Air Defense Identification Zone) and JADIZ (Japan Air Defense
Identification Zone), established by the Commander of the US Air Force of the Pacific(sic).” The explanatory note to the illustration claims that “ ‘Liancourt Rocks (Take
Island)’ [Dokdo] is included in the KADIZ. This measure remains valid until nowadays(sic).” 3 However, Professor Li’s study merely quotes the note printed on the chart
regarding the Japanese and Korean air defense identification zones. He fails to provide
basic information on his source, including the title of the aeronautical chart, its publisher,or the date of publication.
From the content, it seems likely that the map in question is “Global Navigation and
Planning Chart, GNC-5, Central Asia, 9-87, Edition 7,” a 1:5,000,000 map published by
the Defense Mapping Agency Aerospace Center (US Department of Defense) in
September 1987. By using charts published much later than the period in question, andfailing to provide publication information, Professor Li misleads his readers, encouraging
them to believe that he is discussing a map published in 1951. Professor Li’s actions
violate academic integrity.
But in fact, even if this aeronautical chart did date from around March 1951, thiswould not affect my argument because the Supreme Commander for the Allied Powers(SCAP) responded to a query from the Japanese government about territorial issues bysaying that these should be settled by the San Francisco peace conference. Citing
aeronautical charts drawn up before the signing of the peace treaty is therefore without
significance in clarifying the content of the treaty. And as I will explain later, an air
defense identification zone does not define the limits or extent of territorial air or land
space.
Aeronautical charts produced by US government agencies are important sources of
information that demonstrate Washington’s understanding of Takeshima’s geography.
There are three well-known types of aeronautical charts: those published by theInternational Civil Aviation Organization (ICAO, a UN organization), those published by
the private company Jeppesen, and those published by the United States government.4

3

Li Jin-mieung, Dokdo: A Korean Island Rediscovered, Northeast Asian History

Foundation, 2010, pp.237–238, p.329.
4

Incidentally, neither the aeronautical charts produced by the ICAO nor those produced by
3

The aeronautical charts published by the United States government cover almost theentire world, with maps scaled at 1:2,000,000, 1:1,000,000, and 1:500,000. As the world’s
most comprehensive, precise, and widely circulated charts, they have been used for
civilian and military purposes, and have been described as goliaths in the world of
aeronautical charts. These topographical maps are used not only for flight navigation but
also for many purposes including strategic planning, exploration, and media reporting.5
In June 2012, I purchased from an antiquarian bookseller in Tokyo a copy of the “Jet
Navigation Chart, JN-26, Edition 3” (Sea of Japan), a 1:2,000,000-scale map drawn up
by the US Department of Defense in 1980 and published in 1981. On the chart, a national
borderline is drawn between Ullŭng Do (Ulleungdo, or Utsuryo To in Japanese) andanother island which has a latitude and longitude corresponding with the coordinates ofTakeshima, although its name is not marked on the chart. The area to the southeast of thisline is marked “Japan,” and the area to its northwest is marked “Korea.” This confirmsthat on this chart, Ulleungdo is shown as Korean territory and Takeshima as Japanese
territory.6
In February 2013, I obtained from a university library in the United States a photocopy
of a 1:2,000,000 aeronautical chart: “Jet Navigation Chart, JN-25, Edition 5” (Yellow
Sea), drawn up by the US Department of Defense in 1996 and published in 1997. The
map showed an island which had coordinates and a position that corresponded to thoseof Takeshima, though no name for the island was given. Above the island was the text
“Japan,” while the island of “Ullŭng Do” was marked “South Korea,” confirming that
this chart too showed Ulleungdo as Korean and Takeshima as Japanese territory.7
Even though these charts were produced 29 and 45 years respectively after the San
Francisco Peace Treaty came into effect, they remain important sources of informationthat indicate the understanding of the United States government regarding the geography

the private company Jeppesen contain any information regarding sovereignty over Takeshima.
They would have no value as evidence in international law.
5

Hiroshi Ota, Kokuzu no hanashi (About aeronautical charts), Seizando Shoten, 2007,

pp.44–45.
6

Yomiuri Shimbun, Osaka edition, February 20, 2013: “80-nen Bei no chizu de ‘Nihonryo’

Ken nyushu” (Prefecture obtains US map from 1980 showing island to be Japanese territory).
This map has since been donated to Shimane Prefecture’s Takeshima Reference Room.
7

Yomiuri Shimbun, Shimane edition, March 28, 2013: “Bei 1997-nen Takeshima ‘Japan’

Kokubososho no kokuzu kisai” (US Department of Defense marked Takeshima as “Japan”
on 1997 aeronautical charts).
4

of Takeshima. By analyzing the text printed on aeronautical charts produced by the UnitedStates government directly after the peace treaty came into effect, it should be possible toconfirm the US government’s understanding of Takeshima’s geography when the treaty
was signed and came into effect. A private research company based in Tokyo wasaccordingly hired to conduct a study of US government-produced aeronautical charts inthe collections of the US National Archives. This study was carried out in fiscal 2019 aspart of a research project undertaken by Shimane University on behalf of the Japan
Institute of International Affairs.
(2) Views of the governments of Japan and the Republic of Korea on the treatment
of Takeshima in the San Francisco Peace Treaty
Research carried out over many years by Takashi Tsukamoto, a former professor at
Tokai University, has already made clear the treatment of Takeshima in the San Francisco
Peace Treaty.8 The views of the Japanese government are given as follows on the websiteof the Ministry of Foreign Affairs.9---------------------------------------------------------------------------------------------------1. The San Francisco Peace Treaty, signed in September 1951, stipulated that Japan
should recognize the independence of Korea, and that Japan should renounce all rights,
titles and claims to “Korea, including the islands of Quelpart, Port Hamilton and
Dagelet.”2. Upon learning of this section drafted by the United States and the United Kingdom,in July 1951 the ROK submitted a letter to Dean G. Acheson, the Secretary of Stateof the United States, from Yang Yu Chan, ROK Ambassador to the United States. Thisletter contained the following statement:

8

For example, Takashi Tsukamoto, “San Furanshisuko Joyaku to Takeshima: Bei-gaikobunsho-shu yori” (The San Francisco Treaty and Takeshima: From collections of US
diplomatic papers), The Reference 33-6, 1983. Also, “Heiwa joyaku to Takeshima: Sairon”(The Peace Treaty and Takeshima: Reconsidered), The Reference 44-3, 1994.
9The Ministry of Foreign Affairs of Japan maintains information relating to Takeshima in

English and several other languages: “Treatment of Takeshima in the San Francisco Peace
Treaty” https://www.mofa. go.jp/a_o/na/takeshima/page1we_000062.html (Accessed June
1, 2021).
5

My Government requests that the word “renounces” in Paragraph A, Article Number
2, should be replaced by “confirms that it renounced on August 9, 1945, all rights,
titles and claims to Korea and the islands which were part of Korea prior to its
annexation by Japan, including the islands [of] Quelpart, Port Hamilton, Dagelet,
Dokdo and Parangdo.”
3. In response to this request from the ROK, in August of the same year the United States
submitted a letter (an excerpt of which is shown below) from Dean Rusk, UnitedStates Assistant Secretary of State for Far Eastern Affairs, to Ambassador Yang, andin it clearly denied the claims of the ROK:...the United States Government does not feel that the Treaty [the San Francisco Peace
Treaty] should adopt the theory that Japan’s acceptance of the Potsdam Declaration
on August 9, 1945, constituted a formal or final renunciation of sovereignty by Japanover the areas dealt with in the Declaration. As regards to the island of Dokdo,
otherwise known as Takeshima or Liancourt Rocks, this normally uninhabited rockformation was according to our information never treated as part of Korea and, since
about 1905, has been under the jurisdiction of the Oki Islands Branch Office of
Shimane Prefecture of Japan. The island does not appear ever before to have been
claimed by Korea.
Based on this correspondence, in the San Francisco Peace Treaty, it is obvious that
Takeshima was affirmed as a territory of Japan.
4. The report by Ambassador Van Fleet after visiting the ROK in 1954 and returning to
the United States also states that the United States concluded that Takeshima was aterritory of Japan and the island was not included among the islands that Japan
released from its sovereignty under the San Francisco Peace Treaty.
---------------------------------------------------------------------------------------------------To summarize: Takeshima was not listed among the territories to be relinquished by
Japan in the article concerning renunciation of claims over Korea10 in the San Francisco
Peace Treaty. The US government officially rejected the Korean government’s request to

10“Japan recognizing the independence of Korea, renounces all right, title and claim to

Korea, including the islands of Quelpart, Port Hamilton and Dagelet.”6

include Takeshima among the territories to be given up by Japan, in a letter dated August
10, 1951, written by Dean Rusk, United States Assistant Secretary of State for Far Eastern
Affairs. In light of these facts, we can conclude that Takeshima was clearly retained aspart of Japanese territory in the San Francisco Peace Treaty.
Further reinforcement for the position of the Japanese government can be found in
the statement made at a regular press briefing at the White House in Washington, DC on
July 30, 2008. The statement read: “Our policy on this territorial dispute has been firmand consistent since 1952, and that is, we do not take a position on this territorial
dispute.”11 This extremely important statement shows that although the United States
government has consistently maintained a stance of not getting involved in territorial
disputes between third-party countries that do not affect its own interests, the US
government has not changed its view on the issue since the Rusk letter of August 1951,
the San Francisco Peace Treaty (signed in September 1951, effective from April 1952),
and the Van Fleet report of August 1954.
Despite this, the government of the Republic of Korea’s interpretation isdiametrically opposite to the Japanese view. The extent of these differences is madeclear by a series of diplomatic notes verbales between the Korean and Japanese
governments, as follows.12
1) In a “rebuttal to the views of the Japanese government of July 13, 1953, on
Dokdo [Takeshima]” dated September 9, 1953, the Korean government
wrote:SCAPIN [Supreme Commander for the Allied Powers Instruction Note]
677, dated January 29, 1946, clearly placed Dokdo outside Japanese
territory, and the section of the peace treaty dealing with Japanese

11

Available on the White House website: “Press Briefing by Senior Director for Asian Affairs

at the National Security Council, Dennis Wilder, on President’s Trip to Asia,” July 30, 2008.
https://georgewbushwhitehouse.archives.gov/news/releases/2008/07/20080730-13.html(Accessed April 18, 2021).
12This and all following documents released by the government of the Republic of Korea aretaken from Takashi Tsukamoto, “Takeshima ryoyuken o meguru Nik-kan ryogoku seifu no
kenkai” (Views of the Japanese and Korean Governments on Takeshima), The Reference, 526, 2002.
7

territory contains nothing that contradicts this memorandum. The treaty
therefore confirmed the intentions of the Supreme Commander for the
Allied Powers on this issue without any changes.
2) In a note outlining the “Views of the Korean government” dated September
25, 1954, regarding note verbale No. 15 A-2 sent by the Japanese Ministryof Foreign Affairs on February 10, 1954, the Korean side wrote:
The peace treaty with Japan contains nothing that contradicts Korea’s
legitimate claim to territorial sovereignty over Dokdo. Furthermore, ourinterpretation is that Chapter 1(sic), Article 2A (The correct reference
should be to Chapter 2, Article 2A of the treaty.) of the treaty recognizes
Dokdo as Korean territory along with Ulleungdo [Dagelet], as adependency of Ulleungdo.
3) In a note dated January 7, 1959, outlining the “Views of the government of
the Republic of Korea, in rebuttal of the views of the government of Japan
regarding Dokdo of September 20, 1956,” Korea wrote:
SCAPIN 677 explicitly treats Dokdo separately from the “adjacentsmaller islands,” and since Japanese territory was limited to the [mainislands and] adjacent smaller islands in the basic policy after Japan’ssurrender, published on June 19, 1947, this confirms the separation of
Dokdo from Japanese territory. Since the Treaty of Peace with Japan
contains no ruling positively including Dokdo within Japanese territory,
no change is possible from the previously confirmed position, namelythat the island would be separated from Japan. It is necessary to have aunified understanding of the treatment Dokdo based on the various
documents from the Potsdam Declaration to the basic policy after
Japan’s surrender. Japan’s position, which attempts to distort the whole
by taking Article 6 of SCAPIN 677 out of context, is inappropriate. In
particular, we should remember that Korea achieved independence inAugust 1948 — in advance of the Treaty of Peace with Japan — andaccordingly recovered control and administration over Dokdo, andreceived formal acknowledgement of this from the countries involvedin formulating the Peace Treaty at the time. Dokdo was not one of the8peripheral small islands under the control of SCAP, nor was it a region
over which the United States retained legislative and judicial control
after Korean independence. Furthermore, Japan never established what
it claims as “residual sovereignty” over Dokdo.
The Korean view is essentially that Takeshima became Korean territory as a result of
SCAPIN 677, published in 1946, and that since the San Francisco Peace Treaty does notcontain any clause explicitly declaring Takeshima to be Japanese territory, there has been
no change to the decision laid out in SCAPIN 677. This is not an essay on internationallaw, and counterarguments in response to the Korean appeals to international law
regarding SCAPIN 677 and the Peace Treaty have already been made by the Japanese
government and Japanese scholars, so I will not go into a detailed discussion here. Suffice
it to say that SCAPIN 677 was a ruling issued under the special and limited circumstancesof Japan’s temporary occupation. This is made clear in Article 6 of the ruling: “Nothing
in this directive shall be construed as an indication of Allied policy relating to the ultimate
determination of the minor islands referred to in Article 8 of the Potsdam Declaration,” afinal decision on which was to be made in the Peace Treaty. The Korean government’s
claims are consequently unsustainable in international law. It is also worth noting that
nowhere in the various notes and other documents issued by the Korean government isthere any mention of the Rusk letter sent by the US government to the Korean government.
We can confirm the current views of the Korean government regarding the San
Francisco Peace Treaty via the informational internet page “Dokdo, Beautiful Island of
Korea,” hosted on the official website of the Korean Ministry for Foreign Affairs. 13 The
section “Why Dokdo is Korean Territory” contains the following account of the“Conclusion of the Treaty of Peace with Japan”: “The Treaty of Peace with Japan is atreaty which the Allied Powers concluded with Japan at the close of World War II. Article
2 (a) provides that “Japan, recognizing the independence of Korea, renounces all right,
title and claim to Korea, including the islands of Quelpart, Port Hamilton and Dagelet.”
The webpage goes on to say that Among Korea’s approximately 3,000 islands, these threeislands have been referred to as examples, and therefore, the mere fact that Dokdo is notnamed in the said article, does not suggest that Dokdo is not included among those13

See the section “Conclusion of the Treaty of Peace with Japan” under “Why Dokdo is

Korean Territory” part of “Dokdo, Beautiful Island of Korea,” available on the website of the
Korean Ministry of Foreign Affairs: https://dokdo.mofa.go.kr/eng/dokdo/reason.jsp(Accessed June 3, 2021).
9

territories of Korea that have been separated from Japan.”
It is clear that the Korean government today has essentially inherited the views of the
Korean government of the 1950s more or less unchanged. However, there is still no
mention of the Rusk letter, in which the US government informed Korea before the treaty
was signed that the San Francisco Peace Treaty treated Takeshima as Japanese territory.
The current Korean view is therefore also untenable. It is clear from the Rusk letter, theSan Francisco Peace Treaty, and the report of the Van Fleet mission that according tointernational law, Takeshima was retained as Japanese territory after World War II.
Despite this, the Korean government and some scholars in Korea and Japan continue toadhere to the views put out by the Korean government during the 1950s.
Some Korean scholars today maintain that the Rusk letter cannot be considered asvalid evidence — even though it was official diplomatic correspondence sent from the
US government to the government of Korea. In this paper, while continuing to consider
international law, I want to move away from traditional international-law-based
perspectives. Although maps are no more than secondary proof, I will look at official
maps produced by the government of the United States, as a drafter of the treaty, and use
them to consider the treatment of Takeshima in the San Francisco Peace Treaty byanalyzing the US government’s understanding of Takeshima’s geography immediately
after the Peace Treaty came into effect.

2. Details of textual and other information provided on aeronautical charts
Work to retrieve information at the National Archives of the United States has madeit possible to confirm the content of three aeronautical charts produced by the US
government immediately after the San Francisco Peace Treaty came into effect. All three
charts were produced and issued by the US Air Force, and were published in 1953 and1954, one to two years after the Peace Treaty came into effect.
(1) USAF Jet Navigation Chart, (JN-25), Yellow Sea (1954)
The title of this map is “USAF Jet Navigation Chart, JN-25, Yellow Sea,” 9-54, 1stEdition. The publisher is listed as the USAF Aeronautical Chart and Information Center(ACIC), Air Photographic and Charting Service (APCS)—in other words, the map was
published by the US Air Force. The publication date is given as August 1953 and theprinting date is September 1954.

10

Fig. 1 “USAF JET NAVIGATION CHART, (JN-25), YELLOW SEA,” 9-54, 1st EDITION【Collection of the National Archives of the United States】
11

Fig. 2 “USAF JET NAVIGATION CHART, (JN-25), YELLOW SEA,” 9-54, 1st EDITION(Showing the vicinity of Ulleungdo, Takeshima, and Oki Islands)【Collection of the National Archives of the United States】
12

The map has a scale of 1:2,000,000, and shows the western part of the Japanesearchipelago, the Korean Peninsula, eastern China, the Russian Far East, and Mongolia(Fig. 1). In the Sea of Japan, Ulleungdo and Takeshima are shown between the Korean
Peninsula and the Oki Islands (Fig. 2). Ulleungdo is marked with its Korean name, spelled“ULLǓNG DO.” The number 3232 indicates an altitude in feet (equivalent toapproximately 985 meters), showing the elevation above sea level of Seonginbong, thehighest mountain on Ulleungdo, at 984 meters. Takeshima is marked using its Western(originally French) name, as “Liancourt Rock.” Two islands are marked: Ojima (orNishijima, West Island) and Mejima (Higashijima, East Island).
According to the map’s legend, labeled “Aeronautical Legend,” the area to thenortheast of Takeshima marked “D” represents “Danger, Restricted or Warning Area,”and presumably marks a US armed forces training area. Between Takeshima and the Oki
Islands are markings showing the “KOREA ADIZ” and the “JAPAN ADIZ,” or “AirDefense Identification Zone,” as is explained on the map legend.
Takeshima is therefore included within the Korea’s ADIZ. Some people connectedwith the Korean government have claimed that Takeshima is Korean territory based on
this inclusion. However, ADIZs are not an established system in international law, andlack legal underpinning. Generally, an ADIZ is something established internally by eachcountry for air defense. An ADIZ is not considered to define the limits or extent of acountry’s airspace or land territory. Takeshima’s inclusion in the Korea’s ADIZ
consequently cannot be used as evidence in international law for the claim that the islandis part of Korean territory.
A dotted line is marked between Ulleungdo and Takeshima. The area to the northwestof this line is marked “Korea,” and the area to the southeast is marked “Japan.” On thelegend, this type of dotted line is explained as a “Division of Insular Sovereignty (landareas only)” (Fig. 3). In other words, the line marks sovereignty over islands but notsovereignty over maritime areas. At the time, territorial waters extended three nautical
miles, or about 5.6 km from the coast, and everything outside that was international waters.
Consequently, the chart shows that Ulleungdo is Korean territory and Takeshima isJapanese.
(2) USAF Jet Navigation Chart, (JN-26), Sea of Japan (1954)
The title of this aeronautical chart is “USAF Jet Navigation Chart, (JN-26), Sea ofJapan” 12-54, 1st Edition, and the publisher is given as “USAF Aeronautical Chart andInformation Center, Air Photographic and Charting Service.” In other words, it was
published by the US Air Force. The date of publication is July 1953 and the printing date13

is December 1954.
The scale is 1:2,000,000 and the map is centered on the Sea of Japan, showing theJapanese archipelago, South Sakhalin, the Korean Peninsula, Northeast China, and theRussian Far East. In the Sea of Japan, Ulleungdo and Takeshima are shown between the
Korean Peninsula and the Oki Islands (Figs. 4 and 5). Ulleungdo is marked with its
Korean name, spelled Ullungdo. The number 3232 indicates an altitude in feet (equivalent
to approximately 985 meters), and shows the elevation above sea level of Seonginbong,
the highest point on Ulleungdo, at 984 meters. Unlike on Map 1, Takeshima is marked
with its Japanese name, rendered as “Take-shima.” Two islands are shown: Ojima(Nishijima) and Mejima (Higashijima). As on Map 1, the area to the northeast of
Takeshima is marked “D” for “Danger: Restricted or Warning Area,” presumably
indicating a US Forces training area.

14

Fig. 3 “USAF JET NAVIGATION CHART, (JN-25), YELLOW SEA,” 9-54, 1st EDITION(Legend)【Collection of the National Archives of the United States】

Marked between Takeshima and the Oki Islands are the “KOREA ADIZ” and the“JAPAN ADIZ”, showing the Air Defense Identification Zones. As on Map 1, Takeshima
is included within the Korea’s ADIZ. However, in international law this fact cannot be
used as evidence to support the contention that Takeshima is part of Korean territory.
As on Map 1, there is a dotted line between Ulleungdo and Takeshima, marked “Korea”
on the northwest side and “Japan” on the southeast. This dotted line marks “Division of
Insular Sovereignty (land areas only).” In other words, as with Map 1, this chart too shows
Ulleungdo as Korean territory and Takeshima as Japanese.
15

Fig.4 “USAF JET NAVIGATION CHART, (JN-26), SEA OF JAPAN,” 12-54, 1st
EDITION(Coastal regions around the Sea of Japan)【Collection of the National Archives of the United States】

16

Fig.5 “USAF JET NAVIGATION CHART, (JN-26), SEA OF JAPAN,” 12-54, 1st
EDITION(Vicinity of Ulleungdo and Takeshima)【Collection of the National Archives of the United States】

17

Fig.6 “USAF PILOTAGE CHART, (379D) G, TO DONG, JAPAN-KOREA,” 12-53,
1st EDITION Revised“Interchart Relationship”【Collection of the National Archives of the United States】(3) USAF Pilotage Chart, (379D) G, To Dong, Japan-Korea (1953)
The title of this aeronautical chart is “USAF Pilotage Chart, (379D) G, To Dong,
Japan-Korea,” 12-53, 1st Edition Revised. The publisher is the USAF Aeronautical Chart
and Information Center. The publication date is given as November 1943, with revisions
as of June 1953. The date of printing is given as August 1953, with overprinting as ofDecember 1953. The scale is 1:500,000.
Charts like this, on a 1:500,000 scale, together with 1:250,000 charts, make up the
1:1,000,000 World Aeronautical Chart series. Printed on the back of the chart is the“Interchart Relationship” (Fig. 6). Each 1:1,000,000 chart is divided into four sections, A,
B, C, and D, and each section is represented by a 1:500,000 chart. These are then divided
18

in turn into four sections to give the 1:250,000 charts, shown as I, II, III, and IV. At thebottom of the Interchart Relationship, it is written: “Each chart is a component section of
1:1,000,000 World Aeronautical Chart Series, and is indexed within the series as indicatedon diagram.” This 1:500,000 aeronautical chart is numbered 379D, corresponding to thesouthwestern side of the 1:1,000,000 World Aeronautical Chart 379, showing the southernpart of the Sea of Japan.

Fig.7 “USAF PILOTAGE CHART, (379D) G, TO DONG, JAPAN-KOREA,” 12-53,
1st EDITION Revised【Collection of the National Archives of the United States】

On this aeronautical chart, Ulleungdo, Takeshima and the Oki Islands are shown inthe southwestern part of the Sea of Japan (Fig. 7). The text “To Dong” in the title of the
map refers to “Dodong,” located in the southeast of Ulleungdo. Dodong is the island’s
chief town and port that serves as the gateway to Ulleungdo. The Oki Islands are also
shown on the chart, and the map’s title is clearly marked “Japan-Korea,” indicating clearly
19that the map shows parts of both countries. Although the map’s title makes specificmention of Dodong on the Korean island of Ulleungdo, this should not be taken to suggestthat the entire area shown on the map is Korean territory. The map includes not only
Takeshima but also the Oki Islands—so that it can hardly be claimed on this basis that
Takeshima is a dependency of Ulleungdo.14
The two letters on the charts are an alphanumerical code used by US and NATO forces
to indicate coordinates on maps as part of the Military Grid Reference System, or MGRS.
Each 100-kilometer square is indicated by a two-letter reference.15
Ulleungdo is shown using the Korean name for the island, as “ULLǓNG DO(UTSURYŎ-TŎ) Korea” and is specifically marked as Korean territory (Fig. 8). The
number 3228 is in feet (approximately 984 meters), and indicates the 984-meter elevationof Seonginbong, the highest point on the island.
Takeshima is shown using its Western (French) name, as Liancourt Rocks. The
number 515 is in feet, and indicates the highest point at approximately 157 meters, on
Ojima (Nishijima). According to a geological survey carried out by satellite imaging by
the Geospatial Information Authority of Japan in 2007, the highest point on Ojima(Nishijima) is at an elevation of 168 meters. The two symbols “+” (labeled “Charted
Rocks”) shown on Takeshima indicate Ojima (Nishijima) and Mejima (Higashijima).
The practice of marking the highest point on Ojima (Nishijima), one of the two islands
that make up Takeshima, at 515 feet on Japanese sailing directions, maps, charts, andinstructions can be traced back to two publications. The first, dealing with the Korean
coastline, was Nihon Suiroshi Dai-6- kan Chosen Zengan (Japan sailing directions, Vol.
6: Entire coast of Korea) 16 published in December 1911 by Japan’s Hydrographic

14

Korean and some Japanese scholars have used the inclusion of present-day Takeshima onsome nautical charts published by Japan’s Hydrographic Department during the Meiji Era(1868-1912), among them the Map of the East Coast of Korea (Chosen higashi kaigan-zu)
and Map of the Entire Coast of Korea (Chosen zengan) to argue that the Japanese governmentof the time recognized the islands as part of Korean territory. These arguments claim that all
the areas included on a map must belong to the territory of the country named in the title ofthe map. But in order to show clearly the position places marked on the map, some parts ofneighboring countries must naturally be shown as well. Unreasonable arguments along theselines are clearly without basis or proof.
15

Based on information from the Hydrographic and Oceanographic Department, Japan

Coast Guard.
16

It is sometimes claimed by Korean and some Japanese scholars that the Japanese
20Department. For the northwest coast of Honshu, the relevant volume is Honshu engan
Suiroshi Dai-2-kan (Sailing directions for the coast of Honshu, Vol.2), published by the
Hydrographic Department in 1931. The first of these says: “The westerly of the twoislands rises to 515 feet above sea level in a sugar cube shape” (p.49), while the latterreads: “The westerly islet has a height of 157 meters, and forms a sharp pinnacle” (p.54).
Subsequent records reproduce these figures, which were based on an actual survey carriedout by the Hydrographic Department in August 1908.17
Nihon Suiroshi Dai-4-kan (Japan sailing directions, Vol.4) published by the
Hydrographic Department in 1916, and providing sailing directions for the northwest andnorth coast of Honshu, notes that Takeshima was “incorporated into Shimane Prefecture
in Year 38 of Meiji” (p.58), recording Takeshima’s formal incorporation into Shimane
Prefecture in 1905. All subsequent publications, with the exception of the abridged editionof May 1945 (Kan’i suiroshi Honshu engan Dai-2-kan), reproduce the same text.

government recognized Takeshima as part of Korean territory based on the inclusion of theislands in sailing directions for the Korean coast published in Japan. But the publication inquestion, Nihon Suiroshi Dai-6-kan Chosen Zengan, published by the Hydrographic
Department in December 1911, also includes other places clearly not intended to beconsidered as part of Korean territory: Chapter 3 on the South Coast of Korea lists details on
the Tsushima Strait, Western Channel and Eastern Channel (pp. 202–203), and Chapter 5,West Coast North Section (Korea) includes in its section on the Yalu River references toDadonggou (p. 628) on the west bank of the mouth of the Yalu River, which is Chinese
territory (now Donggang, Dandong, in Liaoning Province). In other words, the directions
included places that were not under the jurisdiction of the colonial Korean Government
General. This makes it clear that information provided in sailing directions does notnecessarily coincide neatly with geographical or administrative boundaries.
17

Based on the “Ledger of Latitude and Longitude Measurements of Markers (本標実測経緯

度原簿)” in the collection of the Hydrographic and Oceanographic Department, Japan Coast
Guard, consulted in March 2012.
21

Fig.8 “USAF PILOTAGE CHART, (379D) G, TO DONG, JAPAN-KOREA,”
12-53, 1st EDITION Revised(Vicinity of Ulleungdo and Takeshima)【Collection of the National Archives of the United States】
22

Two memoranda drawn up on July 13 and 16, 1951, by Samuel Boggs, geographer at
the US Department of State during the drafting of the peace treaty, quote US
Hydrographic Office Publication No. 123A, Sailing Directions for Japan, Volume I (1sted., 1945). Page 597 of the publication says of “Take Shima (Liancourt Rocks)” that “thewestern and highest has a pointed summit, which rises 515 feet.”
After Yang Yu-chan, Korean ambassador to the United States, sent his request to the
US government regarding the final draft of the peace treaty on July 19, 1951, Boggs
submitted an office memorandum on July 31 on the subject of “Parangdo and Dokdo(islands).” The memorandum was addressed to Robert A. Fearey, an assistant to John
Foster Dulles, a special advisor to President Harry Truman, who was handlingnegotiations on the peace treaty at the State Department. The memo cited US
Hydrographic Office Publication No.122B, Sailing Directions for the Southeast Coast of
Siberia and Korea, from Sakhalinskiy Zaliv(Sakhalin Gulf)to the Yalu River including
Sakhalin (1st ed., 1947). Pages 535 and 536 of Publication No. 122B contained an entry
on “Liancourt Rocks (Take Shima)” that was very similar to a passage in the previously
mentioned Publication No.123A, Sailing Directions for Japan, Volume I.
This allows us to confirm that the US Department of State referred to sailingdirections compiled by the US Hydrographic Office during the drafting of the peace treaty.
It also allows us to confirm, from the information given regarding the highest point on
Ojima (Nishijima) as 515 feet, that the US Hydrographic Office referred to the suiroshi(sailing directions) published by the Japanese Hydrographic Department. It is likely thatin compiling its aeronautical charts, the US Air Force referred to the sailing directions
published by the US Hydrographic Office, with the US Hydrographic Office directions
based on the information in the suiroshi (sailing directions) published by the Japanese
Hydrographic Department.
In the office memorandum sent to Fearey on July 31, 1951, on “Parangdo and Dokdo(islands),” Boggs wrote: “In response to your telephone requests for information
regarding Dokdo and Parangdo, two islands which Korea desires to have Japan renouncein favor of Korea in the treaty of peace, we have tried all resources in Washington which
we have thought of and have not been able to identify either of them. . . . [Ulleungdo] is
the Korean name corresponding to the name conventionally used in English, Dagelet
Island, and to the Japanese name Utsuryo To. That island is found on available maps andcharts, by all three names, in approximately 37° 30' N. latitude, 130° 52' E. longitude.”This shows that during the drafting of the San Francisco Peace Treaty, officials at the
US Department of State hunted through all the sailing instructions, maritime charts, andmaps available in Washington in search of the Korean name of Dokdo. In fact, no island
23

labeled as “Dokdo” appears on any Korean-drawn map of the Korean Peninsula produced
before 1950.
As on Map 1, the “Danger Area” shown to the northeast of Takeshima is presumably
a US Armed Forces training area. Between Takeshima and the Oki Islands are the“KOREA ADIZ” and the “JAPAN ADIZ.” As I explained for Map 1, ADIZ stands for“Air Defense Identification Zone.” As with Map 1, Takeshima falls within the Korea’s
ADIZ on this chart, but in international law this cannot be used as evidence for a claimthat Takeshima is Korean territory.

Fig.9 “USAF PILOTAGE CHART, (379D) G, TO DONG, JAPAN-KOREA,” 12-53,
1st EDITION Revised “TOPOGRAPHIC SYMBOLS (CULTURAL and
MISCELLANEOUS [FEATURES])”【Collection of the National Archives of the United States】

Between Ulleungdo and Takeshima is a dotted line: the area northwest of this ismarked “Korea,” and the area southeast as “Japan.” According to the legend on thereverse of the map, which gives an explanation of “Topographical Symbols (Cultural andMiscellaneous) [Features],” this two-point chain line marks “international” boundaries.
In fact, on the legend, “international" boundaries are shown with a belt of dots around thetwo-point chain line. At first glance, the line on the map in question might look more likea “State & Provincial” boundary marker than an indication of an “international” boundary
24

(Fig. 9). However, it seems fair to say that this two-point chain line does indeed represent
an international boundary. In 1953, the boundary between Korea and Japan was clearly
an international boundary, and similar dotted lines can be found representing internationalboundaries on other US-produced aeronautical charts from the same series. For example,
a US Army 1:1,000,000 map that is in the author’s collection — “World Aeronautical
Chart, (613), Niitaka Mountain, China-Nansei-Islands-Philippines,” 11-52, 8th Edition,
printed in June 1952 and with overprinting in November 1952 — uses the same two-point
chain line to mark the international boundary in the Bashi Channel between the Republicof China (Taiwan) and the Philippines (Fig. 10). As with Map 1, therefore, this chart toomarks Ulleungdo as Korean territory, and Takeshima as Japanese territory.

25

Fig.10 “WORLD AERONAUTICAL CHART, (613), NIITAKA MOUNTAIN, CHINANANSEI-ISLANDSPHILIPPINES,” 11-52, 8th EDITION(US Army) (Vicinity of Bashi Channel)【Author’s Collection】

26

3. Comparisons with previous editions of relevant aeronautical charts
I will next analyze the information that was recorded on previous editions of relevant
aeronautical charts to confirm whether the details provided on our three maps about
Takeshima reflect the content of the San Francisco Peace Treaty after it came into effectin 1952.
Starting with Map 1, a previous edition of this is available, albeit in a 1:3,000,000
scale, as “U.S. Army Air Forces Long Range Air Navigation Chart, (LR-17), Yellow Sea,”
11-50, 8th Edition Revised. This chart was printed in November 1950, with overprinting
as of March 1953. For Map 2, however, no post–World War II aeronautical chart showing
this section of the Sea of Japan was published before 1954. According to the Series Index(Fig. 11) that serves as an index map for the 1:3,000,000 aeronautical LR series, Map LR18, to the east of LR-17, covers the eastern side of the Japanese archipelago.
Although the chart (LR-17) was published directly after the peace treaty came into
effect and shows the “KOREAN ADIZ” and “JAPAN ADIZ” in the western region of the
Sea of Japan, it does not mark Takeshima or the international boundaries between islands,
and is therefore not suitable for comparison. An older edition is available, in the form of“U.S. Army Air Forces Long Range Air Navigation Chart, (LR-17), Yellow Sea,” 6-50,
7th Edition Revised (Fig. 12). This chart was printed in June 1950, with overprinting asof October 1950. On this chart, KOREAN and JAPANESE ADIZs are not shown in thewestern region of the Sea of Japan, and the only information marked for Takeshima is its
Western (French) name “Liancourt Rocks,” the number 515, marking the elevation of its
highest point in feet, and the text “Danger Area,” presumably denoting a US Forces
training area (Fig. 13).
Incidentally, SCAPIN 1778, issued on September 16, 1947, during the occupation ofJapan, designated Takeshima as a US Armed Forces bombing range, and it is likely thatthe chart reflects this fact. No international boundaries are shown in the vicinity ofTakeshima. Similarly, the 1:3,000,000 aeronautical chart (LR-17) Yellow Sea, 7th Edition(printed March 1948, with overprinting as of March 1950) and 6th Edition (printed March
1948, with overprinting of aerial information as of June 1948) carry the same text as therevised 7th Edition (printed June 1950, with overprinting as of October 1950), and do notshow international boundaries in the vicinity of Takeshima. Takeshima is not shown on
the 5th Edition (printed August 1947, with overprinting of aerial information dated backto June 1947, and re-issued December 1947), or on the previously cited 8th Edition(printed November 1950, with overprinting as of March 1953). Similarly, there is no text
to indicate KOREAN or JAPANESE ADIZs.
27

An older edition of Map 3 is “AAF Aeronautical Chart, (379D) G, To Dong, Central
Japan,” 3-51, 1st Edition, in the same 1:500,000 scale (Fig. 14). KOREAN andJAPANESE ADIZs are not marked in the western region of the Sea of Japan. There is no
marking to indicate international boundaries in the vicinity of Takeshima, where the only
text is the Western (French) name of “Liancourt Rocks,” the number 515 indicating theelevation of the highest point in feet, and the warning “Danger Area,” presumably
indicating the presence of a US military training area (Fig. 15). It is important to note that,as with the 1:3,000,000-scale map described earlier (LR-17, Yellow Sea, 7th Edition
Revised) that was printed in June 1950 with overprinting as of October 1950, this map(1:500,000, (379D) G, 1st Edition, To Dong, March 1951) does not show any internationalboundaries between the small islands. The same is true of two other editions. The 3rd
Edition of the 1:500,000 chart (379D), To Dong, (printed September 1950 with
overprinting as of October 1950, and printed February 1951 with overprinting as of March
1951) only has “Liancourt Rocks,” the altitude of its highest point, and the text “Danger
Area,” while the revised 2nd Edition of the 1:500,000 chart (379D), To Dong, (with aerial
information as of December 1945) carries only the name “Liancourt Rocks.” Neither ofthese maps carries any indication of international boundaries in the vicinity of Takeshima.

28

Fig.11 “U.S. ARMY AIR FORCES LONG RANGE AIR NAVIGATION CHART, (LR17), YELLOW SEA,” 3-53, 8th EDITION “SERIES INDEX”【Collection of the National Archives of the United States】

29

Fig.12 “U.S. ARMY AIR FORCES LONG RANGE AIR NAVIGATION CHART, (LR17), YELLOW SEA,” 10-50, 7th EDITION Revised【Collection of the National Archives of the United States】

30

Fig.13 “U.S. ARMY AIR FORCES LONG RANGE AIR NAVIGATION CHART, (LR17), YELLOW SEA,” 10-50, 7th EDITION Revised(Vicinity of Ulleungdo, Takeshima, and Oki Islands)【Collection of the National Archives of the United States】
31

Fig.14 “AAF AERONAUTICAL CHART, (379D) G, TO DONG, CENTRAL JAPAN,”
3-51, 1st EDITION【Collection of the National Archives of the United States】

32

Fig.15 “AAF AERONAUTICAL CHART, (379D) G, TO DONG, CENTRALJAPAN,” 3-51, 1st EDITION(Vicinity of Ulleungdo and Takeshima)【Collection of the National Archives of the United States】
33

These two aeronautical charts (Fig. 12 and Fig. 14) were published immediately
before the signing of the San Francisco Peace Treaty. The map shown in Fig. 12 wasreleased in October 1950 as an overprint, and the map shown in Fig. 14 was released in
March 1951 in a new printing run. On aeronautical charts dating from just before thesigning of the Peace Treaty, no international boundaries between islets are shown in thevicinity of Takeshima. This presumably shows that the boundaries of Japan’s territory
were not yet legally fixed before the peace treaty came into effect. This fact too cantherefore be taken to mean that Maps 1, 2, and 3 show the US government’s understandingof geography directly after the peace treaty came into effect, and likely reflect theintended content of the peace treaty as well.

4. Conclusion
All three aeronautical charts examined in this paper, published in 1953 and 1954, were
produced and published immediately after the San Francisco Peace Treaty came into
effect in 1952, and were drawn up by the US Air Force. They are therefore official maps
produced and published by the United States government. It is consequently possible touse them to gain an insight into the US government’s understanding of geography at thetime.
On the three maps, KOREAN and JAPANESE ADIZs are shown between Takeshima
and the Oki Islands. People connected with the Korean government and scholars on the
Korean side have argued that these ADIZs show that Takeshima was recognized as
Korean territory. However, an ADIZ is a domestic measure established by a country for
air defense purposes, and is not considered to define the limits or range of a country’s
territorial air or land space. In the same way, international boundaries are shown in the
Tsushima Strait Western Channel between Tsushima and Busan, and between the Goto
Islands and Jeju Island. These boundaries are shown separately and are clearly
distinguished from the ADIZs. The marking of ADIZs on these maps cannot therefore beused as evidence showing sovereignty over Takeshima.
It was also possible to confirm that Takeshima is shown as Japanese territory on thesecharts because all three aeronautical charts mark the Korea/Japan international boundary
between Ulleungdo and Takeshima. From the textual and other information marked onthese aeronautical charts produced by the US Air Force, we were able to confirm that the
US government recognized Takeshima as Japanese territory. Since these charts were
published in 1953 and 1954, just after the San Francisco Peace Treaty came into effect, it34

is reasonable to conclude that the information given on these charts reflects the content
of the San Francisco Peace Treaty.
Comparisons of the textual information on the charts with previous editions revealthat information listed on previous editions of Map 1 and Map 3 was limited to anindication of Takeshima using its Western (French) name as “Liancourt Rocks,” thenumber 515 indicating the elevation of the highest point in feet, and the text “Danger
Area,” presumably indicating a US military training area. We were able to confirm thatno international boundaries were marked on the maps in the vicinity of Takeshima. These
aeronautical charts were issued immediately before the signing of the San Francisco
Peace Treaty. No international boundaries are shown between the islands on aeronauticalcharts published before the peace treaty came into effect, probably because they date frombefore when the boundaries of Japanese territory were legally fixed and finalized in thetreaty. Our recent research also showed that the content of SCAPIN 677, which reflected
the policy of the Supreme Commander for the Allied Powers during the occupation andwas not a final decision on Japanese territory, was not reflected in textual or otherinformation printed on charts that were published before the San Francisco Peace Treaty
came into effect. This further supports the view that these three aeronautical charts
published in 1953 and 1954 reflect the US government’s understanding of geography
immediately after the peace treaty, and reflect the intentions and content of the peace
treaty.
The Korean government makes a number of claims: that Dokdo was recognized as
Korean territory in the San Francisco Peace Treaty as a dependency of Ulleungdo, thatthe territories named in the treaty are merely a partial list, and that Dokdo was intended
to be among the territories to be relinquished by Japan. But the fact is that theseaeronautical charts drawn up by the government of the United States, one of the draftersof the treaty, immediately after the treaty came into effect, marked the internationalboundary between Ulleungdo and Takeshima, with Ulleungdo shown as Korean territory
and Takeshima as Japanese. In light of these charts, we may conclude that our researchfirmly and unmistakably disproves the claims of the Korean government.
The views of the US government were also made clear in the official report of the Van
Fleet mission, written in August 1954:
When the Treaty of Peace with Japan was being drafted, the Republic of Korea
asserted its claims to Dokdo but the United States concluded that they remained
under Japanese sovereignty and the Island was not included among the Islands thatJapan released from its ownership under the Peace Treaty. The Republic of Korea
35

has been confidentially informed of the United States position regarding the islands
but our position has not been made public. Though the United States considers thatthe islands are Japanese territory, we have declined to interfere in the dispute. Our
position has been that the dispute might properly be referred to the International
Court of Justice and this suggestion has been informally conveyed to the Republicof Korea.
The Van Fleet mission report confirms that the US government’s view that Takeshima
was Japanese territory did not change between the signing and coming into effect of thepeace treaty and the publication of the aeronautical charts we have studied in this paper.
The significance of these three aeronautical charts is that they can be understood toreflect the US government’s understanding of geography immediately after the San
Francisco Peace Treaty came into effect. It is therefore reasonable to assume that thecharts reflect the intended content of the San Francisco Peace Treaty and the Rusk letterthat supplements the treaty. This is the first time it has been possible to confirm that
Takeshima was shown as Japanese territory on maps produced by the US government
soon after the San Francisco Peace Treaty came into effect. The claims of the Korean
government—that the territorial provisions in the San Francisco Peace Treaty merely
represent an incomplete and illustrative listing, that Takeshima was a dependency of
Ulleungdo, and therefore regarded as part of Korean territory together with Ulleungdo—
have therefore been discredited and disproven by the charts uncovered at the National
Archives of the United States. In international law, Takeshima cannot be claimed as
Korean territory, and our research reconfirmed that Korea is illegally occupying
Takeshima. Maps can never be more than a secondary source of proof in international law.
Nevertheless, it is fair to describe these charts as an important resource that supports
Japan’s claims that Takeshima was retained as Japanese territory after World War II, bymeans of the San Francisco Peace Treaty and the Rusk letter that supplemented it.1818

18

A rebuttal from the Korean side was reported by Yonhap News in Korea on October 23,

2020, the day the Japan Institute of International Affairs issued a press release about the US
aeronautical charts discussed in this paper. My response to the Korean rebuttal was
published on the website of the Japan Institute of International Affairs on December 10,
2020 as “On U.S. Government Aeronautical Charts Published in 1953 and 1954 Indicatingthat Takeshima Is a Japanese Territory—Rebuttal to the October 23, 2020 reporting of
Korea’s Yonhap News Agency” https:// www.jiia.or.jp/column/20201210-takeshimaaddendum.html
36

We will continue our research in archives and libraries and continue to study more maps
and charts published in the United States, United Kingdom, and other countries involvedin the drafting of the San Francisco Peace Treaty.

[Postscript]
During the writing of this paper, I benefitted greatly from the assistance provided bythen division head Yo Iwabuchi (now managing director at the Japan Hydrographic
Association) and division head Tetsuichiro Yabuki, both of the Hydrographic andOceanographic Department at the Japan Coast Guard. I would like to express my gratitude
for their help. I dedicate this paper to the memory of Hiroyuki Sakata, Sankei Shimbun
newspaper’s Matsue Bureau Chief, who passed away suddenly on March 20, 2021, at theage of just 43. For many years, Mr. Sakata made important contributions to research andreporting on Takeshima, particularly on US aeronautical charts and Edo period
geographer Sekisui Nagakubo’s map of Japan.
This paper is an edited and expanded version of “Appendix 1: Summary of Findings
from US Government Aeronautical Charts Published in 1953 and 1954 Indicating that
Takeshima Is a Japanese Territory (written by Rikinobu Funasugi),” originally prepared
for a press release by the Japan Institute of International Affairs at Shimane Prefecture’s
Takeshima Reference Room on October 23, 2020. This paper represents part of the resultsof two research projects undertaken by Shimane University on behalf of the Japan
Institute of International Affairs: “Geographical Research on Takeshima as Seen on Old
Maps (Including Compilation of a Database of Old Maps and a Written Report),” forfiscal 2019 and fiscal 2020.
Released April 26, 2021
Revised February 13, 2022

37