FAST-FIN-1 Finnish Institutions Papers
Finnish Territorial Waters and Naval Surveillance
Pekka Snellman (Autumn 2004, UK)
A FAST-FIN-1 (TRENPP2C) Finnish Institutions Student Paper
FAST Area Studies Program
Department of Translation Studies, University of Tampere

Finland is a maritime state. More than 30 percent of Finland's national borders are at sea. Over 75 percent of Finland's foreign trade enters or leaves the country through its seaports. Vessel traffic in the northern part of the Baltic Sea has grown rapidly in the last decade, particularly the east- and westbound traffic in the Gulf of Finland. It is increasingly important for Finnish national security authorities to have access to accurate, comprehensive and up-to-the-minute situation data of the vessel traffic at sea. The system for collecting, processing and distributing this data involves the co-operation of a number of authorities, the main actors being The Frontier Guard, The Defence Forces and The Finnish Maritime Administration.

What are the current issues facing the Finnish territorial surveillance capacity? What is the purpose of naval surveillance? This paper describes the maritime environment of Finland, its territorial waters and the special characteristics of the northern Baltic Sea. It introduces the naval surveillance system of Finland and describes the roles of the different actors, with the emphasis on The Finnish Navy. The concepts and procedures of the surveillance and protection of Finland's territorial integrity are also introduced, with particular attention to the legislative background. The focus will be on surface vessel traffic; although matters concerning underwater and air surveillance are an integral part of the Finnish naval surveillance system, they are beyond the scope of this paper.

Finland's Maritime Environment

Approximately 1,250 kilometres of Finland's national borders are at sea (Frontier Guard). The coastline of Finland, however, is more than 4,600 kilometres long. Adding to the fragmented nature of the coast are more than 81,000 islands, counting only those with an area exceeding one acre. Counting by the number of islands (17,000), the archipelago of the Archipelago Sea1 is the largest in the world (Kouvolan Tietopalvelut). The Baltic Sea is very shallow for its size. Its mean depth is only 60 metres, in the Gulf of Finland 38 metres and in the Gulf of Bothnia 43 metres (Österlund and Viitasalo 9). The dense archipelago and shallow waters make navigation and surveillance of the Finnish coastline exceptionally challenging.

The Finnish territorial waters lie for most part north of the 60th latitude. In the winter the whole Finnish coastline normally always freezes, including the Gulf of Bothnia and the Gulf of Finland (Österlund and Viitasalo 13). The whole Baltic Sea, including the Polish and German coasts, has been ice-covered on only two occasions in the 20th century2. Normally, however, only the northern parts of the Baltic will be completely covered with ice. The ice stays on the coasts of Finland for up to five months in the north, but for a considerably shorter period in the south. During the winter months, foreign vessels in particular are entirely dependant on the service of the Finnish icebreaker fleet (Kouvolan Tietopalvelut).

The arctic climate together with the shallow water makes the natural environment in the northern part of the Baltic Sea extremely vulnerable. At the same time, the Baltic Sea has an increasingly important role as a shipping route, in particular for Russia's oil exports. Oil shipments through the Gulf of Finland have risen even more rapidly than forecast and are expected to reach 190 million tonnes by 2010 (Tukkimäki); the number of ships visiting oil harbours in the Gulf of Finland (see Picture 5) has doubled since 2001. The size of the tankers has also increased in recent years. A tanker size between 75,000 to 100,000 gross tonnes is most common in the Baltic Sea (Tukkimäki), which is small in comparison with ocean-going super tankers, but quite large considering the size of the Baltic Sea. An oil spill, even a smaller one by global standards, would in the Baltic conditions have catastrophic consequences for the environment as well as for the economy of Finland, as shipping in the polluted area would be seriously obstructed.

Finland is highly dependent on shipping for its foreign trade. In 1999, 76 percent of its foreign trade (both imports and exports) went through Finnish seaports. The share of shipping is even more predominant with Finnish exports, reaching 91 percent (Tulli). Furthermore, the military security environment in the Baltic Sea area has gone through dramatic changes in the last 15 years, the most recent change having been the accession to NATO membership of Estonia, Latvia and Lithuania in May, 2004. The Baltic Sea is of military interest to Russia as well: it is vital both as an oil export route and as a supply route for Russia's second largest city, St Petersburg. Thus Finland, a member of the European Union and the Schengen Agreement, needs to pay special attention to its border surveillance at sea. It is a matter of national interest for Finland, and for the European Union as well, to protect the safety and integrity of its shores.

The Finnish Territorial Waters and Sea-Borders

Finnish territory consists of the land and sea area within its national borders, and the territorial sea and the airspace above them (Finlex, Laki). The basis for the formation of the Finnish territorial waters is the outmost landmarks of the coastline and archipelago, either on the mainland or on islands. Even a rock, however small, which protrudes above the mean sea-level also counts as a landmark (Finlex, Decree). These outmost landmarks form base points for the border to follow (see Picture 1). A conceptual line drawn over 177 of these base points forms the inner boundary of the Finnish territorial sea.3 The sea areas within this line comprise Finland's internal waters, sometimes also called the inner territorial sea. The inner boundary of the Finnish territorial sea is thus also both the outer boundary of the internal waters and the Finnish national border at sea, with a few exceptions (see below). The outer border of the territorial waters is a line at a distance of 12 nautical miles from the inner border, where not restricted by the proximity of the national border at sea or geographical features (see below). The sea area between these two borders is called the territorial sea (Finlex, Laki).

Picture 1. Simplified graphic of territorial waters and sea-borders on the Finnish coast. © Pekka Snellman.
The graph shows the principle of how the borders are drawn and their respective names.
A neighbouring country is shown in yellow in this illustration.

The Finnish national border at sea deviates from the route of the outer boundary of the internal waters in the areas adjacent to the national borders with Russia and Sweden. The naval national border with Sweden, established in 1811, lies in the Bay of Bothnia and also west of the Åland Islands, and measures 48 kilometres in all. In other areas of the Gulf of Bothnia and the Archipelago Sea, the border towards Sweden consists of the outer border of the territorial waters. The Russian naval border, established in 1940 and more accurately defined in 1965, lies at the eastern end of the Gulf of Finland and is 54 kilometres in length (Rajavartiolaitos).

The Finnish territorial sea in the Gulf of Finland does not extend closer than 3 nautical miles from the middle line of the Gulf. This arrangement was made in 1994 between Finland and Estonia (it applies likewise to the Estonian territorial sea border) to facilitate free transit shipping in the Gulf of Finland (Österlund and Viitasalo 15-16). In other words, there is a 6 nautical miles-wide shipping channel in the middle of the Gulf of Finland (see Picture 5).

Having 12 nautical miles of territorial waters extending out from the national border is a common method of defining national territory; most of Finland's neighbouring countries in the Baltic Sea have adopted this practise as well. This definition of territorial waters gives the borders a distinct shape and makes them easier to follow and supervise. The territorial sea of Finland was considerably narrower prior to 1995. The current width of the territorial sea, 12 nautical miles, entered into force on August 2, 1995 (Finlex, Decree). A wider territorial sea makes the supervision of vessel traffic entering and departing the country easier. The time between entering or exiting Finnish territory and crossing the national border is longer. This increases the allowed response time of the surveillance authorities. The concept of the territorial sea helps the surveillance authorities in distinguishing between lawful traffic near the coast from illegal activities across the border, such as smuggling and illegal immigration (Österlund and Viitasalo 15).

The Finnish legislation defining Finland's borders at sea is based on international law and treaties (Finlex, Decree [Section 2]; Finlex, Aluemerta). Also, maritime border matters with neighbouring Russia and Sweden are uncontroversial and clearly defined in law. In addition to the borders and areas mentioned above, there are also many other borders and specially defined areas at sea. These borders, such as customs lines, limits of fishing areas and military restricted areas, are each defined separately and relate to the respective authorities. As such, they are not a part of the territorial surveillance covered by this paper.

Naval Surveillance Authorities

The authorities responsible for conducting the surveillance of the Finnish territorial waters are listed in the Territorial Surveillance Act (Finlex):

The territorial surveillance authorities are the military, frontier guard, police and customs authorities and officials assigned to territorial surveillance. The Finnish Maritime Administration and the Finnish Civil Aviation Administration shall act as territorial surveillance authorities within their respective spheres of competence, and they shall be considered equal to the territorial surveillance authorities referred to in paragraph 1 unless otherwise provided hereinafter. The Ministry of Defence shall direct and coordinate the activities of the territorial surveillance authorities in matters falling under this Act, subject to the competence of the Supreme Commander of the Defence Forces.
This definition lists the authorities responsible for the surveillance of all of Finland's national borders, where the coordinating body with the overall responsibility is the Ministry of Defence. In the sphere of naval surveillance, airspace excluded, three actors are especially important: The Frontier Guard, The Navy (a part of the Defence Forces), and the Maritime Administration. The Finnish naval surveillance system is a close co-operation of these three authorities. The overall responsibility for the naval surveillance of the Finnish Territorial waters lies with the Headquarters of the Navy (subordinate to the Ministry of Defence). In the words of the Territorial Surveillance Act (Finlex):
The military authorities are responsible for the implementation of territorial surveillance and the cooperation of the territorial surveillance authorities. The Frontier Guard authorities are responsible for territorial surveillance in conjunction with their duties related to border surveillance and border controls in their surveillance area. Other territorial surveillance authorities shall participate in territorial surveillance in conjunction with their duties. They shall report any territorial offence or territorial violation or any threat thereof to a military or Frontier Guard authority and, using all means available to them, take measures to prevent such territorial offence or territorial violation.
The Finnish police and the Customs authorities also have a minor role in the actual territorial or naval surveillance, their area of duty concerning more Finland's internal security. The role and duties of the three main actors in naval surveillance are:

The Frontier Guard

The Frontier Guard has the aim of maintaining peaceful and safe conditions in the border areas of Finland. The main tasks include border control and border checks as well as border surveillance. The Frontier Guard is also in charge of the maritime rescue services in Finland. For its maritime duties, the Frontier Guard is organised into two Coast Guard districts with 27 coast guard stations, and can deploy seven patrol ships and a number of smaller patrol craft (Frontier).

The Maritime Administration

The Finnish Maritime Administration's field of duty is the surveillance, co-ordination and recording of commercial vessel traffic. All merchant ships trafficking regular routes in Finnish waters report in to the surveillance systems operated by the Maritime Administration, either manually or automatically. However, all other ships exceeding certain size or tonnage limits must report in as well. The surveillance systems are the Vessel Traffic Service (VTS) and the Gulf of Finland Mandatory Ship Reporting System (GOFREP). These systems operate much like an air-traffic-control system for shipping, ensuring smooth and safe trafficking in narrow fairways and ports (Finnish Maritime: Alusten, GOFREP and VTS).

The Navy

The Navy has overall responsibility for the surveillance and protection of territorial integrity in Finnish waters. For this purpose, the Navy maintains a high peacetime readiness and defence capability (Puolustusvoimat). The main task of the Navy is the protection of maritime traffic. This requires gathering, co-ordinating and distributing the surveillance data provided by different sensors to form a comprehensive situation awareness, as well as the capability of detecting and identifying all targets within, or in the proximity of, Finnish territory. The Navy's defence and protection capability is based on fixed and mobile coastal troops and naval task units, supported by the Air Force (Finnish Defence). The Navy has two Naval Commands and a Coastal Command available for its surveillance duties.

The above authorities operate in very close co-operation in naval surveillance matters. Their tasks do not overlap, but support each other. For instance, each authority has its own radar network, which can be used as a back-up system for the other authority should their system fail. Furthermore, all Navy and Coast Guard vessels collect surveillance data when at sea. Well worth noting is that all costs incurred from the naval surveillance activities must be allocated within the budgets of the respective authorities (Finlex, Territorial). In other words, there is no separate allocation for surveillance duties. This encourages the surveillance authorities toward cost-effectiveness. The combined aim of the co-operating naval surveillance authorities is to maintain a real-time awareness of the situation in the Finnish territorial waters.

The Naval Surveillance System

The task of naval surveillance consists of detecting, identifying and tracking all vessel traffic within Finnish territory. The traffic in the internal waters, that of pleasure craft in the summer in particular, is of secondary importance to the naval surveillance system. The main focus of surveillance lies in the territorial sea and all craft crossing the national border, especially when entering the country.

The surveillance authorities work in close co-operation, sharing their surveillance data with one another. In the naval surveillance system, vessels at sea are called "targets". One division of responsibility between the three main actors, if one were to be found, would be the focus on different categories of targets. The Frontier Guard, being in charge of both border control and the maritime rescue services, as well as having some duties with environmental surveillance (Frontier Guard), is particularly interested in civilian and pleasure craft. The Maritime Administration is, apart from traffic control in harbours and narrow fairways, exclusively interested in merchant vessels, as well as other ships exceeding set size limits (see Table 1).

The Navy, on the other hand, has as its main point of focus government vessels, that is, all ships that fall within the category of 'a military, frontier guard, police or customs vessel or a vessel which is mainly used for government purposes other than merchant shipping' (Finlex, Territorial).

The surveillance itself is done in a similar way by all three authorities, and consists of detecting, identifying and tracking targets. In a broader context, the surveillance process would include the collecting, processing and distributing of the surveillance data as well, with the 'final product' being the situation awareness provided to the user of the collective surveillance data.

Detection and Identification

All targets approaching the Finnish territorial waters are detected by radar. The Navy, the Coast Guard and the Maritime Administration all have their own radar networks, which provide uninterrupted and comprehensive radar coverage of the territorial waters. The radar systems partly back up each other, and have some back-up systems of their own. In addition to the radar systems, the Navy and the Coast Guard have passive sonar and electronic intelligence systems for the detection of targets.

When a target is detected in, or immediately approaching, Finnish territory, it is subject to identification. The most common method of identifying a target is by visual recognition, either by a manned surveillance station (see Pictures 2 and 3), a camera or a Navy or Coast Guard vessel. On rare occasions the assistance of the Finnish Air Force may be needed to identify a naval target visually. In poor visibility the most common practise is to contact an unidentified ship by radio. If a ship can't be identified as a government vessel, it is considered a merchant vessel. All underwater vessels are considered warships until identified otherwise (Finlex, Government).

       

Picture 2 (Above left). Targets are identified visually whenever possible. (Source: http://www.mil.fi/.)
Picture 3 (Above right). A manned surveillance station on the Finnish coast. (© Ilmatorjuntaupseeriyhdistys ry.)

The vast majority of targets are normally already identified before they enter Finnish territorial waters. This is done automatically by the Automatic Identification System (AIS) for commercial vessels (Finnish Maritime Administration), by obtaining the identification data from the neighbouring countries' surveillance authorities, or by the ships themselves reporting in to the surveillance authorities.4

  Passport control Customs declaration VTS GOFREP
Pleasure craft X* X* 20 m or longer 300 tonnes or more
Commercial vessel X* X 20 m or longer 300 tonnes or more
      Note: All vessels 12 m or longer with a VHF radio must listen to the VTS channel. Note: All vessels must report in when not under command or when manoeuvrability is impaired.

Note: Government vessels have special regulations for entering Finnish territorial waters.5
* Unless coming from a country of the EU applying the Schengen Agreement.
Table 1. Reporting duties for pleasure and commercial vessels, including size and tonnage limitations.
(Source: Frontier Guard, Finnish Maritime Administration)

Tracking and monitoring

After detection and identification, or while being identified, targets are monitored and tracked for as long as they remain at sea in Finnish territorial waters. The tracking and monitoring is done automatically by radar and visually by camera, by the manned surveillance stations and/or by a surveillance ship at sea. The units producing the surveillance data — a radar unit, a camera, a Coast Guard of Navy patrol ship or a coast artilleryman in a surveillance tower — are called "sensors". The data (bearing, range, course, speed etc.) gathered by the sensors is automatically collected and fed into a database of actively monitored targets. There can be as many as several hundred targets under simultaneous surveillance (Finnish Defence Forces).

The situation data of the surveillance databases can be easily accessed, monitored and processed by a computer interface. The situation data can also easily be distributed in a matter of seconds to provide decision makers on all levels with up-to-the-minute situation awareness. The Naval Surveillance Centres of the Navy are responsible for collecting and distributing the surveillance data. Their names, locations and zones of responsibility are shown below in Picture 4.

Picture 4. The Naval Surveillance Centres on the Finnish coast with their zones of responsibility.
(MEVAKE stands for Merivalvontakeskus, or "Naval Surveillance Centre")
Copyright: Finnish Defence Forces, 2004 (Source: Turun Rannikkopatteriston esittely)

Picture 5. The Gulf of Finland Reporting System (GOFREP). This picture shows the free transit shipping lane
in the middle of the Gulf of Finland, as well as some of the larger ports in the area.
Source and copyright: Finnish Maritime Administration 2004.

Surveillance and Protection of Territorial Integrity, Use of Force

As stated above, the Navy has the overall responsibility for coordinating the co-operation of the surveillance authorities. In its main task of maritime surveillance, the Navy must also take into account the possibility of territorial violations and how to react to such violations. The concepts of the surveillance and protection of Finnish territorial integrity are defined in the Territorial Surveillance Act as follows (Finlex):

Surveillance of Finland's territorial integrity refers to the activity of the territorial surveillance authorities which is carried out primarily at Finland's borders to prevent, expose and investigate territorial offences and territorial violations;

Protection of Finland's territorial integrity refers to the use of force or other means adopted by the Defence Forces and other territorial surveillance authorities to prevent or repel territorial violations.

Territorial violations are thus violations against Finnish law. Territorial violations are not uncommon, but are in most cases done without intent, for example through human error, and are treated accordingly. One common violation of this kind would be the unlawful entry into a restricted area on the Finnish coast or an illegal activity such as anchoring or scuba diving within a restricted area. The restricted areas on the Finnish coast can be seen in Picture 6.

Picture 6. Restricted areas on the Finnish coast.
Copyright: Finnish Defence Forces. (Source: Puolustusvoimat)

In the case of a territorial violation, all surveillance authorities have the right to:

  1. Order the person in violation to leave the restricted area;
  2. Order a military person, military unit, military vehicle, government vessel or government aircraft which is illegally in Finnish territory to leave Finnish territory;
  3. Order a vehicle or vessel to be stopped or an aircraft to land if such action is necessary to prevent or investigate a territorial offence or a territorial violation. (Finlex, Territorial)

For the purpose of investigating a territorial violation, persons suspected of having violated territorial regulations, including the restricted areas, must give the surveillance authorities, when requested, '[his] name, identity number or, if a person has no identity number, the date of birth and nationality of any person, and the address where he can be reached'. A person failing to provide this information is subject to apprehension and security control (Finlex, Territorial). There are separate regulations for boarding and inspecting vessels.

In the event of a government vessel illegally entering the Finnish territorial sea 5, the surveillance authorities will admonish the vessel for being in the Finnish territorial waters and urge it to leave without delay. The same applies to government vessels that have legally entered Finnish territory but failed to leave when the prearranged time for the visit or the reason for its entry has expired (Finlex, Government).

In the event of the admonition being ignored by the violating vessel, the use of force may come into question. An admonition would in most circumstances be repeated before a warning would be issued. A warning may include a threat of the use of force. In the words of the Territorial Surveillance Act (Finlex):

Before using force, a territorial surveillance authority must issue the admonition referred to in section 25, paragraph 1, and a warning that force may be used. A warning may, if necessary, be made more effective by opening warning fire. A decision to make a warning more effective by opening warning fire may be taken by the official carrying out territorial surveillance.
The implementation of warning fire, or 'intensified warning', as it is also called, is described in closer detail in the Territorial Surveillance Decree (Finlex):
The warning referred to in section 25, paragraph 1, of the Territorial Surveillance Act shall be given orally or in writing or by using communication equipment or international signs. If these means cannot be used to give a warning, a warning may also be given by making a threatening or aggressive movement with a vessel or aircraft. A warning to a diving submarine shall be given by firing a blank charge or a depth charge in such a way that the target is unlikely to suffer any damage. The warning fire referred to in section 32 of the Territorial Surveillance Act shall be fired as a warning shot from a gun or small arm, or by dropping an explosive from a vessel or aircraft.
For the purposes of intensified warning as well as self-defence, all Coast Guard and Navy vessels on patrol duty carry live ammunition. The authorisation for the use of force, up to the point of warning fire, lies with the commanding officer of the ship or coast artillery fort6 on site.

In the event of hostile activity7, the use of military force might come into question. With the use of military force, the authority lies higher than in the case of intensified warning.

The term 'military means of force' refers to the use of armed force with armaments which is more powerful than the use of a personal weapon by a military person. The use of military means of force shall be decided by the Ministry of Defence subject to the competence of the Supreme Commander of the Defence Forces unless otherwise provided by section 34. (Finlex, Territorial)
Situation Awareness: a Matter of National Interest

The national territory and territorial waters of Finland and matters concerning their surveillance and protection are clearly defined in Finnish law. The national legislative grounds for territorial matters are, in turn, based on international laws and agreements. This firm legislative background supports the Finnish surveillance authorities in their work.

The rapid increase in commercial vessel traffic in the Gulf of Finland can be expected to continue as Russia's economy develops. At the same time, Finland is becoming increasingly dependent on shipping for maintenance and supply as a part of the interdependent world economy. It would very difficult, if possible at all, to replace disrupted shipping with another means of transport. The Baltic Sea, with its arctic and rocky characteristics, is more important than ever. Its vital role as a transport route — one of the most important in the EU — makes the Baltic Sea a focal point both economically and militarily.

It is increasingly important in the changing security environment of the northern Baltic Sea to have an accurate and up-to-date picture of the situation at sea. The Finnish naval surveillance system accomplishes this task with relatively low cost through the extensive co-operation of specialised authorities.

Notes:

  1. Map with the names of the sea-areas surrounding Finland and the 60th latitude.


    (Source: http://europa.eu.int/, picture edited by Pekka Snellman.)

  2. Historically, the Baltic Sea has been completely frozen on average 2 to 3 times in a hundred years. Observation and documentation of the ice-cover has earlier relied on various sources such as fishermen's reports and is not entirely reliable. However, the latest occasions of complete freezing in 1947 and 1987 have been accurately verified, the latest with satellite pictures. In the winter of 1987, only 3.4% of the Baltic's surface was ice-free (Verkkouutiset).

  3. The distance between the base points of the inner border of the territorial waters must not exceed two times the width of the territorial sea (12 nautical miles or 22,224 metres). An exception on the Finnish coast are the waypoints near Bogskär, which are 27 nautical miles (nm) apart (Österlund and Viitasalo 15). The purpose of this rule is that the shape of the territorial sea should follow the shape of the landmarks of the coast and archipelago closely enough, but not in meticulous detail (Finlex, Aluemerta).

  4. Ships may be required to report in to Finnish authorities for a number of reasons. These may include requests for the use of a pilot, which is obligatory in most fairways and ports, make arrangements with harbour officials, customs declaration agents, etc. There are also special requirements for vessels carrying certain cargoes (such as flammable gases or explosives) and government ships. The data of a ship reporting in, including the date, time and position of its entering Finnish territorial waters, would in these cases be automatically conveyed to the surveillance authorities.

  5. A government ship may legally enter Finnish territorial waters

    1. By permission applied for in advance from the Defence Staff. In the written permit the exact location, date and time for the ship's entering into Finnish territory is recorded along with other information (Finlex, Government).
    2. By innocent passage, which means passing through the territorial sea without intention of entering the internal waters. Innocent passage may include stopping and anchoring when necessary for navigational reasons. Submarines must be surfaced and flying national colours (Finlex, Aluemerta). In practise, government ships often contact the surveillance authorities before commencing innocent passage.
    3. In a case of emergency at sea or search-and-rescue missions. The foreign government vessel must in these circumstances act under the command and follow the orders of the Finnish surveillance authorities and leave when the reason for its entry has expired (Finlex, Government).

  6. A coast artillery fort is an independent unit with a tactical area of responsibility. A fort usually consists of one or more coast artillery batteries with supporting units and is stationed in heavy fortifications.

  7. Quoting the Territorial Surveillance Act (Finlex), the term 'hostile activity' is defined as:

    1. Armed military activity illegally targeted at Finnish territory or performed in Finnish territory by a foreign state;
    2. Entry of an armed warship or military aircraft of a foreign state or a military vehicle of a foreign state into Finnish territory in spite of a warning given by a Finnish territorial surveillance authority;
    3. Entry of an armed warship or military aircraft of a foreign state or a military vehicle of a foreign state into Finnish territory in spite of a warning given by a Finnish territorial surveillance authority;
    4. Entry of a submarine or other underwater vehicle of a foreign state into Finnish territorial waters without permission otherwise than on the surface;
    5. Intelligence operations and electronic interference illegally targeted by a foreign state at objects in Finnish territory which are important for national security;
    6. Electronic jamming illegally targeted by a foreign state at a Finnish government vessel or government aircraft;
    7. Unlawful use of Finnish territory by a foreign state in an activity referred to in subparagraphs 1 to 5 against a third state.

Works Cited:

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Last Updated 10 January 2005