evidence: The APMSS map also indicates that Vietnam has 14 more outposts in the Spratly Islands. Comparing the map with what exists on the ground – or, if you prefer, the water – we can see that they are the 14 lookout structures (nha gian in Vietnamese) that Vietnam is operating on six underwater banks located southwest of the Spratly Islands. Vietnam started to set up permanent structures on Vanguard Bank (Vietnamese: Bai Tu Chinh), Rifleman Bank (Bai Vung May), and Prince of Wales Bank (Bai Phuc Tan) in 1989, on Prince Consort Bank (Bai Phuc Nguyen) in 1990, and on Grainger Bank (Bai Que Duong) and Alexandra Bank (Bai Huyen Tran) in 1991. These platforms measure between 100 and 250 square meters each, and stand on shallow elevations lying between seven and 25 meters below the sea surface. Whether these shoals form part of the Spratly Islands is a matter of debate. China’s maps group them together with the Spratlys proper while treating them as if they were landforms above water. As a result, the Chinese numbers of the Vietnamese-occupied features in the Spratly Islands range typically between 27 and 30. Vietnam argues that as the shoals lie deep under water and within 200 nautical miles (nm) from the Vietnamese baselines, they belong to Vietnam’s continental shelf and exclusive economic zone (EEZ) as stipulated in Article 76 of the UN Convention of the Law of the Sea (UNCLOS). According to UNCLOS, submarine features cannot be appropriated by occupation or otherwise.