On 12 July 2016, the tribunal of the
Permanent Court of Arbitration concluded that for purposes of Article 121(3) of the
Convention, the high-tide features at Gaven Reef (North) are rocks that cannot sustain human habitation or economic life of their own and accordingly shall be entitled to of territorial sea measured from its baseline but have no exclusive economic zone or continental shelf. PCA also concluded that the features at Gaven Reef (South) are, or in their natural condition were, exposed at low tide and submerged at high tide and are, accordingly low-tide elevations that do not generate entitlement to a territorial sea, exclusive economic zone or continental shelf. ==Military development==