Jerusalem has been conquered and reconquered more than 37 times in its long history. Yet, with establishment over the past century of clear international legal principles forbidding such military conquests and of international organizations with at least minimal enforcement mechanisms, there has been a persistent hope that the fate of Jerusalem could-along with other territories seized by the Israeli armed forces-be resolved peacefully and with deference to international law.
The United States has traditionally been one of the most outspoken supporters of strong legal standards as guiding principles of international affairs, yet has often failed to uphold these values when transgressions have involved a close ally or its own perceived military exigencies. Still, recent moves by the Clinton administration regarding Jerusalem have surprised even the most cynical observers of U.S. foreign policy for their disregard of such international legal conventions and their departure from the stated positions of previous administrations.
The U.N. General Assembly partition resolution of November 1947 called for Jerusalem to be internationalized, specifically declaring that "The City of Jerusalem shall be established as a corpus separatum under a special international regime and shall be administrated by the United Nations. . . ."1 In the subsequent war, Israel seized the western part of the city, while Jordan took control of the eastern part. The city remained divided until 1967, when Israel conquered the remaining Arab section of the city along with the rest of the Jordanian-controlled West Bank.
For several years after Israel's independence, the United States still gave its support to an international regime over Jerusalem. The United States neither recognized Israel's 1948claim that West Jerusalem was its capital, nor did it recognize Jordan's declaration of East Jerusalem as its co-capital in 1960. In the years following the 1967 War, when Israel began to administer a greatly-expanded East Jerusalem under Israeli law, the United States repeatedly emphasized its belief that the city should be unified, but that its status should be determined by negotiations as part of a comprehensive peace settlement.
As a result of Israel's de facto annexation, the Department of State issued a statement which read "The United States has never recognized such unilateral actions by any of the states in the area as governing the international status of Jerusalem,"2 and supported U.N. Security Council Resolution 267 which condemned Israel's conquest of the city as illegal and censured ". . . in strongest terms all measures taken to change the status of the City of Jerusalem. ..."3 President Lyndon Johnson's Assistant Secretary of State for Near East and South Asian Affairs declared that
For 20 years the United States has stressed the international character of this holy city. We have not recognized claims of national sovereignty over Jerusalem. We have not accepted the view that either Israel or Jordan has a superior claim to the city. The interests of both these countries, as well as the interests of the international community, must be taken into account and properly protected.4
Generally, the United States has recognized de facto Israeli sovereignty without de jure sovereignty. The State Department and other government agencies regularly conduct business with Israeli officials in the city, though the embassy has remained in Tel Aviv and the U.S. consulates in the city report directly to Washington. According to Israeli jurist Stephen Adler, "The effect of U.S. policy on Jerusalem is... to grant the practical and legal consequences of recognition while still denying the legitimacy of the status quo."5
From the Johnson administration, in office during Israel's takeover of East Jerusalem, through the administration of President George Bush, every American government challenged the legitimacy of Israeli control and colonization. The Johnson administration made clear it considered Jerusalem from the beginning as part of the occupied territories. According to U.S. Ambassador to the United Nations Arthur Goldberg, "Our own view has been and remains that the future of Jerusalem is a problem which falls within the purview of Security Council Resolution 242..." which supports the concept of Israeli withdrawal from territories seized in the 1967 War in return for security guarantees from its Arab neighbors.6
Even during the administration of President Richard Nixon, when the U.S. tilt towards Israeli power as a tool for U.S. interests in the Middle East reached its early prominence and when the United States first used its veto power to protect Israeli violations of international law, the United States still went to great lengths to make clear its opposition to Israeli policy towards Jerusalem. For example, Charles Yost, Nixon's first ambassador to the United Nations, spoke before the Security Council in 1969, declaring that
The expropriation or confiscation of land, the construction of housing on such land, the demolition or confiscation of buildings, including those having historic or religious significance and the application of Israeli law to occupied portions of the city are detrimental to our common interests in the city. The United States considers that the part of Jerusalem that came under the control of Israel in the June war, like other areas occupied by Israel, is occupied territory and hence subject to the provisions of international law governing the rights and obligations of an occupying Power.7
Outlining in detail Israeli violations of the Fourth Geneva Convention, including the colonization of the traditional Arab sections of the city with Israeli Jews, Yost went on to declare that the United States ''regrets and deplores this pattern of activity."8
Similarly, President Gerald Ford's ambassador to the United Nations, William Scranton, argued before the Security Council in 1976 that Israeli settlement policy in Jerusalem was an obstacle to peace and could not prejudge the location of international borders.9
President Jimmy Carter's U.N. ambassador, Andrew Young, reiterated Scranton's statement. Carter himself also repeated remarks by Goldberg and Yost regarding their respective administrations' positions and Secretary of State Cyrus Vance confirmed in testimony before the Senate Foreign Relations Committee the Carter administration's position that East Jerusalem was indeed occupied territory.10
This position was challenged during the 1980 presidential campaign when Ronald Reagan stated that '' An undivided city of Jerusalem means sovereignty for Israel over that city."11 However, once in office, Reagan administration policy towards Jerusalem was mostly in line with the policy of its predecessors. For example, the U.S. deputy U.N. representative declared before the U.N. Security Council that "the position of the United States toward the status of Jerusalem, the applicability of the Fourth Geneva Convention to the territories occupied by Israel and Israeli responsibilities under that Convention remains unchanged."12
The Bush administration also considered Jerusalem to be occupied territory, taking a particularly strong stance against the construction of new settlements, and similarly emphasizing Israeli responsibility for upholding the Fourth Geneva Convention.13
Successive American administrations have had to resist right-wing initiatives in Congress to have the U.S. embassy moved to Jerusalem on the sound legal grounds that it would, in effect, provide recognition of Israeli sovereignty. However, given that some of these same administrations have shown little regard for international law in other aspects of U.S. foreign policy, it appears that this seemingly principled position on Jerusalem is, in fact, a recognition of the anti-American outrage in the Islamic world which would likely occur were the United States to make such an important symbolic recognition of Israeli control over the Holy City. While a handful of conscientious members of Congress have raised concerns about such a move on legal grounds, most opponents of the move simply raised pragmatic considerations dealing with the timing and its possible ramifications on the peace process. As a result, advocates of a U.S. move may not be totally incorrect when they charge that the United States is essentially giving in to "Arab pressure" on the issue.
President Bill Clinton reversed his earlier calls for moving the embassy as a reflection of his recognition of its potentially explosive ramifications. Indeed, as stated in an interview during the presidential campaign,
I do recognize Jerusalem as Israel's capital, and Jerusalem ought to remain an undivided city. But I think that timing is the real issue. Moving our embassy there while negotiations are in progress could disrupt the peace process in a way which could undermine the very objective we seek.14
Previous administrations saw no contradiction to their position that East Jerusalem was occupied territory and that the city should be united. The distinction came down to a belief that the city should not be physically divided and holy sites and other parts of the city should not be inaccessible to various religionists, yet the ultimate question of sovereignty could not be determined by military conquest and unilateral acts of annexation. Though long calling for a united city, the United States joined virtually the entire international community in declaring Israel's de facto annexation "null and void," the same language later used regarding Iraq's annexation of Kuwait. Indeed, the Bush administration's primary public rationale for the Gulf War was on the grounds that such land grabs must be reversed and that U.N. resolutions must be obeyed.
The six U.S. administrations in office since the 1967 War all saw Jerusalem as part of the Israeli occupation subject to U.N. Security Council Resolutions 242 and 338, which call for Israeli withdrawal from Arab lands conquered in the 1967 War in return for security guarantees from neighboring Arab states. Indeed, these resolutions explicitly reiterate the longstanding principle of international law regarding the illegality of the expansion of any nation's territory through military force.
At the same time, there did exist a contradiction between taking a position upholding international law regarding Jerusalem and the U.S. refusal to tie its massive military, economic and diplomatic support of successive Israeli governments to its enforcement. As Carter stated, any final agreement regarding the status of Jerusalem had to be acceptable to the Israeli government and the United States would not impose anything on Israel.15 Given the Israeli government's clear opposition to anything less than its complete control and sovereignty over all of greater Jerusalem, it would appear that the U.S. government could not both uphold international law and refuse to apply the necessary pressure on a recalcitrant Israeli government. Such contradictions have led to much criticism from other governments throughout the world. This has been a particularly difficult issue for certain conservative Arab regimes which are allied with the United States regarding many important strategic issues, but whose strong religious ties to Jerusalem resulted in a particularly negative reaction to American support of the Holy City's occupying army.
In addition, one of the requirements imposed by the United States in the Madrid peace talks, which began in 1991, was that no member of the Palestinian delegation could be from Jerusalem. Not only was no other delegation to the talks subjected to such geographical restrictions regarding its representatives, it implied a U.S. acceptance of the position by the Israeli government that Jerusalem was not a subject for negotiation. (Later in the talks, however, the United States did allow Faisal Husseini to participate, but only by using the legal fiction that he was resident of Jericho.) As Helena Cobban described it, "[W]hile the United States has never repudiated the U.N. resolutions on issues relating to Jerusalem, U.S. policy has been marked by numerous indications of slippage from adherence to those resolutions."16
Despite these questionable policies, however, the United States could remain faithful, at least in rhetoric, to important principles of international law.
CLINTON'S SHIFT TO THE RIGHT
This longstanding policy has changed under the administration of President Clinton. In citing statistics on Israeli settlements in the occupied territories, for example, the Clinton administration fails to count those in East Jerusalem. When Assistant Secretary of State Edward Djerejian testified before the House Foreign Affairs Subcommittee on the Middle East in March 1993, he did not include units under construction in East Jerusalem in his figures, implying that the United States does not consider them part of the occupied territories.
Bush's secretary of state, James Baker, in his letter of assurance to Arab leaders in preparation for the Madrid peace talks, explicitly stated that the United States did not recognize Israel's annexation of East Jerusalem and reiterated that the city's final status would be part of the negotiations. In that letter, the United States also reiterated its commitment to U.N. Security Council Resolution 242, which calls for "withdrawal of Israeli armed forces from territories occupied in the recent conflict" in return for peace with its Arab neighbors. This U.N. resolution, which the United States had long considered the basis of Middle East peace negotiations, also explicitly reiterated the longstanding principle of international law regarding ''the inadmissibility of the acquisition of territory by war,'' which appeared in the preamble of the U.N. resolution and which clearly included East Jerusalem.
When Clinton came to office, however, it quickly became clear that the Democratic administration was backing away from this assurance and, indeed, the policies of six previous administrations, particularly in regards to Jerusalem. In the June 30, 1993, paper to the delegations in the Washington peace talks, the United States for the first time would not recommit to 242 and 338. Emboldened by this, the government of Israeli Prime Minister Yitzhak Rabin essentially took Jerusalem off the negotiating table. According to Rabin, "The government is firm in its resolve that Jerusalem will not be open to negotiation. The coming years will also be marked by the extension of construction in Greater Jerusalem."17 The Clinton administration raised no objections.
The most obvious sign of this change came this past April, when the United States abstained from a section of a U.N. Security Council resolution condemning the February massacre at the mosque in Hebron, objecting to a paragraph which referred to the Arab part of Jerusalem as occupied territory. This unprecedented action led to a strong reaction from other member nations; no other government besides Israel had previously taken any issue with conferring that status on East Jerusalem. Such a unilateral disregard for international law by an American administration has usually led to outrage on Capitol Hill, which has challenged such irresponsible policies of previous administrations in Central America, Southern Africa and elsewhere. But instead, Congress was pressuring President Clinton from the right. Eighty-two senators signed a letter calling on the United States to not just abstain on the paragraph in question, but cast a veto against a U.N. resolution for referring to Jerusalem as occupied territory, even though it was clear that such an action would likely lead to the total collapse of the peace talks. The letter was drafted by two senators who have a long history of undermining the authority of the United Nations: Florida Republican Connie Mack, who successfully pushed the United States to reject the verdict of the International Court of Justice forbidding U.S. attacks against Nicaragua; and New York Democrat Daniel Patrick Moynihan, where-as Nixon's ambassador to the United Nations-successfully blocked U.N action against U.S. allies Indonesia and Morocco when they invaded and occupied neighboring countries.18 Not surprisingly, the letter was also signed by such right-wing Republican stalwarts as Jesse Helms, Strom Thurmond, Trent Lott and Alfonse D'Amato, but also included a large number of erstwhile liberal Democrats.
In a conference call with leaders of major Jewish organizations in March, Vice President Al Gore reaffirmed the Clinton administration's position which recognizes a united Jerusalem as the capital of Israel. As part of the objection to mentioning Jerusalem as occupied territory, he promised that the United States would abstain on the paragraph; a veto, he explained, would have jeopardized the resumption of the peace talks. He added that had mention of Jerusalem been an operative paragraph rather than simply as part of the preamble, the United States would have indeed vetoed the entire resolution.19
The rationale for the position taken against the United Nations by the administration and the majority of the Senate was that, according to the Declaration of Principles signed between Israel and the Palestine Liberation Organization in September 1993, the issue of Jerusalem-along with settlements and military locations-is relegated to "permanent status negotiations" which need not even begin until "the beginning of the third year of the interim period," which is 1996. Secretary of State Warren Christopher insists that since Jerusalem is "a final status matter... any effort to prejudge that issue in a U.N. resolution would find the opposition of the United States."20
Such a rationalization, however, is patently disingenuous. Both Clinton and Gore, as well as the vast majority of members of Congress who attacked the U.N. resolutions as "pre-judging" the status of Jerusalem, are on record unilaterally declaring Jerusalem the unified capital of Israel, clearly an effort to "pre-judge" the city's status. More importantly, however, whatever the final outcome of negotiations, the fact remains that the residents of East Jerusalem never voluntarily ceded to Israeli sovereignty through a referendum or other methods; their part of the city was seized by military force. To this day, Israeli occupation forces patrol the streets and human rights abuses against residents who oppose Israeli rule continue. By any definition, this constitutes a military occupation.
In addition, no bilateral agreement between two parties can supersede the authority of the United Nations Security Council, which on numerous occasions has declared Jerusalem to be an occupied city, particularly since one of the two parties (the PLO) would never be a party to any final agreement which would countenance continued unilateral Israeli control as anything but occupation.
Previous U.S. administrations raised objections to some U.N. resolutions on Jerusalem on a number of grounds: regarding what were seen as one-sided attacks on Israel or exaggerated accounts of Israeli transgressions; efforts to separate Jerusalem from a comprehensive peace settlement which would include an end of Arab belligerence towards Israel; practical obstacles to the physical dismantling of the large Jewish neighborhoods in East Jerusalem; implied attempts to restore what were seen as an unreasonable status quo ante; possible efforts to impose sanctions on Israel; or, various other legal technicalities. No administration prior to Clinton's, however, has questioned the fact that East Jerusalem is occupied territory, that Israeli settlements in East Jerusalem are anything but illegal, or that Israeli governance of East Jerusalem was subject to the provisions of the Fourth Geneva Convention. During these two Democratic and four Republican administrations, the United States supported eight U.N. resolutions which challenged Israeli policies in East Jerusalem or mentioned Jerusalem in context with other aspects of the Israeli occupation of Palestinian land. None of the ten abstentions was cast with any question that Jerusalem was under military occupation.
The U.S. government is taking additional steps to ensure there can be no implications of U.S. sanction to claims that Palestinians might also have a right to any part of greater Jerusalem. This past summer, an amendment to the Appropriations bill barred any U.S. government office from being set up anywhere in Jerusalem to conduct business with the Palestinians. In addition, the Clinton administration withdrew plans to open a Jerusalem branch office of the U.S. Agency for International Development that would have supervised the allocation of funds to the Palestinian Authority.
Thus, despite denials by Clinton administration officials, there has been a real shift in U.S. policy regarding Jerusalem. Given the centrality of Jerusalem in any comprehensive peace settlement, this change in policy may have serious ramifications.
This became apparent soon after the U.S. abstention on the Security Council resolution on the Hebron massacre. Emboldened by the shift in U.S. policy, Israel closed off greater East Jerusalem from the rest of the West Bank on April 7, the first of a series of closures in subsequent months, creating enormous hardships for West Bank Palestinians. The Israelis have justified such actions on security grounds, following bloody attacks by Palestinian terrorists. However, these attacks occurred well inside Israel's internationally recognized borders, not in Jerusalem. It appears that such decisions are part of a larger plan to permanently separate Jerusalem from the West Bank and further integrate it into Israel.
Just as Jordanian authorities barred Israeli Jews from their holy sites in Jerusalem prior to 1967, now Israeli authorities bar both Christian and Muslim Palestinians from outside the city access to theirs.
Yet Jerusalem is not just important for religious reasons. For centuries, it has been the commercial and cultural center of Palestinian society. As the only major city of the West Bank, it is where thousands of Palestinians come to visit relatives, go to theaters and concerts, do their major shopping, and - most importantly - work. When Jerusalem is closed off, Palestinians who regularly commute into the city from nearby towns to work in Palestinian businesses are denied entry. Children cannot get to their schools, and patients cannot see their doctors. In addition, this effectively separates the northern and southern parts of the West Bank.
Twenty-six years of economic strangulation by Israeli occupation authorities in the West Bank has made it virtually impossible for many Palestinians to find alternatives to employment and other necessities. This increased hardship strengthens radical forces opposed to the Oslo accords and their propensity for violence, especially as the Israeli government-bankrolled by the American taxpayer-continues to expand its illegal settlements in East Jerusalem and beyond.
There is a consensus among knowledgeable observers that any failure to successfully address the Jerusalem issue will derail the entire peace process. Cobban observes correctly that "... [l]f the peace process is to stay on track over the next two years, there must be a significant improvement in the lives and expectations of the Palestinians of Jerusalem...."21 Indeed, combined with the fact that only the United States has the influence to force Israel to end its occupation of Jerusalem, the Clinton administration's shift in policy threatens the future peace and stability of the entire region.
While Rabin has largely compromised the Likud government's effective claim of sovereignty over the entire occupied territories, the Labor government's claim to the 10 percent of the West Bank which it sees as part of greater Jerusalem is as adamant as its right-wing predecessors. Indeed, the Israeli government under Rabin has increased its efforts to colonize and effectively change the demographics of the region wedged between Ramallah, Hebron and Jericho.
Approximately 168,000 Israelis now live in East Jerusalem, (approximately equal to the number of Palestinians) in ten major settlement neighborhoods. This demographic shift is a major problem. According to Khalil Tufakji, a Jerusalem geographer who serves as an adviser to the Palestinian negotiating team, "These are the blackest of days for Jerusalem. In two years, it will all be over.''22 Similarly, according to Haidar Abdel Shafi, former head of the Palestinian delegation to the peace talks, "In two or three years it might be too late to set up a Palestinian state because of the policy of continued settlement building around Jerusalem."23
The U.S. role is critical. According to Cobban, ''... if there is to be anything left for the Palestinians to negotiate about in Jerusalem in 1996, then the U.S. administration must get a handle on the current orgy of new Jewish construction in [East Jerusalem]."24 By delaying discussion of Jerusalem for at least two years, as the Clinton administration insists, it effectively allows Israel to consolidate its illegitimate conquest. The United States appears to be actively collaborating with this Israeli strategy.
Ironically, as American and Israeli leaders work to make permanent Israel's takeover of Jerusalem, many influential Palestinians and Israelis in Jerusalem itself have met together to explore possible solutions to the unique and difficult challenges dealing with the administration and status of a city claimed by two peoples. A number of working groups and non-government organizations have presented several creative and workable alternatives which could keep the city united without supporting the dangerous precedent that would come from legitimizing Israel's 1967 conquest. Options discussed have included making Jerusalem an international city as originally called for by the United Nations in 1947, creating a joint Israeli-Palestinian administration or re-partitioning the city along its original dividing line, but with full access by residents and visitors to both the Israeli and Palestinian sides.
The PLO and the majority of other Palestinian leaders have shown enormous flexibility on the Jerusalem issue short of accepting total Israeli sovereignty. PLO chairman Yasser Arafat has promised to share Jerusalem as the joint undivided capital of both Palestine and Israel.25 Virtually no one has called for a return of the 1948-67 division with barbed wire, sentry posts and snipers. Yet repeatedly, American political leaders have cited that period as justification for endorsing continued Israeli occupation, as if a return to the status quo ante was the only option. (For example, in a 1990 Congressional resolution on Jerusalem, an overwhelming majority of both houses supported a resolution attacking the Bush administration for challenging illegal Israeli settlements in East Jerusalem by saying that it raised concerns "that Jerusalem might one day be redivided and access to religious sites in Jerusalem [be] denied to Israeli citizens."26 This is apparently an effort to obscure the fact that the United States is effectively endorsing a country's act of unilateral territorial expansionism.
Challenging the fact that Jerusalem is currently under military occupation discourages the Israelis from making the necessary compromises for peace and gives license to any nation which seeks to enlarge its territory by force of arms. No other nation outside the United States and Israel supports the idea of a Jerusalem united under Israeli sovereignty as Israel's capital. International organizations and leaders of major religious bodies throughout the world have repeatedly stressed the importance of not allowing Israel's unilateral takeover to remain unchallenged.
As long as the American stance is seen as simply "pro-Israel," there is little likelihood that there will be a sufficient groundswell of public opposition to change the direction of Clinton administration policy on Jerusalem. However, the problem with Clinton's view of Jerusalem is ultimately not a bias towards Israel, but a direct challenge to the authority of the United Nations and some of the most basic tenets of international law. At stake, then, is a lot more than the fate of one Middle Eastern city.
In short, the Clinton administration's policy on Jerusalem threatens both the authority of the United Nations and the most fundamental principles of international law. It jeopardizes the peace process, emboldens hard-liners on both sides, and creates enormous suffering for many thousands of Palestinians.
This is not an issue of being pro-Israel or anti-Israel. Even some of the Jewish state's strongest defenders-including many Israelis-recognize the dangers inherent in supporting Israel's claim to all of Jerusalem. It is a choice between those who wish to uphold international law and the right of self-determination versus those willing to accept the results of military might and the right of conquest. The Clinton administration is on the wrong side.
1 U.N. General Assembly Resolution 181.
2 Statement by the Department of State, June 28, 1967, (Department of State Bulletin, vol. 57, no. 1464, July 17, 1967, p. 60).
3 U.N. Security Council Resolution 267.
4 Assistant Secretary of State for Near East and South Asian Affairs Lucius Battle, "Objectives and Directions of U.S. Policy in the Near East," talk before the American Jewish Congress, Miami, FL, May 16, 1968, (Department of State Bulletin, vol. 58, no 1510, June 3, 1968, p. 712).
5 Stephen Adler, "The United States and the Jerusalem Issue," Middle East Review, Summer 1985, p. 46.
6 Arthur Goldberg, before the U.N. Security Council, May 21, 1968, (Provisional Verbatim Record of 1426th Meeting, S/PV.1426, pp. 6-7).
7 Charles Yost, cited in Report on Israeli Settlements in the Occupied Territories, Washington: Foundation for Middle East Peace, February 1994, p. 5.
9 William Scranton, cited in ibid., p. 6.
11Cited in Adler, op. cit., p. 45.
12 U.S. U.N. Deputy Representative Byrne, before
U.N. Security Council, January 30, 1986, in American Foreign Policy: Current Documents, 1986, #179 (Washington: Government Printing Office, 1987), p. 373.
13 Jody Boudreault and Yasser Salaam, eds., U.S. Official Statements: The Status of Jerusalem (Washington: Institute for Palestine Studies, 1992), pp. 8.
Application of the Fourth Geneva Convention is important because specific provisions regarding human rights and population transfers apply only to territories seen as under military occupation and would not be applicable to activities within a country's recognized boundaries.
14 Middle East Insight, November-December 1992.
15 President Carter, in reference to Camp David peace negotiations and subsequent statements, cited Boudreault and Salaam, op. cit., pp. 61-62.
16 Helena Cobban, "U.S. Policy on the Issue of Jerusalem," Jerusalem: A Special Report (Washington: Center for Policy Analysis on Palestine, 1993), p. 27.
17 Richard H. Curtiss, "As U.S. Moves the Goal Posts, Jerusalem Main Obstacle to Peace," Washington Report on Middle East Affairs, September/October 1993, p. 6.
18 The Indonesian occupation of East Timor and the Moroccan occupation of Western Sahara remain in effect to this day, in large part because-as with Israel-the United States blocked any sanctions against the offending governments and has sent large amounts of military and economic aid to help support the occupations.
19 Newstab PR Newswire, March 18, 1994, "Gore Reaffirms U.S. Policy Declaring United Jerusalem as Capital of Israel."
20 Secretary of State Warren Christopher, Hearings of the Foreign Operation Subcommittee of the Senate Appropriation Committee, Wednesday, March 2, 1994.
21 Cobban, op. cit., p. 30.
22 Report on Israeli Settlements in the Occupied Territories, op. cit., p. 9.
23 Ibid., p. 3.
24 Cobban, op. cit., p. 30.
25 Report on Israeli Settlements in the Occupied Territories, op cit, p. 2.
26 Text of the House Concurrent Resolution 290, Congressional Record, April 24, 1990, H 1630.