The increasing number of submarines various countries are deploying to the Indo-Pacific region has fuelled calls for an underwater code of conduct to reduce the risk of accidents in the busiest waterways. The warning comes as Asian Pacific countries are engaged in a submarine arms race, with an estimated 228 full-sized submarines operating in the East and South China Seas – a number that is expected to rise to 300 within a decade. Unlike other warships, submarines are by definition difficult to detect – increasing the chance of accidental collisions and mishaps. In addition, there are no regionally accepted rules governing submarine operation. Speaking at an Asia Society forum in Hong Kong last Friday, David Shear, the former US assistant defence secretary for Asian and Pacific security affairs, warned that the risk of underwater accidents was rising as regional heavyweights and smaller countries – many of which have competing claims to the South China Sea – are expanding their submarine fleets. “The region – particularly the western Pacific, and particularly within the first island chain on the American front perimeter – is filling up with submarines,” Shear said. “Not just American and Chinese submarines, but Korean and Japanese submarines and Malaysian and Vietnamese submarines as well,” he said. The first island chain – Japan, Taiwan and the Philippines – is viewed by China as an area it must secure and pass through in the event of conflict. According to the latest edition of Military Balance 2019, published by the British research institute IISS, the Indo-Pacific region has 228 full-sized submarines and 52 miniature vessels. At present the US Pacific Fleet has the most powerful force in the region, with 33 nuclear-powered subs giving it an asymmetric advantage. Although China has a larger submarine fleet overall, the majority are conventionally powered and it has only 10 nuclear-powered vessels. After that South Korea and Japan both have smaller conventional fleets with 22 and 20 subs respectively. Currently there are no rules governing underwater encounters, whereas a Code for Unplanned Encounters at Sea (CEUS) was agreed by 21 countries – including the US and China – in 2014 in an effort to prevent accidents on the surface. An incident in September highlighted the danger of accidental collisions between rival navies when an American and a Chinese warship nearly collided near territory claimed by China in the Spratly archipelago, which is known as the Nansha Islands in China. The Chinese ship came within 41 metres (135 feet) of the USS Decatur, prompting the Pentagon to accuse the PLA Navy of conducting an aggressively “unsafe and unprofessional manoeuvre”. “We need to reduce tensions among US, Chinese and other navies and air forces in the Western Pacific,” Shear said. “We need to have some way of preventing accidents among all of these submarines. There are ways to do that.” Since 2015 Singapore has been pushing the navies of other countries to extend the existing CUES to include a UCUES – Underwater Code for Unplanned Encounters at Sea. The first draft of UCUES was officially introduced in 2016 when Rear Admiral Timothy Lo, Singapore’s former navy chief, warned that “over the last 10 years or so, we have seen a proliferation of submarines and submarine-operating navies. When the underwater environment becomes more crowded, the risk of an inadvertent collision is higher”. “The draft lays out non-binding safety procedures designed to prevent collisions, including basic manoeuvring instructions derived from existing manuals or accepted practices,” said Bonnie Glaser, an Asia security expert at the Centre for Strategic and International Studies in Washington. “Due to the sensitive nature of submarine operations – operating without revealing their location, I think it will be challenging for this goal to be realised,” Glaser said. Experts said that major players should take the lead, pushing forward the underwater code of conduct to avoid miscalculation. “Any regional initiatives promoting submarine operational safety will necessarily have to get all players on board,” said Collin Koh Swee Lean, a maritime security research fellow at Nanyang Technological University in Singapore. He said it would be “close to meaningless” without the participation of the “main players” – which include China, Russia and the US – who have sizeable and expanding submarine fleets. Song Zhongping, a Hong Kong-based military analyst and a former instructor with the PLA’s Second Artillery Corps, also warned of the increased risk of submarines colliding. “While it is relatively easy for vessels to see each other on the sea, there is higher probability that submarines would not notice each other because of their stealthy capability,” Song said. He said the US should take the lead in setting the underwater rules because of the size of its nuclear-powered submarine fleet and said: “China would be optimistic and positive in supporting the initiative. ”