DSCC Interventions 27/7/23

Date: 27 July 2023

This intervention is on behalf the DSCC, the Environmental Justice Foundation, Oceans North, Greenpeace, WWF, The Ocean Foundation, OceanCare, AIDA and Sustainable Ocean Alliance.

Our main observation on the strategic plan pertains to a matter of process. The Strategic Plan is an important document in the ISA’s functioning and deserves adequate time dedicated to its development, in order to ensure that all member States and Observers have ample opportunity to contribute. However, in this instance, consultation on the Strategic Plan and revised Strategic Plan was limited, with a tight deadline for written submissions, and overlapped with Council meetings. What’s more, the group of member States initially consulted regarding the Strategic Plan was not representative of the spectrum of opinions that are expressed at the ISA today. We note particularly that the process failed to include perspectives from member States calling for a moratorium, precautionary pause or ban. This movement is real and growing and needs to be recognised in all ISA processes. There was also no consultation of the broader range of stakeholders that have expressed interest and concerns over the prospect of deep-sea mining, such as indigenous leaders and the fishing industry. We are therefore concerned that the feedback received and reported by the ISA Secretariat presents an incomplete picture of the interests, opinions and objectives of the stakeholders engaged in this issue.

In light of these concerns, and given the numerous other priorities of ISA stakeholders at this time, we suggest, like Brazil, that the Secretariat postpone the adoption of the next Strategic Plan to the Assembly meeting of 2025, and after the completion of the Article 154 review. Meanwhile, we would hope to see further opportunities for input, including more comprehensive stakeholder consultation.

Finally, the review of the previous Strategic Plan observes (and I quote) “a marked increase in the pace of the meetings of the Council, ensuring that the Council does not lose sight of the ultimate objective of adopting a sound regulatory framework” (end quote).  Firstly, we observe that this accelerated trajectory is untenable for many member States and further exacerbates global inequities. We therefore suggest that the ISA returns to a more sustainable and inclusive schedule of one Council meeting and one Assembly meeting per year. Secondly, we suggest that “the ultimate objective” is not simply to “adopt a sound regulatory framework”, but to ensure that the Area is managed for the benefit of humankind as a whole and that the marine environment is protected from harm. There can be no guarantee at this point that the adoption of a regulatory framework will achieve this objective. In fact it may achieve the opposite by opening the gates to mining before we even truly understand the impacts. The strategic plan must therefore centre around the precautionary principle and should be based on the decadal timescales that independent scientists inform us will be required to obtain sufficient scientific data. 

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