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It responds to ISBA stakeholder consultation on the development of draft standards and guidelines and thanks the Legal and Technical Commission. The comments argue drafting is premature while exploitation regulations are still under deliberation, request additional time and transparent capacity-building support, and highlight uncertainty about how comments will be addressed and integrated. They reiterate that robust stakeholder engagement should be mandatory in environmental impact assessment standards.",{"@graph":63,"@context":119},[64,80,102],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/pew-submission-standards-and-guidelines-comments/380829/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/pew-submission-standards-and-guidelines-comments/380829.png","ImageObject",442,249,{"name":88,"@type":89},"\tJames","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-16","2026-09-24",true,{"@type":98,"interactionType":99,"userInteractionCount":101},"InteractionCounter",{"@type":100},"ViewAction",6,{"@type":103,"mainEntity":104},"FAQPage",[105,111,115],{"name":106,"@type":107,"acceptedAnswer":108},"Why does the submission argue that drafting standards and guidelines is premature?","Question",{"text":109,"@type":110},"Because the exploitation regulations that will govern the standards and guidelines are still under consideration, preventing meaningful assessment of how subsidiary documents will operate within the broader regulatory framework.","Answer",{"name":112,"@type":107,"acceptedAnswer":113},"What do the comments request regarding timelines and support for drafting?",{"text":114,"@type":110},"They recommend deferring consideration until the draft regulations are more stabilized, provide additional time for quality over haste, and encourage the Secretariat to work with the Commission and stakeholders to offer transparent mechanisms for drafting support.",{"name":116,"@type":107,"acceptedAnswer":117},"How do the comments address stakeholder engagement in the EIA standard?",{"text":118,"@type":110},"They state that robust stakeholder engagement should be a mandatory component in the EIA standard and that its absence in the current exploitation regulations should not be used to exclude stakeholder consultation.","https://schema.org",{"og:url":78,"og:type":121,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":123,"canonical":78},"index,follow",{"doc_id":125,"site_id":56},380829,1791352729,{"code":4,"msg":5,"data":128},{"doc_id":125,"user_id":129,"nickname":88,"user_avatar":130,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":131,"file_id":132,"file_url":133,"file_type":134,"file_size":135,"view_count":101,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":136,"language":137,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":138,"faqs":139,"seo_title":140,"seo_description":61,"update_tm":141,"read_time":142},2336474466412,"https://ap-avatar.wpscdn.com/davatar_155a257f0dc6eb9ab79c44ca47cae57d","2 July 2021  \nMr. Nathan Eastwood  \nOffice of Legal Affairs International Seabed Authority Email: [ola@isa.org.jm](ola@isa.org.jm)  \nDear Mr. Eastwood,  \nThe Pew Charitable Trusts, in its capacity as an observer to the International Seabed Authority (the Authority), respectfully submits these comments in response to the stakeholder consultation initiated by the Authority pursuant to ISBA/25/C/19/Add.1 on the process of development of draft standards and guidelines. We thank the members of the Legal and Technical Commission for their work in developing these draft documents and welcome the opportunity for consultation.  \nThese comments were prepared in consultation with members of Pew’s Code Project, an initiative launched in 2017 to bring together scientists, regulatory practitioners, and legal scholars, to review and comment on aspects of the evolving governance regime for mining in the Area.  \nAs we noted in earlier correspondence, the Draft regulations on exploitation of mineral resources in the Area (ISBA/25/C/WP.1) envision that standards and guidelines will address a host of critical issues. Fair and inclusive stakeholder consultation should be a prerequisite for drafting all of these documents and we commend the Authority on its efforts to solicit comments thus far. We hope the present submission is a constructive contribution to this discussion.  \nBut we also must raise some concerns. First, it is increasingly clear that at this stage consideration of standards and guidelines is premature. During the prior round of consultations carried out in November 2020, several respondents noted that the Authority is still deliberating the draft regulations on exploitation which will control these standards and guidelines, preventing any meaningful consideration as to how these subsidiary documents will operate within the broader regulatory framework. We further note that the Council has formed a series of informal working groups to discuss the draft regulations, including a working group on protection and preservation of the marine environment that will have outputs likely to bear directly on this consultation. Due to COVID-related cancellations, this group and others have yet to hold their first meetings.  \nCouncil members have repeatedly emphasized a preference for quality over haste in the development of the mining code. If the importance and complexity of the exploitation regime, including standards and guidelines, requires more time and deliberation than may have been initially envisioned, then additional time should be provided. Further, if additional capacity and expertise in drafting standards and guidelines could be useful, then we would encourage the Secretariat to work with the Commission and other stakeholders to provide a transparent mechanism for such offering such support. In any event, it seems more prudent to defer consideration of standards and guidelines until the draft regulations are further stabilized. The exploitation regime can then be considered in its totality.  \nIt also remains unclear what will be done with these comments. A chart available on the Authority’s webpage indicates that, following a stakeholder consultation, draft standards and guidelines will be under consideration for approval by the Commission and then will be considered by the Council. But it does not explain how the Commission will respond to comments submitted or integrate those comments into revised drafts. Nor does it provide opportunity for further discussion and comment on those submissions. Given the importance of these issues and the extensive commentary that will likely be generated from this review  \nprocess, we express our strong hope and encouragement that several rounds of consultations will be conducted for each set of standards and guidelines to ensure that all inputs are captured.  \nI thank you again for the opportunity to submit these comments. Please do not hesitate to reach out if further discussion with us or with me","cbCaijU3GBzyNlCc","https://ap.wps.com/l/cbCaijU3GBzyNlCc","pdf",1027439,92,"English","# General Comments\n## Prematurity of S&Gs development\n## Need for robust stakeholder engagement in EIA standard\n## Fundamental environmental protection approach before adoption\n## Request for transparent handling of submitted comments","[{\"question\":\"Why does the submission argue that drafting standards and guidelines is premature?\",\"answer\":\"Because the exploitation regulations that will govern the standards and guidelines are still under consideration, preventing meaningful assessment of how subsidiary documents will operate within the broader regulatory framework.\"},{\"question\":\"What do the comments request regarding timelines and support for drafting?\",\"answer\":\"They recommend deferring consideration until the draft regulations are more stabilized, provide additional time for quality over haste, and encourage the Secretariat to work with the Commission and stakeholders to offer transparent mechanisms for drafting support.\"},{\"question\":\"How do the comments address stakeholder engagement in the EIA standard?\",\"answer\":\"They state that robust stakeholder engagement should be a mandatory component in the EIA standard and that its absence in the current exploitation regulations should not be used to exclude stakeholder consultation.\"}]","Pew Submission - Standards and Guidelines - Comments | PDF",1790242321,32]