In September 2021, IUCN (International Union for the Conservation of Nature) voted to approve a motion calling for a moratorium on deep seabed mining at its annual Congress. We acknowledge the concerns expressed by those who proposed it and those who voted for it. The motion calls for several pre-conditions to be met before deep seabed mining proceeds. Here we summarise those pre-conditions and share our thoughts on each of them: 1. Rigorous and transparent impact assessments have been conducted, the environmental, social, cultural and economic risks of deep seabed mining are comprehensively understood, and the effective protection of the marine environment can be ensured GSR response: We agree with this pre-condition. The International Seabed Authority (ISA) process currently being developed ensures it will be met through its rigorous environmental, social and economic requirements: https://www.isa.org.jm/mining-code/draft-exploitation-regulations  The current draft exploitation regulations (Draft Regulations - DR) developed by the ISA foresee the submission of an Environmental Impact Statement (EIS) as part of the application for approval of a Plan of Work (DR 7(3)(d)). The EIS documents and reports the results of the environmental impact assessment process (DR 47). This process seeks to identify, predict, evaluate and mitigate the biophysical, social and other relevant effects of the proposed mining operation (DR 47(1)(a)). To ensure that it is a transparent environmental impact assessment, the applicant must describe the nature and extent of consultation(s) that have taken place with parties identified who have existing interests in the proposed project area and with other relevant stakeholders (Annex IV of the Draft Regulations (13)). The EIS includes an assessment of impacts on the physicochemical, biological and socioeconomic environment to ensure that environmental, social, cultural and economic risks of deep seabed mining are taken into account (Annex IV of the Draft Regulations). The EIS must be prepared in accordance with the Guidelines, Good Industry Practice, Best Available Scientific Evidence, Best Environmental Practices and Best Available Techniques (DR 47(3)(d)). 2. The precautionary principle, ecosystem approach, and the polluter pays principle have been implemented GSR response: The precautionary principle, ecosystem approach, and the polluter pays principle are part of the guiding principles of ISA’s Draft Regulations (DR 2(e)), which derive from article 145 of the LOSC (Law of the Sea Convention). According to these regulations, the effective protection of the marine environment from the harmful effects which may arise from exploitation must be based on the application of:

• the precautionary approach, as reflected in principle 15 of the Rio Declaration on Environment and Development (DR 2(e)(ii)). This is also a guiding principle for the assessment and management of risk of harm to the marine environment from exploitation in the Area (DR 44(a));
• an ecosystem approach (DR 2(e)(iii)); and
• the “polluter pays” principle through market-based instruments, mechanisms and other relevant measures (DR 2(e)(iv)).

A contractor wishing to carry out mining in the Area must demonstrate compliance with these principles.    3. Policies to ensure the responsible production and use of metals, such as the reduction of demand for primary metals, a transformation to a resource-efficient circular economy, and responsible terrestrial mining practices, have been developed and implemented GSR response: The challenge that everyone faces is that there is simply not enough metal currently in circulation to meet the demands created by a growing global population, urbanisation and the ramp up of clean energy infrastructure.   The International Energy Agency’s (IEA) most recent analysis (May 2021 - https://www.iea.org/reports/the-role-of-critical-minerals-in-clean-energy-transitions/executive-summary) suggests that to reach the goals of the Paris Agreement, minerals supply for clean energy technologies will need to grow four-fold by 2040. To hit net-zero emissions globally by the middle of century, six times more mineral inputs will be required in 2040 compared with today. Mineral supply plans today are not ready to support accelerated energy transitions, says IEA. Metal requirements appear even more overwhelming when one considers IEA’s forecasts for specific minerals. To meet Paris goals, the lithium supply will need to expand 42-fold, graphite 25-fold, cobalt 21-fold, and nickel 19-fold. So, how do we meet this colossal metal demand while causing least harm to the planet want to protect?  Expanding recycling will play a part but according to the IEA will only contribute 10% to supply chains by 2040. That’s because of long in-use lifetimes (an offshore wind turbine is expected to last more than 30 years for example) and also because, in the past, we haven’t created products that are easily disassembled to allow easy recycling of their components.  Beyond recycling, strategies such as material substitution, product re-use and product re-design may be able to place a brake on society’s thirst for minerals, and future technological advances may also help to dampen demand.  However, the scale and pace of forecast demand is so high that significant new sources of metal will still be needed in the coming decades. In summary: We can – and should - work towards a circular economy.  To get there requires a transition period and large quantities of primary resource (new metal) will be required first. 4. Public consultation mechanisms have been incorporated into all decision-making processes related to deep-sea mining ensuring effective engagement allowing for independent review, and, where relevant, that the free, prior and informed consent of indigenous peoples is respected and consent from potentially affected communities is achieved GSR response: The ISA Draft Regulations require contractors to engage in public consultation and ensure effective public engagement – in alignment with what the IUCN motion calls for (DR 2(e)(vii)). Seven days after determining that an application for the approval of a Plan of Work is complete, the Secretary-General must place the environmental plans of such application on the ISA’s website for a period of sixty days and invite members of the ISA and Stakeholders to submit comments in writing (DR 11(1)(a)). Stakeholders can be any natural or legal person with an interest of any kind in, or who may be affected by, the proposed or existing exploitation activities under a Plan of Work in the Area, or who has relevant information or expertise (Schedule 1, Draft Regulations). The applicant must consider the comments and may revise the environmental plans or provide responses in reply to the comments and shall submit any revised plans or responses within a period of thirty days following the close of the comment period (DR 11(2)). Applications for the approval of a Plan of Work that have not been subject to the public consultation mechanism described above, are not considered by the Legal and Technical Commission of the ISA (DR 11(2)). 5. Promote the reform of the ISA to ensure transparent, accountable, inclusive, effective and environmentally responsible decision making and regulation. GSR response: We agree with transparent, accountable, inclusive, effective and environmentally responsible decision making and regulation.