Marine Policy 149 (2023) 105505

Contents lists available at ScienceDirect

Marine Policy
journal homepage: www.elsevier.com/locate/marpol

Thresholds in deep-seabed mining: A primer for their development

B. Hitchin a, *, S. Smith b, K. Kröger c, DOB Jones d, A. Jaeckel e, f, NC Mestre g, J. Ardron a,
E. Escobar h, J. van der Grient i, j, T. Amaro k
a
Commonwealth Secretariat, Marlborough House, London SW1Y 5HX, UK
b
Blue Globe Solutions Inc (Toronto, Canada) and Global Sea Mineral Resources nv, Antwerp, Belgium
c
JNCC, Inverdee House, Baxter Street, Aberdeen AB11 9QA, UK
d
National Oceanography Centre, European Way, Southampton SO14 3ZH, UK
e
Institute for Advanced Sustainability Studies (IASS), Berliner Strasse 130, 14467 Potsdam, Germany
f
Australian National Centre for Ocean Resources and Security (ANCORS), University of Wollongong, NSW 2522, Australia
g
Centre for Marine and Environmental Research, Universidade do Algarve, 8005-139 Faro, Portugal
h
Universidad Nacional Autonoma de Mexico, Instituto de Ciencas del Mar y Limnologia Unidad Academica, Ecologia Marina Laboratorio, Biodiversidad y
Macroecologia, AP 70-305, Cuidad Universitaria, 04510 Mexico, DF, Mexico
i
University of Hawaii, Department of Oceanography, University of Hawai’i at Manoa, 1000 Pope Road, Marine Sciences Building, Honolulu, Hawai’i, HI 96822, USA
j
South Atlantic Environmental Research Institute, Stanley, Falkland Islands
k
Universidade de Aveiro, 3810-193 Aveiro, Portugal

A R T I C L E I N F O A B S T R A C T

Keywords: The establishment of thresholds is integral to environmental management. This paper introduces the use of
Environmental management thresholds in the context of deep-seabed mining, a nascent industry for which an exploitation regime of regu­
Deep-seabed mining lations, standards and guidelines is still in the process of being developed, and for which the roles and values of
International Seabed Authority
thresholds have yet to be finalised. There are several options for integrating thresholds into the International
Management thresholds
Regulation
Seabed Authority’s regulatory regime, from being stipulated in regulations to being part of a mining contract,
Precaution each option having its own advantages and disadvantages. Here we explore the range of ways that thresholds can
be derived, set out the challenges in translating ecological and management data into thresholds, highlight
factors for acceptance and operationalisation of thresholds in deep-seabed mining, and explain the necessity of
refining thresholds as knowledge on impacts to features improves. Some comparable marine industries already
use thresholds and these could potentially be used as starting points for the development of thresholds for deep-
seabed mining. In order to be acceptable to the wide range of deep-seabed mining stakeholders, thresholds need
to strike a balance among levels of harm acceptable by society, levels of environmental precaution justifiable by
governments, scientific robustness, and operational practicality.

1. Introduction benefits derived from energy production, agriculture and use of motor
vehicles) with potential harms to individuals, society and the environ­
A threshold is an amount, level, or limit of a measured indicator, ment (e.g. risk of collision, risk of fluorosis and other health problems,
created and used to help avoid unwanted change. In the context of health issues associated with pollution). Thresholds will be based on
environmental management, a threshold provides a limit that, when scientific evidence and societal values, both of which may change over
reached, suggests that a risk will – or is expected to - become harmful or time.
unsafe, or provide an early warning of such an occurrence. In our daily Thresholds are an inherent part of science-based environmental
lives, we come across numerous and varied thresholds imposed by local, management [1,18,19] and many regulatory thresholds already exist to
national or international guidance or regulation, ranging from legally help manage levels of human impacts on terrestrial, freshwater and
binding speed limits, the amount of fluoride regulated in drinking water, marine ecosystems. Often such thresholds have been implemented
through to air pollution alerts. The aim of such thresholds is to balance reactively following a dramatic change to an ecosystem, e.g., the
possible benefits (e.g. efficient road travel times, increased oral health, introduction of restrictive catch quotas after the collapse of a fishery

* Corresponding author.
E-mail address: [email protected] (B. Hitchin).

https://doi.org/10.1016/j.marpol.2023.105505
Received 15 July 2022; Received in revised form 22 December 2022; Accepted 22 January 2023
Available online 2 February 2023
0308-597X/© 2023 The Author(s). Published by Elsevier Ltd. This is an open access article under the CC BY-NC license (http://creativecommons.org/licenses/by-
nc/4.0/).
B. Hitchin et al. Marine Policy 149 (2023) 105505

[20]. For emerging industries such as deep-seabed mining (DSM), on the 2.2. Management thresholds
other hand, there is an opportunity to set initial thresholds for envi­
ronmental impacts before the commencement of commercial activities. Management thresholds can be found within environmental impact
Deep-seabed mining in the seabed beyond national jurisdiction (‘the statements, environmental management and monitoring plans, tech­
Area’) is regulated by the International Seabed Authority (ISA), an nical publications, standards, guidelines, permit, licensing or contract
organisation established under the 1982 United Nations Convention on conditions, and are set to prevent human pressures further impacting an
the Law of the Sea [50] (UNCLOS) and the 1994 Agreement relating to ecosystem such that benefits or services cannot be delivered, or that
the Implementation of Part XI of UNCLOS. The ISA is presently devel­ benefits or services are reduced to a level judged to be unacceptable
oping the legal framework for DSM in the form of its ‘Mining Code’, an [21]. Thus, management thresholds are based on both scientific un­
umbrella term for all ISA rules, regulations, and procedures. The Mining derstanding as well as value judgements that involve political, eco­
Code sets out, inter alia, the legal responsibilities of contractors who nomic, social and practical considerations.
hold exploration (and when they become available, exploitation) con­ Legally established terms such as ’serious harm’ or ’material change’
tracts with the ISA, states sponsoring these contracts, and the ISA itself, typically drive the need for establishing numeric management thresh­
comprised at present of 167 Member States and the European Union. olds, and many have been internationally agreed upon (e.g., the Inter­
Key amongst these responsibilities is the obligation to protect the marine national Maritime Organisation’s MARPOL Annex VI pollution
environment, as set out in articles 145, 192, and 194 of UNCLOS and thresholds or the UN Food and Agriculture Organization’s criteria for
reflected in the Mining Code.1 Implementing this obligation requires Vulnerable Marine Ecosystems2). Environmental management plans
finding agreement about the level of environmental harm that is operationalise how environmental objectives and regulations will be
acceptable and that which is not. In the DSM regulatory regime, met, mainly by ensuring that monitored indicators do not exceed pre-
thresholds will need to be established when operationalising environ­ determined thresholds [15].
mental management plans, both for proactive management, by Pragmatic management thresholds are easy to understand, based on
providing guidance about when to intervene in a timely manner to readily measurable and cost-effective indicators that have a straight­
prevent undesirable ecosystem changes before serious harm occurs, and forward and well-understood link to an ecosystem response. For
as hard limits which cannot be exceeded owing to the increasing risk of instance, 350 ppm CO2 in our atmosphere has been widely adopted as a
serious harm occurring. safe level to avoid a cascade of tipping points leading to global
This paper provides an introduction to how thresholds could be used ecosystem change following [22]’s study. Where there is uncertainty or
in DSM environmental management, assessment, and regulation. variability in the way an ecosystem might respond to pressure, as is
Thresholds that have been tested and operationalised in similar in­ expected in the deep sea, management thresholds and their imple­
dustries are presented, and the potential for transferral to DSM scenarios mentation will need to display precaution and be open to adaptation. It
is discussed. Barriers to adoption of thresholds are elaborated, and the is worth noting that multiple thresholds are often used for industry-wide
options for positioning of thresholds within the ISA’s Mining Code are licensing, for example in fisheries management strategies. The New
considered. Zealand Fisheries Harvest Strategy [38] provides one example of how
multiple thresholds are used in practice. Targets are set (e.g., a stock size
2. Thresholds: the basics at/near biomass maximum sustainable yield (BMSY), or about 30%
virgin biomass - dependent on stock productivity) and if the targets are
In environmental management, thresholds can be divided into two met, then no management response is required. The next threshold level
main categories – ecological and management thresholds [21]. entails a soft limit, defined as stock size at 50% BMSY or 20% virgin
biomass. If this soft limit is reached, it then triggers a requirement for a
formal, time-constrained rebuilding and/or management plan. The final
2.1. Ecological thresholds threshold level entails a hard limit (25% BMSY or 10% virgin biomass).
The hard limit provides a biological reference point at which point
Ecological thresholds occur where a system experiences a qualitative closure should be considered for target fisheries.
internal or external change, often in an abrupt and discontinuous way It is envisaged that a similar set of staged thresholds would be useful
[56]. Some of these changes may be reversible, but many are not, and for DSM, relating to minor harm which is deemed acceptable due to
ecological responses to reaching a threshold may vary. These ecological inclusion within a consenting envelope, to moderate harm where a
thresholds are sometimes termed ‘tipping points’ (e.g., [44], [55]), from management response and/or modification is required, and to serious
which the system cannot on its own readily recover. Ecological thresh­ harm (and risk of it), where mining activities would need to be signifi­
olds are often the result of complex interactions among variables – cantly adjusted or stopped entirely. A submission regarding environ­
naturally occurring (e.g., seasonality), and anthropogenic, both mental threshold development was recently made to the ISA Council
long-term (e.g., climate change, nutrient and pollutant input) and [27]. The submission highlights the stepped approach to environmental
short-term (e.g., construction or maintenance operations) at a range of obligations under UNCLOS, related to effective protection, risk of
spatial scales, thereby making them difficult to predict and manage. In serious harm, and the need to develop and implement measurable and
marine management, a now classic example for a system reaching a science-based environmental thresholds linked to those obligations.
tipping point is the severe decline of the Newfoundland cod stocks and In data-limited situations, one may start with broader environmental
the associated shift in the ecosystem to an alternative state where lob­ goals and objectives that must be met, such as a percentage of area/
sters dominated, leading to the closure of the Canadian cod fishing in­ habitat/ecosystem (etc.) that must remain protected, setting more spe­
dustry in 1992 [20]. While the identification of an ecological threshold cific thresholds as more indicator data become available over time.
may make the development of a meaningful management threshold Threshold development is influenced by a wide range of factors that
more likely [19], in practice it can be fraught with a range of social, legal require expertise across several disciplines (Fig. 1).
and political challenges [25] and the direct application of ecological
thresholds to environmental management remains limited (e.g., [12],
[51], [19]).

1 2
See e.g., ISA, Regulations on Prospecting and Exploration for Polymetallic FAO, International Guidelines for the Management of Deep-Sea Fisheries in the
Nodules in the Area, ISBA/19/C/17, 22 July 2013, regulation 31–32. High Seas, 2009, para. 42.

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B. Hitchin et al. Marine Policy 149 (2023) 105505

Box: terminology definitions used in this paper

Indicator: An agreed quantitative or qualitative value or measurable parameter that can be used to provide insight into the state of the
environment, but also to measure effects of specific management measures (adapted from [49]).
Pressure / Stressor: Mechanism through which an activity has an effect on any part of an ecosystem. The nature of the pressure is determined by
activity type, intensity and distribution.
Receptor: Part of the environment on which a pressure has an impact (e.g., organism, habitat).
Serious Harm: Any effect from activities in the Area on the Marine Environment which represents a significant adverse change in the Marine
Environment determined according to the rules, regulations and procedures adopted by the International Seabed Authority on the basis of
internationally recognized standards and practices informed by Best Available Scientific Evidence [26].

Fig. 1. The principal influences on threshold development

and refinement. Note that these include a wide range of
scientific, technical, legal and societal factors that will need
to be considered for individual projects as well as cumu­
latively.
Factors are grouped as follows: green – ability to monitor,
blue – licence to operate (social and legal), dark orange –
ecological understanding and ability to detect changes,
yellow – uncertainty, a factor that pertains to several other
factors, including robustness of forecasting impacts.

3. Threshold development b. Experimental or field-based correlation between the receptor and a

proxy that is simpler to measure (e.g., changes in the grain size
Management thresholds are ideally set using robust baseline evi­ distribution of sediments related to physical habitat stability).
dence, long-term monitoring, environmental understanding, and draw­
ing upon best available practices. Where uncertainties exist (such as for Source 2: Use of the natural variability of a physical indicator
a new industry that does not yet have a track record to draw from), a under baseline conditions (e.g., the baseline range of suspended sedi­
precautionary approach (described below) is needed, and success will ment concentrations found in the habitat prior to the proposed devel­
depend on the ability to translate higher-level policy into what can be opment occurring). This serves the purpose of a base reference against
monitored operationally, e.g., monitoring techniques, size of a site, which the changes due to the implementation of a project are measured.
number of replicates and replicate sites, time required for monitoring, Source 3: Ecological analogues from another environment where
and monitoring frequency. Thresholds may need to be refined as more pressure – receptor relationships are better known (e.g., initially using a
information becomes available, and this process will need to be fully threshold value of suspended sediment concentration that is known not
documented, likely in the Environmental Management and Monitoring to cause serious harm to a comparable receptor). The applicability of
Plan. Thresholds also need to consider not just direct effects but also such analogues to the deep ocean would need to be scientifically
indirect and cumulative effects to the wider biological communities considered prior to their operationalisation. If this involves an assess­
and/or habitats that may go unnoticed if monitoring is focused on direct ment of applicability through component or whole system testing, these
interactions. thresholds may evolve from analogues (Source 3) into Source 1
Management thresholds can be based on a variety of sources, thresholds.
including: Source 4: Numerical modelling of impacts and mortalities can
Source 1: Measurements of change to an indicator species or provide the basis for thresholds that may otherwise be too resource-
environmental condition that is known to reflect harmful impacts/ef­ intensive or ethically challenging to gain through data acquisition (e.
fects more broadly: g., modelling of cetacean noise disturbance thresholds instead of a study
exposing cetaceans to various noise levels).
a. Direct experimental measurements of harmful effects on a receptor Management thresholds derived from measurements (Source 1) can
(e.g., an experiment that investigates the level of suspended sedi­ be developed in several ways. Firstly, they can be estimated from
ment concentration that leads to the death of 50% of organisms of empirical data obtained from experiments. These data are ideally ob­
interest). This could lead to species that act as ’a canary in a coal tained in controlled settings (e.g., using Remotely Operated Vehicle
mine’ for other species that are sensitive, albeit less so, to the pres­ experiments) using factorial experimental designs that investigate the
sure in question. potential impacts of a pressure or a suite of pressures. Such pressures
may affect organisms at various levels of biological organisation,
ranging from cellular and molecular to whole-individual responses that

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B. Hitchin et al. Marine Policy 149 (2023) 105505

in turn can affect population dynamics. Physiological, biochemical and be anticipated.

cellular responses often occur at lower pressure levels than whole-body
responses and thus can serve as early warning indicators for serious 4. Iteration and precaution
harm (e.g., [2]). Ecotoxicological studies are useful in deriving such
links, and they are widely used in informing the setting of thresholds for Already adopted by the ISA in its exploration regulations,3 and as
various pressures and biota. It should be noted that comprehensive da­ included in the draft exploitation regulations, the precautionary
tabases of ecotoxicological studies relevant to the deep sea do not approach calls for precaution that is proportionate to the uncertainty of
currently exist [23] owing to inherent difficulties in retrieving and the situation combined with the potential risk of harm. Where much
keeping deep-sea organisms alive to perform the required experiments remains unknown, the statistical power of baseline information is low,
(e.g., [6]). Thresholds created for a regulatory setting need to take into and where there is potential for lasting harm, precaution requires that a
account the variety of responses across the ecological community and conservative approach is taken towards environmental management
ideally focus on the most sensitive species in a community, although and assessment, with initial thresholds that are also conservative, but
these species may not yet be known or identified in the deep sea. A few which may later be adjusted once more monitoring data and technical
studies have investigated deep-sea (benthic) responses to increased knowledge are available (at different scales).
suspended sediments. To date, these laboratory-based studies have Coupled with precaution is the concept of adaptive management.
focused on coral and sponge responses in relation to drill-cutting ex­ Starting with a conservative threshold(s), regulators can assess the
posures, bottom trawling sediment resuspension, and deep-seabed actual operational impacts (typically through monitoring data provided
mining sediment plumes (e.g. [8], [16], [29], [30], [35], [36], [43], by the operator), and if acceptable, incrementally relax the threshold
[47], [48], [52]). value(s). However, such an approach is likely to require closely moni­
Ecosystem models can aid in investigating how impacts at the species toring a range of indicators (not just the indicator associated with the
level may affect the whole biological community and may need to be threshold) at several representative test locations, using sufficient sta­
considered in combination with the direct measurements. Duration of tistical power to detect minor impacts, i.e., effects that constitute less
exposure to a pressure should also be considered in setting a threshold. than ‘serious harm’. Once a representative range of impacts is charac­
For example, a prolonged exposure of increased suspended sediment terised under normal operating conditions, then management thresholds
concentration is known to lower response thresholds in various aquatic can be refined to better reflect the range of impacts deemed to be
organisms [24,37]. In addition, the combination of increased levels of a acceptable and to maintain compliance. It is envisaged that regulators
pressure and the length of exposure duration to this pressure can be can impose, or contractors can propose refinements. If additional harms
additive [37] or nonadditive [41] and is seldom linear. are discovered during monitoring, this updated information could lead
The second type of management threshold developed from mea­ to a tightening, rather than relaxing, of some threshold values.
surements are those focused on a measured relationship between two As any human activity in the deep sea represents some level of
indicators. If there is a well-known relationship, then the threshold can disturbance, the management thresholds will be a statement of what
focus on the indicator that is simpler and more reliable to measure. This represents ‘acceptable’ levels of harm caused by these activities.
approach has been used by the United Kingdom marine aggregates in­ Defining an acceptable level of harm requires a multicriteria judgement
dustry [13] with post-extraction thresholds for particle size distribution ideally based on empirical data, ecological understanding of the impacts
based on previous scientific investigations of the correlation of grain size on temporal and spatial scales, and a valuation of the losses (to nature,
distribution to the composition of faunal communities. the environment, and to humankind) in comparison to the benefits ex­
Setting management thresholds based on natural variability of (a pected to be gained.
suite of) physical variables (Source 2) is a commonly used approach for
assessing abnormal and likely undesirable environmental conditions, e. 5. Thresholds operational in existing offshore industries
g., in assessments of impacts of climate change (e.g., [46]). This
approach assumes that the natural conditions and variability in which One of the methods listed above for development of thresholds in­
the organisms or communities occur represent boundaries for healthy, cludes the use of ecological analogues. Many environmental thresholds
resilient systems, and is linked to the concept of an ecological niche, or already exist for inshore and offshore activities, such as those for the oil
the range of environmental conditions which allow survival and repro­ and gas and dredging industries, which are operational and part of
duction of organisms and communities. Operationalising this approach existing regulatory regimes. While existing industry thresholds may not
requires baseline data on the variability of the indicator in order to be directly or immediately applicable to DSM, they may provide a
remain within its natural boundaries, but does not require specific in­ reasonable starting point for the development of more specific thresh­
formation on the response of the receptor. Such thresholds may be set olds. The table below (Table 1) progresses the initial exploration of in­
based on the range of variability, another statistical property (e.g., 95% dustry thresholds developed in the ISA’s “Draft standard and guidelines
confidence interval) or a multiple of the natural variability. for the environmental impact assessment process” (ISBA/27/C/4; [27]).
If insufficient site-specific data are available to start with, manage­
ment thresholds may also be set using information or thresholds ob­ 6. Application of existing thresholds to DSM
tained elsewhere, such as from different industries or ecosystems
(Source 3), based on different biological communities than those Operational thresholds that relate to the impacts expected from DSM
observed in the deep sea. This is a practical and quick method in the activities are available in inshore and offshore industries (Table 1). For
absence of empirical data or ecological knowledge. However, deep-sea exploitation of polymetallic nodules, there are analogues with the im­
systems are considered to respond to impacts very differently than pacts known to occur from dredging activities. While the industries
shallow-water systems [7]. They may be more sensitive and have above are generally shallow water (<50 m water depth), the oil and gas
considerably longer recovery trajectories (e.g., [28], [53], [54]). Hence, industry is increasingly operating commercially in waters deeper than
such thresholds may represent a practical starting point, but need to be 1500 m, with the deepest well drilled currently being at over 3400 m
thoroughly tested in deep-sea ecosystems and adapted as appropriate, water depth. Although there are known differences in the responses of
based on new or updated knowledge. deep-water organisms to impacts, some thresholds listed in Table 1
Management thresholds may also be developed from numerical
estimation, informed by qualitative information, models or theory
(Source 4, e.g., [5]. As these usually contain a number of assumptions, 3
See e.g., ISA, Regulations on Prospecting and Exploration for Polymetallic
field-testing and further refinement of the threshold values should also Nodules in the Area, ISBA/19/C/17, 22 July 2013, regulation 31(2).

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B. Hitchin et al. Marine Policy 149 (2023) 105505

Table 1
Examples of thresholds from offshore industries that may be relevant to development of deep-seabed mining thresholds.
Categories Relevant DSM activity Similar operational Examples of known operationalised Comments
activities thresholds

Air Quality Vessel operations Other vessel and platform Revised MARPOL Annex VI (limits air Thresholds would be applicable to vessels
operations pollutants in exhaust gases; shipboard used in DSM operations.
incineration, VOC emissions).
IMO thresholds (Greenhouse Gas
emissions)
Noise Vessel noise Surface vessel operations IMO thresholds (noise in the Some similarity is likely, although DSM
environment). operations in the Area are likely to be in
National and regional disturbance the order of 100–1000s of km from
thresholds for seabirds from marine seabird breeding grounds.
energy installations.
Collector vehicle and riser Dragheads and risers used in Quantitative disturbance and injury As thresholds are present for the full
operation aggregates dredging thresholds for marine mammals from auditory range of marine mammals,
operations; stationary drill impulsive and non-impulsive noise (e.g., thresholds should translate for use in
risers used in oil and gas Temporary Threshold Shift (TTS) onset at DSM operations.
Installation/decommissioning Offshore wind farm 178 dB re 1µPa2s for high frequency Piling for offshore wind is louder, but
activities (piling/explosives) installation marine mammals (non-impulsive noise) shorter lived, compared to DSM
and 170 dB re 1µPa2s) weighted for operations. This may affect suitability of
impulsive noise [45]. thresholds.
The authors are unaware of any
thresholds for deep-sea benthic species
from impulsive or non-impulsive noise.
Light Vessel operations All marine activities There are no international threshold Thresholds in existence for vessels/
requiring light (e.g., levels for light pollution for biota living platforms and deep water ROV/AUV
shipping, oil and gas either in the deep sea or on the sea operations would be applicable to DSM,
platforms) surface. Typically, operations aim to e.g.,[33],[40].
Equipment transiting through the Seafloor vehicles, ROV, AUV reduce the use of light to the extent
water column descents and ascents possible, while allowing for safe
Benthic Collector/Mining Collector operations, operations, and/or use low-level/red
operations, monitoring and monitoring, maintenance of filtered lights to limit interference to
maintenance with ROV/AUV subsea operations marine life.
Water Quality Vessel operations Normal ship discharges (e. IMO thresholds (London Convention/ Thresholds in existence for vessels/
g., sewage treatment, London Protocol measures to prevent platforms should be applicable to DSM.
macerated food waste) pollution by dumping of wastes).
Sediment plume dispersal from All applicable marine Australian and New Zealand water quality These thresholds have been applied to
return water discharge or from activities guidelines (trigger values for marine activities, such as dredging. The
mining operations – related to concentrations of metals and toxicants guidelines were used to define the
spreading of contaminants/metals allowable at alternative levels of “mixing zone boundary” of the sediment
protection (% species protected). [3], [4]. plume for the Solwara 1 project in Papua
New Guinea. [11]
Applicability of these guidelines to
deep-sea species will require further
research.
Sediment plume dispersal related Shallow water sand mining For defined distances, a threshold level of Similar activities are being regulated,
to sediment/turbidity 10 mg/L is set to protect demersal fish though involving different soil/sediment
[17]. types from those of nodule fields
Navigational dredging For the Øresund link project (Sweden/ Continual plume creation as per DSM
(sediment plume from Denmark), the spill budget of suspended requires monitoring for spatial
draghead) sediment flowing outside the project exceedances; While the Øresund link
boundaries was agreed and monitored in work occurred in shallow water and
real time. If exceedances were imminent, faster current regimes, similar sediment
contractor mitigated by either reducing types were involved.
operation rate or by moving to another
dredging area, where budget was still
available [31].
Øresund link – turbidity monitoring used
contiguous thresholds in area of impact
(sedimentation concentrations above a
threshold in 2 fish migration areas, water
visibility in a swan grazing area and for
bathing beaches, sedimentation limits in
areas with mussel beds) [31].
Construction dredging Wheatstone LNG Project, Australia – Continual plume creation as per DSM
works (sediment plume from license included tiered turbidity trigger requires monitoring for spatial
draghead) levels to ensure protection for corals, exceedances; similar sediment types
seagrass and macroalgae. Plume density involved at least in part. However,
monitored through the day using satellite- Wheatstone work occurred in shallow
telemetered water quality instruments water.
[9].
Navigation channel Vale iron ore facility, Malaysia. Sediment Continual plume creation as per DSM
dredging works spill threshold levels defined – 1) a daily requires monitoring for spatial
“spike” exceedance, 2) 3 day running exceedances; similar sediment types
averages and 3) 7 or 14 day running involved.
averages. Level 1 required no immediate However, Vale operations occurred in
(continued on next page)

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Table 1 (continued )
Categories Relevant DSM activity Similar operational Examples of known operationalised Comments
activities thresholds

action. Level 2 required investigation of shallow water and higher current

exceedance and mitigation. Level 3 conditions than expected in the deep
required immediate actions [42]. ocean.
Sediment discharge/ Thresholds exist for contaminants These thresholds may be applicable to
disturbance activities (sediment quality guideline values DSM, however, to establish SQGVs for
(contaminants) (SQGVs)). In Spain, there are 3 action disturbing deep sea sediments,
levels for dumping at sea, according to comprehensive baseline studies would be
concentrations of metal contaminants. needed.
Level C for any metal means that those
sediments are highly contaminated, and
cannot be dumped at sea [10,34].
Spread of invasive Vessel operations Maritime industries covered IMO’s 2019 Ballast Water convention and Applicable to surface vessels in DSM
species by IMO IMO’s 2011 biofouling guidelines. operations.
Sedimentation Sediment plume deposition Oil and gas industry Thresholds for sediment deposition: Similar types of sediment deposition,
(deposition 0–1 mm is negligible impact, 1–3 mm is hence potentially applicable to DSM,
thickness) low impact, 3–10 mm is significant though sensitivities may be different.
impact, >10 mm is considerable impact
[39].
Sediment plume deposition Oil and gas drilling Sediment coverage should be <10 mm in Potentially applicable to DSM, though
total to avoid considerable exposure for sensitivities may be different.
cold water corals [14].

could potentially be considered for transferral and adaptation to a deep- contract,4 emergency orders, which may include orders for the suspen­
sea context. sion or adjustment of operations,5 and potentially compliance notices.6
Thresholds from other offshore industries are potentially comparable Whether there may also be liability issues associated with proven serious
enough to provide a starting point for the development of thresholds for harm (i.e. where there are clear grounds for believing that serious harm
deep-seabed mining for a similar impact, although they may require is likely to occur or has occurred as a result of a DSM activity) is legally
additional precaution to account for unknown differences in the re­ plausible. However, it is not defined whether the liability threshold for
sponses of the ecosystems. These thresholds are often detailed, for compensable damage would actually sit at “serious harm” or perhaps
example, considering plume parameters for sedimentation and con­ below [32].7
taminants. They have all been proven to be measurable, and many of While it is envisaged that the requirement for thresholds would be set
such impacts can be monitored in real time, with enforcement pathways out in the future Exploitation Regulations, and possibly also the current
available if transgressions occur. Both international and site-based Exploration Regulations, the specific threshold values could be specified
thresholds have been considered and made operational. in any number of documents. Table 2 summarises the advantages and
disadvantages of several options.
7. Integration of thresholds, UNCLOS and the Mining Code
8. Discussion and conclusions
To contribute to the environmental management of DSM, thresholds
need to be placed within a regulatory regime. It is envisaged that in the Thresholds are likely to be inherently part of the operationalisation
ISA’s mining regime, thresholds would function to help in achieving of environmental management plans for deep-seabed mining. Develop­
effective protection for the marine environment, as required by Article ment of fair and effective thresholds will require wide-ranging accep­
145 of UNCLOS, and furthermore, should be seen as part of an early tance from scientific, legal, management, and political perspectives.
warning system that alerts the regulator and contractor before serious With the current levels of uncertainty associated with the commence­
harm is caused, to allow for a management response aimed at avoiding ment of DSM exploitation operations, precautionary thresholds adapted
serious harm. Conceivably, this early warning threshold system would from comparative industries may represent a good initial approach.
require at least two regulatory thresholds: first a threshold that indicates However, undesirable ecosystem changes will need to be detectable
movement away from the level of acceptable impact/harm, and second a before serious harm occurs, to trigger initial management actions (such
threshold for risk of serious harm occurring. Further non-regulatory as more detailed or more frequent monitoring and alteration of mining
thresholds may also be chosen between the first and second regulatory practices). Hard limits that cannot be exceeded, owing to the increasing
thresholds to enable a gradation of more finely nuanced management risk of serious harm occurring, will also need to be established.
responses. Setting precautionary thresholds for a given DSM operation It is expected that threshold effectiveness will increase over time. For
that provide adequate protection of the environment, but at the same thresholds to be effective in the environmental management of deep-
time include sufficient flexibility in the selection of practical technology seabed mining, we suggest the following should be met:
and techniques will not be an easy task, and efforts may not strike the
right balance in the first iterations of defining such thresholds.
Pursuant to UNCLOS and the Mining Code, the threat of serious 4
UNCLOS, Articles 162(2)(x), 165(2)(l); ISA, Regulations on Prospecting and
environmental harm may be used to trigger regulatory processes such as Exploration for Polymetallic Nodules in the Area, ISBA/19/C/17, 22 July 2013,
rejection of, or a requirement to amend, an application for a mining regulations 4(3), 21(6), 31(4).
5
UNCLOS, Articles 162(2)(w), 165(2)(k), ISA, Regulations on Prospecting and
Exploration for Polymetallic Nodules in the Area, ISBA/19/C/17, 22 July 2013,
regulation 33.
6
UNCLOS, Article 139, annex III article 22; ISA, Draft Regulations on Exploi­
tation of Mineral Resources in the Area, ISBA/25/C/WP.1, 22 March 2019, draft
regulation 4(5).
7
ISA, Regulations on Prospecting and Exploration for Polymetallic Nodules in the
Area, ISBA/19/C/17, 22 July 2013, regulation 30, annex IV section 16.

6
B. Hitchin et al. Marine Policy 149 (2023) 105505

Table 2 Table 2 (continued )

Options for the placement of thresholds within the ISA’s regulatory regime and Modality Advantages of the potential Disadvantages of the
potential consequences thereof. location potential location
Modality Advantages of the potential Disadvantages of the the broader contract same region, conducted
location potential location consultation process over time
Regulations 1. Consistency across all 1. Difficult for changes to 4. Environmental
mining contract areas be made performance is a strong
2. Transparency (publicly 2. Would not correspond component of the
accessible) with where thresholds sit review/monitoring
3. Subject to public for many other industries sections in the draft
consultation during the 3. Assumes thresholds for Exploitation Regulations
development of the exploitation will be and regular reviews (at
Exploitation Regulations applicable across all least of the EMMP) are
mineral types and all expected
mining contract areas,
which may not be
appropriate 1) A threshold should be SMART (Specific, Measurable, Achievable,
4. Review of regulations, Relevant, Time-bound), with particular emphasis on the need to be
and hence the thresholds, measurable in a timely fashion
is unlikely to be frequent
or regular
2) A threshold should be clearly presented and understandable, with
Regional 1. Would be region and 1. Non-binding unless explanation of why it is appropriate for deep-seabed mining
Environmental resource-specific compliance is required regulation
Management 2. Consistency across through the exploitation 3) A threshold should allow the detection of change and it should be set
Plans (REMP) mining contract areas contract
within a monitoring regime entailing sufficient statistical power to
within a region 2. A process of regular
3. Transparency (publicly review for REMPs is not reliably separate acceptable values from unacceptable ones
accessible) yet established, and there 4) A threshold should relate directly to management actions and envi­
4. Could be subject to may need to be a grace ronmental goals/objectives
public consultation as period allowed for 5) A threshold should incorporate appropriate precaution and the
part of REMP contract conditions to
consultations align with changes to the
ability for incremental improvement
5. Subject to regular review REMP 6) The regulatory framework should require that thresholds be estab­
as part of REMP review lished, and the regulatory framework should provide for compli­
process ance/enforcement measures
Standards 1. Transparency (publicly 1. Unclear whether the
7) The process for threshold development should be inclusive, consul­
accessible) process for making
2. Standards should be changes would be ting stakeholders with a broad range of expertise, experiences, and
regularly reviewed cumbersome values.
2. A process of regular
review for Standards is Each of these requirements comes with its own challenges. While an
not yet established
Guidelines 1. Transparency (publicly 1. Likely to be non-binding
initial threshold could aim to meet some of the above requirements (e.g.,
accessible) (unless specifically refer­ being ‘specific’, ‘relevant’ and ‘time-bound’), realising others (e.g.,
2. Amendments might be enced as binding in the ‘measurable’ and ‘achievable’) will rely on increasing understanding
relatively contracts) gained from baseline and monitoring surveys before and during opera­
straightforward to 2. Usually associated with
tions. In terms of the need for scientific rigour, some industry thresholds
implement in response to voluntary monitoring
updated scientific data and compliance involve statistical testing while others rely on expert judgement. In an
and knowledge environment such as the deep sea, where information is relatively
3. Greater flexibility to put limited, it is possible that some thresholds need to be refined over time
forward a variety of good from a starting point that is mostly informed by expert judgement, an­
practices
Contractual terms 1. Site-specific 1. Less transparent unless
alogues or modelling, but which will move towards greater scientific
2. Operational limits/ contract conditions (or at rigour as more information is gathered. Regardless of how they are first
thresholds described in least the thresholds) are established, DSM thresholds should be open to further refinement. Such
the EIS/EMMP (see stipulated to be made adaptation may be active, through deliberate experimentation, or
below) will likely be public in the exploitation
reactive, through comprehensive monitoring programmes. Whichever
linked with the contract regulations or through
contract conditions. approach (or mix of approaches) is taken, the basis for any DSM
2. May not be subject to threshold needs to be clearly and transparently documented, including
review during the term of the approach used, the indicators on which it is based, assumptions and
a contract, unless there is data sources, monitoring regime to test its efficacy, the statistical power
a specific contract
condition that requires
(i.e., confidence) of that regime, and the process for testing and refining
such a review. it further.
3. May risk inconsistency – While a level of precaution will need to be inherent in their devel­
and therefore opment and management, thresholds also need to be operational. Un­
incomparability –
derstanding and realising that balance will be a central challenge, and
between contracts in the
same region, issued over initially linking thresholds to wider-scale environmental goals and ob­
time jectives may be one way of tackling it, with thresholds being set against
EIA documentation 1. Site-Specific 1. May risk inconsistency – more specific targets as more indicator data become available. Compo­
(EIS and/or 2. Transparency (likely and therefore nent and whole system testing as well as the ramp-up stages of com­
EMMP) publicly accessible) incomparability -
mercial operations would allow not only more detailed understanding of
3. Likely subject to public between contracts in the
consultation as part of these operational indicators and relationships to the requirements of the
Mining Code, but also aid in evaluation of methods and values used by

7
B. Hitchin et al. Marine Policy 149 (2023) 105505

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