ISA Stakeholder Consultation Process: Why Twenty-Three Submissions Mattered More Than You Think

The International Seabed Authority’s description of its own consultations is disarmingly bureaucratic. A note verbale here, a consultation guide there, twenty-three submissions tallied like exam papers. And yet, beneath all that procedural calm, the ISA is doing something genuinely difficult: trying to figure out how an obscure UN body, headquartered in Kingston, should talk to the world about the deepest, least understood part of the planet.

The Authority held public discussions on its draft Strategic Plan in March and April of 2018. The window was only slightly longer than six weeks. Members sent in fifteen submissions, contractors three, observers four, and one came from a single individual whose identity is buried somewhere in the record. It’s a small number, honestly. For a process meant to set the direction of seabed governance for half a decade, twenty-three responses feels almost intimate. But that, perhaps, is the nature of this particular corner of multilateral life.

The Secretary-General, in those weeks, moved between Kingston and the Permanent Missions in New York, holding meetings that rarely make headlines. Diplomats nodding politely over draft language. Contractors quietly pushing for clarity on timelines. Observers, mostly environmental groups, asking the questions everyone in the room would rather defer. There’s a sense, watching these processes unfold, that the ISA is simultaneously trying to be a forum and a referee, and the two roles don’t always sit comfortably together.

A year later, in May 2019, the High-Level Action Plan went out for similar review. Thirteen submissions were returned. Two from observers and eleven from members. Smaller again. It’s possible that consultation fatigue had set in, or that stakeholders simply trusted the document more. It’s also possible that the deeper conversations were happening elsewhere, in side meetings and informal exchanges, where the real bargaining tends to live.

What makes the ISA’s consultation question genuinely interesting, though, is not the count of submissions. It’s the moment the Authority finds itself in. For decades, it has functioned mainly as a convener, a place where states discussed seabed minerals in the abstract. Now, with exploitation regulations being drafted, it is becoming a regulator of an actual industry. That shift changes everything. A convener can afford to listen politely; a regulator has to decide who counts, whose objections are heard, and whose are filed away.

The Pew Charitable Trusts captured this tension bluntly in its response to the Zero Draft of the Communications and Stakeholder Engagement Strategy circulated in December 2020. Their critique, while diplomatic in tone, was sharp in substance. The draft, they argued, read less like a vision for participation and more like a catalogue of restrictions. It mapped the rules without explaining the principles. That is a significant burden for an organization that formally acts on behalf of all people.

Furthermore, it’s difficult to ignore the larger context in this situation. Everywhere, international organizations are under pressure to demonstrate their legitimacy, especially when their choices have an impact on the environment that cannot be reversed. The various human rights frameworks on information access, SDG 16, and the 2030 Agenda all work toward the same goal. Not less, but more transparency. It’s still unclear if the ISA’s approach ultimately reflects that pressure or deftly avoids it. We will learn a lot about the type of organization the Authority wants to become from the upcoming round of drafts and the ensuing consultations.