The international community’s responsibility
Doing things betterWith many onshore oil, gas and ore deposits now more or less exhausted, the pressure on offshore resources is increasing. Oil and gas have been produced offshore for decades, and companies began extracting these fossil resources in deep water some time ago. By contrast, ore extraction from the seabed has not yet begun. Disasters such as the Deepwater Horizon oil rig explosion and numerous tanker incidents have highlighted the dangers of offshore oil production and transportation.
But onshore too, mining, quarrying and oil production are destroying rainforests and human settlements and polluting soils and rivers. The challenge now is to prevent degradation on this scale from occurring in the marine environment in future by ensuring that marine resource extraction is safe and clean.
Humankind’s most comprehensive treatyThe primary instrument governing the protection of seas is the United Nations Convention on the Law of the Sea (UNCLOS). UNCLOS was adopted at the 1982 UN Conference on the Law of the Sea and came into force, after protracted negotiations, in 1994. It is the “constitution for the seas”. The most comprehensive international treaty ever concluded, it establishes rules for all types of use: navigation, fishing, oil and gas extraction, seabed mining, marine conservation and marine scientific research. To date, 165 states and the EU have signed and ratified the Convention. UNCLOS establishes the general obligation for states parties to protect the marine environment, which is then elaborated in more detail in specific regulations for the various types of use.
UNCLOS applies in principle to all maritime zones and to all states which, by ratifying the Convention, agree to be bound by this legal regime. However, states’ jurisdiction and powers to implement legislation vary in each of the maritime zones. The following legal zones are distinguished: TERRITORIAL SEA: The territorial sea – the 12-mile zone – is the sovereign territory of the coastal state. Activities in this maritime zone are governed by the laws and regulations adopted by the coastal state. Coastal states that have ratified UNCLOS must ensure that their legislation is in line with its provisions. EXCLUSIVE ECONOMIC ZONE (EEZ): The exclusive economic zone starts at the seaward edge of the territorial sea and extends to a distance of 200 nautical miles (approximately 370 km) from the coastal baseline. The EEZ is therefore sometimes known as the 200 nautical mile zone. The seabed and the water column form part of the EEZ. Unlike the territorial sea, this zone does not form part of the coastal state’s sovereign territory. However, each coastal state has exclusive rights to exploit the natural resources there, such as oil and gas, minerals and fish stocks. Other nations may only exploit these resources with the coastal state’s consent. Re-source extraction in the EEZ is governed by the legis-lation adopted by the coastal state, which must be in line with UNCLOS provisions. For other types of use, particularly shipping, the principle of freedom of the high seas applies in the EEZ as well.
4.1 > The United Nations Convention on the Law of the Sea divides the sea into various legal zones, with the state’s sovereignty decreasing with increasing distance from the coast. Every state has a territorial sea, not exceeding 12 nautical miles, which extends from the baseline. In the territorial sea, the sovereignty of the coastal state is already restricted, as ships of all states enjoy the right of innocent passage through it. In the exclusive economic zone (EEZ), which extends for up to 200 nautical miles from the coastal baseline, the coastal state has exclusive rights for the purpose of exploring and exploiting the natural resources, whether living or non-living, of the waters. This means that it is entitled to exploit any oil and gas fields, mineral resources and fish stocks found here. On the continental shelf, which is defined as the natural prolongation of a country’s land territory and may extend beyond the EEZ, the coastal state has sovereign rights for the purpose of exploring and exploiting the natural resources, whether living or non-living, on or under the seabed.
- CONTINENTAL SHELF: The continental shelf comprises the seabed that extends, with a steep or gentle gradient, outward from the coastal baseline and constitutes the natural geological prolongation of the coastal state’s land territory. The continental shelf is of particular economic relevance as it is here that large oil and gas fields, gas hydrates and massive sulphides are found. The “inner continental shelf” has the same spatial scope as the EEZ (200 nautical miles). In some cases, the continental shelf drops to such a depth that it forms part of the deep ocean floor. However, in many parts of the world, there are regions in which an outer continental shelf is geologically identifiable which starts within the EEZ and stretches beyond the 200 nautical mile limit, thereby extending the coastal state’s sphere of influence. The state may apply to establish these extended outer limits of its continental shelf by submitting scientific evidence to the Commission on the Limits of the Continental Shelf (CLCS) in New York. The Commission then makes a binding recommendation on recognition of this outer limit, which may not exceed 350 nautical miles from the baseline. Alternatively, a coastal state may request recognition of an outer limit up to 100 nautical miles seawards – and in some cases even more – from the 2500 metre isobath as the extension of its continental shelf beyond the limits of the EEZ.
- Deep sea
The deep sea refers to the totally dark layers of the ocean below around 800 metres. On some coasts and continent shelves, the transition from the land to deep sea is so abrupt that a depth of 800 metres or more is reached within the EEZ. The coast of Japan is just one example.
- HIGH SEAS: After the 200 nautical mile limit is the maritime zone known as the high seas. No state may subject any part of the high seas to its sovereignty. The high seas are open to all states. Nonetheless, regula-tions apply to the exploitation of the resources of the high seas. Fishing, for example, is regulated by Regional Fisheries Management Organizations (RFMOs), which set a Total Allowable Catch for individual species. By contrast, just one organization – the International Seabed Authority (ISA) established by the United Nations – is responsible for controlling the allocation and exploita-tion of resources in and on the seabed. The Authority’s jurisdiction extends to all mineral resources of the seabed beyond national jurisdiction, which UNCLOS defines as the common heritage of mankind. In simple terms, then, a distinction can be made between national and international maritime zones. The ISA has jurisdiction over marine mining in international waters, including – at least in theory – oil and gas production. However, oil and gas fields are mainly found in the EEZs, so the extraction of these resources in international waters is not an issue at present.
UNCLOS – a long time in the makingWhereas gas and oil fields are mainly located in the EEZs, high-yield manganese nodules and, to some extent, cobalt-rich crusts and massive sulphide deposits are found in the high seas. Experts often use the term “the Area” to denote the seabed, ocean floor and subsoil in international waters beyond the limits of national jurisdiction.
For many years, the allocation of the Area’s seabed resources was a contentious issue for the international community, and this was one of the main reasons why UNCLOS did not enter into force until 1994, 12 years after its adoption by the UN Conference on the Law of the Sea. UNCLOS was conceived in the 1970s, which was a time of great change in two respects. Firstly, with the discovery of extensive manganese nodule deposits in the Pacific, the sea seemed to be a vast repository of natural resources which were there for the taking. Secondly, many former French, British and Portuguese colonies had become sovereign states and were now seeking to cement their political and economic independence, inter alia by asserting their claims to marine resources. Accordingly, in 1982, UNCLOS initially provided for the establishment of an International Seabed Authority (ISA), which in turn was to set up a body, known as the “Enterprise”, to serve as the ISA’s own mining operator. The idea was that benefits would be shared equitably among the various states. Under the Convention, the industrialized countries would share their scientific knowledge and mining technology free of charge for the benefit of all. The former colonies and developing countries ratified UNCLOS immediately, but there were protests from the industrial nations.
- 4.2 > The island state of Nauru is the world’s smallest republic. With an area of around 20 square kilometres, it is roughly twice the size of Capri.
- In subsequent years, the modalities for a future marine mining regime were renegotiated in order to achieve a consensus on UNCLOS. Among other things, the requirement for no-cost technology transfer was dropped, and the establishment of an “Enterprise” was postponed indefinitely. These new rules and amendments were finally incorporated into the 1994 Agreement on Implementation, which supplements the Convention. Today, the rules and regulations contained in the Convention and the Agreement are implemented by three international bodies:
- the International Tribunal for the Law of the Sea (ITLOS) in Hamburg;
- the Commission on the Limits of the Continental Shelf (CLCS), which decides on the extension of individual states’ exclusive economic zones;
- the International Seabed Authority (ISA), which controls seabed mining in the Area.
Clear rules for marine miningThe Convention and the Agreement establish a legal framework formulated in general terms. They do not provide any detailed instructions for practical action. The ISA has thus adopted regulations for each of the three types of mineral resources found in “the Area” – manganese nodules, cobalt-rich crusts and massive sulphides – with detailed provisions on the mining of these resources. At present, these regulations only cover the first two phases of marine mining, i.e. prospecting and exploration. As prospecting merely involves general seismic surveying of the seabed by ship, with minimal ground sampling, prospecting activities simply have to be disclosed to the ISA. Exploration, on the other hand, involves intensive seabed sampling and therefore requires a licence from the ISA. Regulations for commercial exploitation do not exist as yet; a draft regulatory framework for exploitation of manganese nodules is expected in 2016 at the earliest. The absence of a regulatory regime for exploitation is due in part to a number of unresolved environmental issues. Intensive exploration is under way in various areas, and scientists on research vessels are constantly collecting new information about seabed habitats. The findings will feed into the future exploitation regime, which should be in place long before mining of manganese nodules starts. No country currently has any specific plans to begin nodule exploitation.
One authority for all statesThe ISA is a small authority with just 40 permanent members of staff, who come from a variety of countries. It owes its existence to the fact that the international community was able to agree that the use of seabed resources should benefit all states. The ISA is develop-ing clear rules before the exploitation of marine minerals begins. It is the first time in history that such an approach has been taken, and contrasts starkly with the situation onshore where, regardless of the type of resource – coal, oil or gas – exploitation has invariably taken precedence, resulting in environmental degradation, until it was recognised that mistakes had been made and remedial action should be taken.
- 4.3 > The Interna-tional Seabed Authority (ISA), based in Kingston, Jamaica, is responsible for ensuring the equitable sharing of benefits derived from seabed minerals.
- The ISA is also responsible for deciding whether a state or company should receive a licence. To date, the ISA has granted around 25 exploration licences. No exploitation licences have been issued as yet. States wishing to explore an area of the sea must apply to the ISA for an exploration licence, for which a fee of 500,000 US dollars is payable. Private companies can also apply for a licence, subject to their application being sponsored by their home state. The sponsoring state provides guarantees that the company has suffi-cient financial and technical capability, and accepts liability for the company’s activities. An exploration licence is valid for 15 years and may be renewed once for a further five years. It is noteworthy that all the regulations can be expanded and updated on an ongoing basis so that the ISA can bring them into line with new scien-tific findings or extraction technologies.
Under ISA rules, developing countries which lack relevant expertise of their own can participate in deep-sea mining in “the Area” by entering into cooperation with a mining company, provided that the company establishes a subsidiary in the developing country. This is now possible following a decision by the International Tribunal for the Law of the Sea, whereby the developing country must accept liability for the company concerned. One of the first countries to take this path is the island state of Nauru, which is cooperating with a mining company via a subsidiary incorporated in Nauru.
Already regulated: manganese nodule explorationSo far, the regulatory regime for manganese nodules, known as the Regulations on Prospecting and Explora-tion for Polymetallic Nodules in the Area, RPEN, is the most advanced one. This mineral is easier to extract than cobalt-rich crusts and massive sulphides and is likely to be the first to be exploited in “the Area”. The first exploration licences were issued as early as 2001 to six applicants, or “pioneers”: China, Japan, France, Russia, South Korea and the Interoceanmetal Joint Organization (a consortium involving Bulgaria, Cuba, the Czech Republic, Poland, Russia and the Slovak Republic).
The framework for manganese nodules contains 40 Regulations. Among other things, these Regulations state that the applicant must divide the area for exploration into two parts of equal estimated commercial value, each covering no more than 150,000 square kilometres – making two areas, each equivalent to the combined area of England and Wales. The ISA selects one of the two areas for itself – this is then a “reserved area” – and issues an exploration licence to the applicant for the other area.
The “reserved area” can continue to be reserved for the “Enterprise”, to be established at a later date, or may be made available to developing countries wishing to engage in marine mining operations in future. The identity of these countries is still unclear, however. As the “reserved area” has already undergone prospecting, the developing country can dispense with this costly procedure and start exploration directly.
Under ISA rules, the maximum area of 150,000 square kilometres allocated to a state under the licence is subsequently reduced over time. Portions of the area explored – amounting to 75,000 square kilometres after eight years from the date of the contract – progressively revert to the ISA. This procedure is known as “relinquishment”. This means that the contractor cannot place any areas in reserve but must decide early on which area of seabed he wishes to continue to explore with a view to mining there in future. This ensures that a nation does not seize all the most attractive sites for itself. The relinquishment clause does not apply if the total area allocated to a state for exploration is smaller than 75,000 square kilometres.
The regulations governing manganese nodules also contain provisions on the conduct of exploration activities and establish a requirement for environmental impact assessments. Such an assessment must be carried out, for example, during exploration phases with intensive sampling, and must include testing of the equipment and methods to be used. In addition, if trial sediment plume generation is carried out during exploration, this requires an environmental impact assessment. The aim is to determine the impact of large-scale operation of mining vehicles on the seabed. The contractor must report regularly to the ISA on the progress of exploration activities. The ISA may also deploy independent observers on the contractor’s research vessels. There are plans to soon make the rules on exploration even more stringent and detailed. To date, the ISA has approved 13 applications for licences for manganese nodule exploration.
4.4 > Under the ISA Regulations, a country is initially allocated a large exploration area, half of which must later be relinquished to the ISA. This half is then reserved for developing countries. However, the state may not exploit the remaining half in its entirety. Some parts of the area must be excluded in the interests of deep-sea fauna conservation.
Exploring massive sulphides in blocksThe rules applicable to prospecting and exploration for massive sulphides and cobalt-rich crusts are similar to those which apply to manganese nodules, but there are some variations on points of detail.
The Regulations on Prospecting and Exploration for Polymetallic Sulphides in the Area, adopted in 2010, apply to the known hydrothermally formed deposits of sulphides, including some 165 deposits whose exploitation appears to be viable. Under the Regulations, the area covered by each application may not exceed 300,000 square kilometres in size. The subsequent exploration must then be confined to a small part of this area, comprising not more than 100 blocks of at most 10 by 10 kilometres. The blocks must be arranged by the applicant in at least five clusters. The ISA’s purpose, in adopting these provisions, is to ensure that companies or states do not secure high-yielding sites for themselves across a wide area but confine their activities to small areas. As a result, the actual exploration area ultimately amounts to no more than 10,000 square kilometres (100 blocks of 100 square kilometres). These Regulations also contain a relinquishment clause. Within specified time periods, the contractor must relinquish the major part of the area allocated for exploration, with the remaining area allocated after relinquishment not exceeding 2,500 square kilometres. This remaining area would presumably offer the applicant the best prospects for exploitation of the resource, with the rest being relinquished to the International Seabed Authority. So here too, the area ultimately remaining for commercial exploitation is significantly reduced. Applications for prospecting and exploration of massive sulphides have been submitted by China, France, India, Russia and South Korea. Germany is currently pre-paring an application.
Rules on the exploration of cobalt-rich crustsThe latest Regulations on Prospecting and Exploration for Cobalt-rich Ferromanganese Crusts in the Area were adopted at the 18th session of the ISA in 2012. Here, the challenge was to develop rules for a resource for which no feasible mining technology currently exists. Furthermore, the crusts are found on seamounts, which are known to be particularly species-rich habitats, and many of which are already at risk from fishing and bottom trawling. Mining would intensify the pressure on these habitats.
Under the Regulations, the area covered by each application for prospecting must be located entirely within a geographical area measuring not more than 550 by 550 kilometres. The area covered by subsequent exploration must comprise not more than 150 cobalt crust blocks no greater than 20 square kilometres in size, which must be arranged by the applicant in clus-ters consisting of no more than five blocks. By the end of the tenth year from the date of the contract, the contractor must have relinquished to the ISA at least two thirds of the original area allocated to it.
The ISA is currently considering a Russian application. China and Japan have already been issued with exploration licences, making China the first country in the world to hold exploration licences for all three types of marine mineral resources.
Precautionary approach The precautionary approach is applied in risk management and was among the principles adopted at the 1992 United Nations Conference on Environment and Development (UNCED) in Rio de Janeiro. According to the precautionary approach, where there are threats of serious or irreversible damage to the environment, lack of full scientific certainty shall not be used by states as a reason for postponing measures to prevent environmental degradation. The precau-tionary approach was incorporated into the Rio Declaration as Principle 15.
Clearing the way for exploitationUnder all three sets of Regulations, the ISA, by granting a licence, expects the states engaged in exploration to maintain standards of good conduct. Should it transpire, during exploration, that the applicant is causing excessive damage to the natural environment or is failing to comply with the rules, an application to extend the exploration period or to exploit the marine mineral in future may be denied. Indeed, the ISA has the power to withdraw the licences for all three marine minerals. Regulations on the exploitation of marine minerals have not yet been finalized. However, in 2012, the Secretary-General of the ISA presented a workplan and timetable for the formulation of regulations on manganese nodule exploitation, to be established prior to 2016. The regulations are to include the following provisions:
- Exploitation should start with a mining test on a 20 to 50 per cent commercial scale. It is anticipated that the data and information obtained from this mining test will feed into the regulations, particularly as regards safety and the protection of the marine environment.
- Comprehensive environmental monitoring must be established and other environmental impact assessments performed throughout the exploitation phase. Monitoring means continuous long-term scientific observation and documentation of all operations, whereas environmental impact assessments are additionally carried out for individual activities. Monitoring and assessments should be updated regularly to take account of the latest scientific knowledge and mining technology.
- dContractors must provide detailed information about the entire production process, including informa-tion on collection techniques; depth of penetration into the seabed; methods for nodule separation and washing on the seafloor; methods for transporting the nodules to the surface; methods for discharging production residues (tailings); location and duration of the mining test; and environmental impacts.
It is unclear, at present, how high the mining royalties should be in future. It is essential to determine whether the best system would be based solely on mining royalties or involve a combination of royalties and profit-sharing for the ISA. In addition, a fixed an-nual fee – in an amount that has still to be determined – could become due at the start of production. For the mining companies, these financial arrangements – alongside environmental protection obligations – will be a crucial factor in their decision on whether or not to begin marine mineral exploitation in “the Area“.
For the future, the ISA is planning to incorporate the comprehensive set of rules, regulations and procedures for prospecting, exploration and exploitation of marine minerals in the international seabed area into a single item of legislation known as the Mining Code.
The “Enterprise” – the ISA’s commercial armInterestingly, the debate about the establishment of an “Enterprise“, as the commercial arm of the ISA, has recently resumed. This was prompted by a proposal received by the ISA from an Australian/Canadian mining company to develop a joint venture with the “Enterprise“ and to contribute the requisite mining technology. The establishment of such an undertaking is entirely possible, in principle, within the framework of the UNCLOS Agreement on Implementation and would in no way conflict with the concept of equitable benefit sharing. The “Enterprise“ would not compete with indi-vidual states for areas of the seabed but would undertake mining operations in unallocated areas. The benefits would then be shared equitably. This would mean that there would be two strands to the ISA’s work in future: it would continue to act as the authority responsible for issuing licences, and would also operate as the “Enterprise“. At present, however, there are no clear rules for the establishment of the ”Enterprise“, and the ISA therefore regards the founding or planning of a joint venture as premature. It is likely to be some years before relevant rules are in place.
- 4.5 > The Clarion-Clipperton Zone (CCZ) in the Pacific has the world’s largest known deposits of deep-seabed polymetallic nodules, covering an area approximately the size of Europe. To date, the International Seabed Authority (ISA) has issued 12 exploration licences for the CCZ. Designation of the reserved areas and areas of particular environmental interest (APEIs) has already taken place.
Mining and nature conservation – squaring the circle?By far the largest known deposits of marine mineral resources in the world are in the Clarion-Clipperton Zone (CCZ) in the Pacific, where many billions of tonnes of manganese nodules extend across an area the size of Europe. In order to protect and preserve habitats of a significant size in this vast area, the ISA adopted an environmental management plan for the CCZ at its 18th session in 2012. The plan identifies nine Areas of Particular Environmental Interest (APEIs) in the CCZ, where extraction of marine minerals is prohibited. Each APEI consists of a quadrilateral core area of at least 200 km in length and width, surrounded by a buffer zone, 100 km wide, in order to ensure that benthic communities in the APEIs are not buried or adversely affected by mining plumes drifting in from areas where extraction is under way. This means that there are, in total, nine 400 by 400 km protected areas in the CCZ, each with a total area of 160,000 square kilometres. Together, the nine APEIs thus cover almost 1.5 million square kilometres – around one-sixth of the CCZ and equivalent to an area twice the size of Turkey. At present, an environmental management plan and APEIs only exist for the CCZ; there are none for other licence areas, such as those in the Indian Ocean, although according to experts similar arrangements are needed elsewhere as well.
The environmental management plan goes even further. Not only does it designate 9 APEIs; it also obliges contractors to designate areas that are representative of the full range of habitats and species assemblages before exploitation begins. These reference zones should be of sufficient size, have similar topography and biodiversity to the impact zone, and must not be mined. In practice, this means that the licence areas will not be worked in their entirety, but only in specific sections. The aim is to preserve natural habitats as a basis for the subsequent recolonization of the mined area. The ISA is currently developing guidelines for such reference areas. However, critics point out that there is currently a lack of information and data relating to habitats in the CCZ and a lack of standards for the surveying and assessment of habitats as a viable basis for the selection of reference zones. This would be vital in view of the over-all purpose of the zones, namely to preserve representative habitats. They also stress that special protection is needed for habitats with endemic biotic communities.
The demise of the commonsDespite criticism that the ISA lacks the capacities need-ed to implement comprehensive protection regimes in all the international waters, the ISA’s work is regarded as well-nigh exemplary, for it operates in accordance with the precautionary approach, one of the guiding principles established, inter alia, in the Convention on Biological Diversity. Moreover, the ISA ensures the equitable distribution of resources defined as the common heritage of mankind. Scientists thus view with concern the efforts being made by some states to extend their jurisdiction beyond the limits of their EEZs into the outer continental shelf. The exemptions in the UNCLOS provisions on the continental shelf, which are invoked by these countries, mean that they would then be able to claim exclusive rights to the marine mineral deposits located in these outer areas.
According to experts, these exemptions – which were originally to be invoked in exceptional circumstances – are creating some bizarre scenarios. Russia, for example, is currently claiming around 40 per cent of the international Arctic seabed as its continental shelf, arguing that the undersea mountains in the central Arctic, such as the Gakkel Ridge, are a geological formation originating in the Russian EEZ, and that in accordance with this definition, Russia should be able to extend its area of jurisdiction to 350 nautical miles. UNCLOS also provides for the extension of the continental shelf to 100 nautical miles (nm) seawards from the 2500 metre isobath. This would enable Russia to extend its jurisdiction even further, beyond the 350 nautical mile limit. As the Russian authorities see it, the permissible combination of these two methods should allow Russia to claim 40 per cent of the Arctic seabed and the marine mineral deposits located there. However, the Commission on the Limits of the Continental Shelf dismissed Russia’s application in 2009 and called for more detailed geological surveys. Since then, Russia has launched several expeditions to collect geological data as evidence that the undersea ridges in international Arctic waters are submerged extensions of the geological formations found in its EEZ. In late 2013, Canada also announced that it was claiming an extension of its Arctic continental shelf as far as the North Pole. In 2014, Russia plans to resubmit its application with new data – coinciding, incidentally, with Denmark’s expected application to extend its continental shelf north of Greenland. Denmark, Canada and Russia are not isolated cases.
- 4.6 > With the expansion of the coastal states‘ exclusive economic zones (green) into the outer continental shelf (orange), the international waters and seabed area are reduced, representing a loss to the interna-tional community. Antarctica, however, has special status. Some states are claiming an EEZ here, as shown on the diagram, but these territorial claims are not recognised under international law.
The term „commons“ is used to denote land that is used collectively by members of a community; examples are fields, grazing areas and woodland pastures. Economists and social scientists also use the term in non-agricultural contexts, applying it, for example, to fisheries in international waters. The “tragedy of the commons” is a phrase that is frequently heard, the tragedy being that these shared resources, being available to everyone, are quickly depleted and destroy-ed by individuals acting according to their self-interest.
- Currently, 78 countries are claiming a continental shelf expansion beyond their existing EEZs. The ISA has received seven applications backed up by information to justify expansion, and a further 46 provisional submissions for which scientific informa-tion may be submitted at a later date. The Commission has not yet dealt with these latter submissions because – as in the case of Russia – there is still a lack of detailed scientific data proving that the geological formations in and outside the EEZ are connected. According to experts in the Law of the Sea, this trend towards continental shelf expansion profoundly undermines the original concept of “the Area” as a form of commons, based on the principle that the seabed and its resources should be used for the benefit of all nations equally. What’s more, in some regions, the 200 nm EEZs already occupy most of the sea area. In the Pacific, for example, the individual island states lie so far apart in some cases that despite their small land area, they can claim vast areas of the sea as their exclusive economic zones, which means that the international community has no claim to many of the resources found there. The EEZs already occupy around one third of the total area of the sea, and the claims for continental shelf expansion submitted to the Commission would increase this by a further 8 per cent.
An end to this trend is not yet in sight. Some submissions have already been approved by the Commis-sion, such as those lodged by the United Kingdom and Ireland to extend their continental shelves farther out into the Atlantic. The United Kingdom has a particular interest in producing oil here and is seeking partners to engage in oil production in this new territory.