# A stakeholder perspective on the drivers and barriers influencing the emergence of deep-sea mining

Manuel Bellanger, Pierre Scemama, Denis Bailly, Shani Friedman, Ugo Massé,

Joëlle Richard, Olivier Thébaud

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Manuel Bellanger, Pierre Scemama, Denis Bailly, Shani Friedman, Ugo Massé, et al. A stakeholder perspective on the drivers and barriers influencing the emergence of deep-sea mining. Resources Policy, 2025, 105, pp.105623. 10.1016/j.resourpol.2025.105623. hal-05244814

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# A stakeholder perspective on the drivers and barriers influencing the emergence of deep-sea mining

Manuel Bellanger<sup>a, *</sup>, Pierre Scemama<sup>a, ∗</sup>, Denis Bailly<sup>b, ∗</sup>, Shani Friedman<sup>b, c</sup>, Ugo Massé<sup>b</sup>, Joëlle Richard<sup>b, †</sup>, Olivier Thébaud<sup>a, †</sup>

ARTICLE INFO

Keywords:

Deep-seabed mining

Deep-sea minerals

Governance

PESTEL analysis

Stakeholder perceptions

Expert knowledge

A B S T R A C T

The identification of drivers and barriers influencing the initiation of commercial deep-sea mining (DSM) is key to developing research approaches to support the development of adequate DSM management frameworks. This study aims to provide a systems-level understanding of DSM drivers and barriers integrating both academic literature and diverse stakeholder perspectives (industry, NGOs, policy-makers, and academic researchers). To this end, we carry out a political, economic, social, technological, environmental, and legal (PESTEL) analysis combining the results of a literature survey, a participatory workshop, and semi-structured interviews. The results provide a broad overview of scientific knowledge and uncertainties relating to DSM drivers and barriers identified in the literature, alongside a synthesis of emerging perspectives and concerns expressed by stakeholders during the participatory workshop and interviews. The discussion highlights both areas of consensus and divergence across stakeholder groups and the literature, as well as a critical reflection on the relevance and limitations of the PESTEL approach, highlighting research needs to further support holistic decision making around DSM.

1. Introduction

Deep-sea mining (DSM) – the extraction of minerals from the deep seabed (below 200m ocean depth) – is a pressing and controversial topic (Beaulieu et al., 2017; Kim, 2017; Miller et al., 2021; Hallgren and Hansson, 2021; Jaeckel et al., 2023; Klimaåuskaité et al., 2024). While some states and a few companies aim to start commercial mining for deep-sea minerals in the near future, the movement or coalition advocating for a moratorium on DSM is growing (Singh et al., 2025), with at least 32 Countries,<fnref n="1" /> 35 multinational corporations,<fnref n="2" /> 20 financial institutions,<fnref n="3" /> over 100 NGOs,<fnref n="4" /> and more than 900 marine science and policy experts<fnref n="5" /> from around the world having expressed their support for a moratorium or a precautionary pause, as of March 2025. Considerable concerns have been raised about DSM's potential to cause

biodiversity losses and broader environmental impacts (Niner et al., 2018), social implications (Childs, 2020), as well as geopolitical, legal, and political economy issues (Carver et al., 2020).

Current governance frameworks for DSM are fragmented and incomplete (Pickens et al., 2024; Yu et al., 2025), creating challenges for ensuring adequate protection of deep-sea ecosystems and the ocean as a whole (Thompson et al., 2018; Friedman, 2024a). Because DSM will have impacts on other ocean resources and users, it is essential to consider DSM governance holistically, taking into account interactions across sectors and the cumulative effects of human activities on marine ecosystems (Tunnicliffe et al., 2020). In this context, the development of responsible DSM governance regimes needs to foster an ecosystem-based management (EBM) approach (Christiansen et al., 2022; Guilhon et al., 2023), which is widely recognized as best practice

<footnote><sup>a</sup> Ifremer, Univ Brest, CNRS, IRD, UMR AMURE, Unité d'Économie Maritime, IUEM, Plouzané, France</footnote>

<footnote><sup>b</sup> Univ Brest, Ifremer, CNRS, IRD, UMR AMURE, IUEM, Plouzané, France</footnote>

<footnote><sup>c</sup> The Hebrew University of Jerusalem, Law Faculty, Israel</footnote>

<footnote>* Corresponding author.</footnote>

<footnote>E-mail address: manuel.bellanger@ifremer.fr (M. Bellanger).</footnote>

<footnote n="1">¹ See https://deep-sea-conservation.org/solutions/no-deep-sea-mining/momentum-for-a-moratorium/governments-and-parliamentarians/.</footnote>

<footnote n="2">² See https://www.stopdeepseabedmining.org/ endorsers/.</footnote>

<footnote n="3">³ See *supra* note 2 and Besson et al. (2024).</footnote>

<footnote n="4">⁴ See https://deep-sea-conservation.org/wp-content/uploads/2024/01/DSCC_FactSheet3_DSM_MORATORIUM_4pp_OCT_23.pdf.</footnote>

<footnote n="5">⁵ See https://seabedminingsciencestatement.org/.</footnote>
to promote ocean conservation and sustainable use in an equitable way (McLeod and Leslie, 2009) and is the overall direction in which any ocean-related industry is required to project itself globally (Long et al., 2015; Link et al., 2019).

The development of research approaches and tools needed to support responsible governance regimes (Berkes, 2012; Bellanger et al., 2020) and EBM (Levin et al., 2009; Link and Browman, 2014) requires a systems-level understanding of DSM-related issues, i.e. an integrated perspective that identifies the key natural, human and management elements to be considered to anticipate the implications of alternative governance options (Folke, 2006; Ostrom, 2009; Link et al., 2017; Hyman et al., 2021; Tilot et al., 2021a). Governance decisions around DSM involve navigating trade-offs across a wide range of dimensions, including geopolitical issues, economic benefits and challenges, environmental and social impacts, as well as technological and legal considerations (Giurco and Cooper, 2012; Vivoda, 2024). Notably, DSM governance is shaped by the interaction of drivers (motivations for mining) and barriers (including constraints and reasons for a moratorium). Only a few studies have examined DSM issues from a holistic perspective, focusing on existing literature on the impacts of DSM on global energy security (Vivoda, 2024) or on conceptual management models (Hyman et al., 2021, 2022; Tilot et al., 2021a). However, a systems-level perspective that integrates stakeholder knowledge and views is lacking, despite this need being underscored by Hyman et al. (2022). Against this background, our research question is: how can we build a systems-level understanding of DSM-related issues that integrates both existing literature and stakeholders' perspectives?

Our study aims to provide a broad overview of political, economic, social, technological, environmental, and legal (PESTEL) factors that could affect the start of commercial DSM exploitation. To this end, we implemented a mixed methods approach combining a survey of the literature and a stakeholder consultation aimed at integrating expert knowledge (industry, NGOs, policy-makers, academic research) into the PESTEL analysis. The PESTEL framework is a flexible analytical tool used to identify key external drivers influencing an industry or a business (Stuiver et al., 2016). For example, the PESTEL framework has been used to examine emerging sectors such as cloud computing (Issa et al., 2010) or the waste-to-energy incineration industry (Song et al., 2017). In this study, we apply the PESTEL framework to the case of the emerging DSM sector to lay the groundwork for a systems-level understanding of drivers and barriers to DSM. Notably, the scope of this work spans both DSM activities in areas beyond national jurisdiction (ABNJ) and within national jurisdiction, as building a systems-level perspective requires consideration of the potential interactions between the two, including geopolitical dynamics and social and ecological implications for which such jurisdictional delineation may not be relevant.

The paper is structured as follows: section 2 provides theoretical background on DSM governance and EBM as well as on the literature on DSM drivers and barriers; section 3 presents our methodological approach; section 4 presents the results of the PESTEL analysis; section 5 discusses the key findings as well as the limitations of our approach, highlighting research needs to further support holistic decision making around DSM.

## 2. Theoretical background

### 2.1. DSM governance and the need for EBM

DSM activities can occur in the international seabed beyond national jurisdiction ('the Area') or within the Exclusive Economic Zones (EEZ)

and the extended continental shelf of coastal states that are under national jurisdictions (Willaert, 2020). DSM activities in the Area are governed by the UN Convention on the Law of the Sea (UNCLOS) and the 1994 Agreement relating to the Implementation of Part XI concerning the Area.<fnref n="6" /> The Area and its resources are defined as the 'common heritage of mankind', meaning no state or other non-state actor can claim sovereignty in the Area.<fnref n="7" /> Exploration and exploitation of the resources in the Area can only be with the approval and under the regulation of the International Seabed Authority (ISA), which was established by UNCLOS. UNCLOS requires the ISA to develop and adopt regulations (procedural rules) on the exploration and exploitation of the Area, ensuring that DSM activities are conducted "for the benefit of [hu] mankind as a whole"<fnref n="8" /> and with due regard for "the effective protection of the marine environment from harmful effects which may arise from such activities".<fnref n="9" /> The ISA adopted regulations for exploration of the Area. So far, the ISA has entered into 31 exploration contracts with 22 contractors. However, the regulations for exploitation in the Area are still being negotiated and have not been adopted yet (Pickens et al., 2024), and no exploitation contract has been signed.

The ISA has largely incorporated EBM principles into its regulatory framework (Guilhon et al., 2021; Christiansen et al., 2022). EBM is a holistic management approach that considers the entire ecosystem, including humans, acknowledging the full array of interactions and cumulative impacts of different activities (Long et al., 2015). EBM has been explicitly referenced in ISA's Regional Environmental Management Plans (REMPs) (ISA, 2012; Wedding et al., 2013, 2015), and EBM principles are broadly reflected in the draft regulations for exploitation in the Area (Guilhon et al., 2021).

Within national jurisdictions, individual coastal states have the sovereign right to regulate DSM activities within their (EEZ) and extended continental shelf. In recent years, several coastal States, such as the Cook Islands, Norway, Papua New Guinea, Sweden, China, and Japan, have initiated efforts to explore and prepare for the potential extraction of deep-sea mineral resources within their EEZ (Besson et al., 2024). These preparations include the development and evolutions of relevant national regulatory frameworks (Willaert, 2021; Tilot et al., 2021b). While the approaches to governance vary among states, UNCLOS obliges coastal States to ensure that their regulatory regime for seabed activities within their jurisdiction is "no less effective than international rules, standards and recommended practices and procedures" in regard to preventing, reducing and controlling pollution of the marine environment<fnref n="10" />. Therefore, EBM principles embedded in the ISA's regime for DSM in the Area are also expected to be relevant for DSM governance within EEZs.

Concrete steps towards operationalizing EBM for DSM are still lacking (Guilhon et al., 2023). In practice, EBM necessitates a comprehensive understanding of how social-ecological systems (SESs) are structured and function before any human activities takes place (Curtin and Prellezo, 2010; Guilhon et al., 2021). SESs are complex adaptive systems in which human and ecological components are tightly linked and interdependent (Berkes and Folke, 1998). SES theory (see e.g. Biggs et al., 2021 for a review), originating from systems thinking (Ackoff, 1971) and complex adaptive systems theory (Holland, 1992), underscores that the study and governance of SESs should integrate factors that could affect how resources are used across the social, economic, environmental, political, and other dimensions, i.e. take a holistic,

<footnote n="6">⁶ UNCLOS, Part XI; Agreement relating to the implementation of Part XI of the United Nations Convention on the Law of the Sea of 10 December 1982, UNGAOR, 48th Sess, UN Doc A/RES/48/263 (17 August 1994) (Part XI Agreement)</footnote>

<footnote n="7">⁷ UNCLOS, Articles 136-137.</footnote>

<footnote n="8">⁸ UNCLOS, Article 140.</footnote>

<footnote n="9">⁹ UNCLOS, Article 145.</footnote>

<footnote n="10">¹⁰ UNCLOS, article 208.</footnote>
systems-level perspective (Ostrom, 2009; Link et al., 2017; Aggarwal and Anderies, 2023). The identification of drivers and barriers with regards to the emergence of DSM is thus key to developing research approaches to support EBM for DSM (Gurco and Cooper, 2012; Hyman et al., 2022; Vivoda, 2024).

## 2.2. Literature on DSM drivers and barriers

Existing studies aimed at identifying the drivers of DSM have largely focused on economic and geostrategic factors (Roche and Feenan, 2013; Hyman et al., 2022; Vivoda, 2024). States and industry interests in exploiting deep sea minerals, such as polymetallic nodules, seafloor massive sulfides, and cobalt-rich crusts, are driven by the escalating demand for metals used in 'green' technologies such as electric vehicle batteries and renewable energy systems (Hallgren and Hansson, 2021; Hyman et al., 2022). Governments seek to diversify supply of critical minerals to reduce reliance on imports from geopolitically sensitive regions (Vivoda, 2024), while corporations are attracted by the opportunities for future profits (Sharma, 2011). Other potential drivers such as providing benefits to mankind as a whole, alleviating poverty, as well as reducing social and environmental impacts of land-based mining have been discussed in the literature (see e.g. Madureira et al., 2023); however, these have been challenged (Klimašauskaitė et al., 2024) and are often considered as "claims" (Hyman et al., 2022), "corporate strategies" (Childs, 2019), or "narratives" (Childs, 2020; Hallgren and Hansson, 2021) used by proponents to legitimize DSM.

The literature has also investigated barriers to DSM, with studies generally focusing on particular thematic challenges or geographical regions. This literature includes, for example, surveys of: challenges to technological developments (Petersen et al., 2017; Hein et al., 2020; Cheng et al., 2023); legal and policy issues (Pickens et al., 2024); environmental impacts and knowledge gaps (Miller et al., 2018; Amon et al., 2022); and barriers to environmental management (Hyman et al., 2022). Gurco and Cooper (2012) reported concerns expressed by industry and government representatives for the case of DSM in Australia. Ribeiro et al. (2020) examined scientific, technical and legal obstacles and challenges for DSM in the Portuguese continental shelf. While there are multi-disciplinary reviews spanning environmental, legal, socio-economic aspects (Koschinsky et al., 2018; Levin et al., 2020), the literature on DSM barriers remains largely fragmented and lacks integration of the diversity of stakeholder perspectives overall.

# 3. Material and methods

## 3.1. Implementing a PESTEL approach

In this study, we carried out a PESTEL analysis to identify drivers and barriers with regards to the emergence of DSM. The PESTEL framework is a strategic analysis framework used to examine the external macro-environmental factors affecting industries and organizations (Stuiver et al., 2016). It breaks these factors into six key categories: (1) political factors, which typically cover government policies, political stability, lobbying activities, international relations, and geopolitical dynamics; (2) economic factors, which refer to economic conditions in the operating environment, including production costs, economic benefits, public and private investments, market dynamics and incentives, and interactions among industry sectors; (3) social factors, which include public perception and awareness, protest movements, equity considerations, ethics, and cultural attitudes; (4) technological factors, which typically focus on technological developments and their influence on industries and practices; (5) environmental factors, which encompass ecological impacts, unintended effects on resources used by other sectors, corporate sustainability and links to climate change; and (6) legal factors, which include laws, regulations, and legal regimes governing activities (Kokkinos et al., 2023). The PESTEL framework can be employed as a diagnostic tool to understand the impact of external

factors on specific sectors (López Gómez et al., 2023), as a comparative framework to evaluate macro-environmental conditions across different regions or case studies (Zentner et al., 2020), or as a scenario building tool to analyze current trends and anticipate potential future developments (Kokkinos et al., 2023). Finally, it can serve as a framework to analyze stakeholder perspectives on a specific issue (Bitoun et al., 2023).

We operationalized the PESTEL framework through three complementary research methods: (1) a literature survey aimed at synthesizing scientific knowledge, gaps, and uncertainties; (2) an online stakeholder workshop that gathered policy-makers, industry, NGOs, and academic researchers, aimed at collecting expert knowledge, emerging perspectives, and stakeholder-specific concerns; and (3) a series of interviews with non-academic actors (policy-makers, industry, and NGOs), aimed at deepening the understanding gained through the workshop. Notably, the selection of participants for the interviews focused on policy-makers, industry, and NGOs, considering that the views of research scientists were already well captured through the literature review and the participatory workshop. We employed purposive sampling where potential workshop and interview participants were identified and selected based on their expertise and institutional roles with the aim of ensuring a diversity of perspectives and adequate representativeness.

For each of the three research methods (literature review, workshop, and interviews), we organized the results following the PESTEL framework (Fig. 1). Data was analyzed in order to obtain quantitative indicators related to the distribution of PESTEL factors to characterize our material and contextualize the results with regard to potential imbalances across research methods and PESTEL dimensions. In addition, we conducted qualitative content analyses to explore in detail the various drivers and barriers regarding the emergence of deep-sea mining.

The categorization of factors according to the PESTEL categories can be ambiguous when factors lie at the intersection of multiple categories. For example, the cost of technology development is relevant to both the economic and technological categories. For the presentation of results in section 4, we generally categorized factors based on the outcome of the participatory workshop during which participants identified themselves the categories associated with the factors. Some factors still appear in multiple categories when it is clear that they were used to support different ideas. For instance, challenges within the ISA were clearly identified in the literature and by stakeholders as being both political and legal in nature.

## 3.2. Literature review

We conducted a systematic scoping review to identify key issues related to deep-sea mining in existing research. This review focused on scientific literature published in English as of June 2024. We employed the Scopus database, which is widely considered to have good coverage of the academic literature across the natural and social sciences (notably, Scopus has a broader scope than Web of Science). We used the search strings "deep-sea mining" or "deep-seabed mining" in combination with search terms relating to PESTEL factors. The search queries for Scopus databases used for the systematic review, and the number of references collected through the search, are provided in Supplementary Appendix (Table A.1). The number of articles per PESTEL category was used to provide quantitative indicators. After gathering search results from the peer-reviewed literature, studies were screened (title and abstract) for inclusion in the qualitative content analysis (full text) as per the PRISMA guidelines (Page et al., 2021). This purposive sampling of the literature for the qualitative content analysis included articles that examined DSM-related issues relevant to at least one PESTEL dimension, specifically those that discussed DSM drivers or barriers, as well as studies that have been most influential in the field. Another inclusion criterion was the relevance of the study to at least one of the following minerals: polymetallic nodules, seafloor massive sulfides, or cobalt-rich crusts. Conversely, studies relevant to none of these minerals were
<figure><img src="image_3.png" /><figcaption>Fig. 1. Workflow diagram of the PESTEL analysis.</figcaption></figure>

excluded. Once relevant articles were identified, the qualitative analysis of full texts was performed using manual coding of full texts to identify and organize important factors related to each PESTEL category including research gaps, recurring issues, conflicting findings, and emerging trends. Additionally, this analysis also allowed the identification of a few key references from the 'grey' literature that have been particularly influential in the academic literature.

### 3.3. Participatory workshop

An online participatory workshop was organized in May 2022 with the aim of identifying and prioritizing DSM-related issues. Break-out groups were constituted based on the type of organization or the sector of activity of the participants (Table 1): Authorities and policy makers composed of persons from intergovernmental and governmental agencies; Conservation experts included essentially individuals from environmental NGOs; Industry experts were from different sectors of activity (equipment manufacturing, industry organization, exploration, services provider, environmental monitoring and management, academic engineering sciences); a group of research scientists from the fields of molecular biology, marine biology, marine microbiology, marine biogeochemistry, deep-sea biology and ecology, international law, economics and political sciences. While efforts were made to engage non-academic actors through targeted invitations, their participation remained lower than desired for authorities and policymakers and, to a lesser extent, for NGOs. The reasons for this included logistical constraints due to different time zones, competing professional obligations, and, in some cases, concerns about the sensitive nature of the discussions

<table><caption>**Table 1**
Number of stakeholders invited and number of participants to the stakeholder workshop.</caption><thead><tr><td></td><td>Invited</td><td>Participants</td><td>Group ID</td></tr></thead><tbody><tr><td>Authorities & policy makers</td><td>49</td><td>4</td><td>PW policy group</td></tr><tr><td>NGOs, conservation experts</td><td>52</td><td>8</td><td>PW NGO group</td></tr><tr><td>Industry experts</td><td>44</td><td>12</td><td>PW industry group</td></tr><tr><td>Research scientists</td><td>36</td><td>29</td><td>PW science group</td></tr></tbody></table>

on DSM governance.

Participants were asked to answer two questions relating to the triggers and to the preventing factors regarding deep-sea mining (DSM), understood as large-scale commercial deep-sea mining operations. The questions were: (1) What may trigger the start of deep-sea mining? (2) What would make it impossible to start deep-sea mining? Participants were asked to organize factors into PESTEL categories. A copy of all the written material produced during the break-out group discussions is available in Massé et al. (2022) and synthesis tables are provided in Supplementary Appendix.

During the workshop, breakout sessions were organized for each stakeholder category, followed by a collective discussion. Participants used post-it notes to identify factors within each PESTEL category. The number of factors identified per PESTEL category and participant type was used to generate quantitative indicators. Additionally, discussions within each group and during the collective session were documented to provide qualitative insights into each issue. Finally, the workshop also included a stakeholder mapping exercise aimed at identifying and characterizing key actors in terms of their levels of interest in and influence over DSM issues (see Massé et al., 2022).

### 3.4. Stakeholder interviews

In addition to the participatory workshop, we conducted a series of semi-structured interviews with stakeholders between March-May 2023 (Table 2). The scope of interviews included consolidating a baseline of issues surrounding DSM activities as well as envisioning the future of DSM (see Supplementary Appendix Table A.6 for the guiding questions used in the interviews). We used a purposive sampling strategy where relevant participants were identified with the help of project partners and their networks as well as through the stakeholder mapping exercise conducted during the workshop in order to represent diverse and balanced perspectives on DSM issues. Participant selection criteria included direct involvement in DSM governance (e.g. policymaking, regulatory roles), affiliation with an organization engaged in DSM-related activities (such as industry and NGOs), and expertise on DSM-related issues through their professional position. Notably, two interviewees had previously attended the participatory workshop
<table><caption>**Table 2**
List of interviews.</caption><thead><tr><th>Interview ID</th><th>Stakeholder category</th><th>Region</th><th>Language</th><th>Attended workshop</th></tr></thead><tbody><tr><td>Interview Pol-1</td><td>Policy-maker</td><td>Global</td><td>English</td><td>No</td></tr><tr><td>Interview Pol-2</td><td>Policy-maker</td><td>Europe</td><td>French</td><td>No</td></tr><tr><td>Interview Ind-3</td><td>Industry</td><td>Europe</td><td>English</td><td>No</td></tr><tr><td>Interview Ind-4</td><td>Industry</td><td>Europe</td><td>French</td><td>No</td></tr><tr><td>Interview Ind-5</td><td>Industry</td><td>Europe</td><td>French</td><td>No</td></tr><tr><td>Interview Ind-6</td><td>Industry</td><td>Europe</td><td>French</td><td>No</td></tr><tr><td>Interview NGO-7</td><td>NGO</td><td>Global</td><td>English</td><td>Yes</td></tr><tr><td>Interview NGO-8</td><td>NGO</td><td>Europe</td><td>French</td><td>Yes</td></tr><tr><td>Interview NGO-9</td><td>NGO</td><td>Europe</td><td>French</td><td>No</td></tr><tr><td>Interview NGO-10</td><td>NGO</td><td>Europe</td><td>French</td><td>No</td></tr><tr><td>Interview NGO-11</td><td>NGO</td><td>Europe</td><td>English</td><td>No</td></tr></tbody></table>

described in Section 3.3. Despite our targeted efforts towards increasing our sample of policy-makers, they remained underrepresented compared to industry and NGOs (Table 2). We also acknowledge the dominance of European perspectives in the sample, noting further that five out seven interviews conducted in French language were with participants working in a French-based organization or a French branch of international organization. Interviews were conducted online and typically lasted between 60 and 90 min.

Each interview was recorded and transcribed using Noota software, followed by a quality check to correct errors. The transcribed interviews were then coded to link each argument/factor to a specific PESTEL category, providing qualitative information for a deeper understanding of each factor. These factors were subsequently grouped into sub-categories within the PESTEL framework (see Table A.5 in Supplementary Appendix). The coding proceeded iteratively between co-authors with an initial independent coding of transcripts, a collaborative discussion to refine the coding framework and align interpretations, and a cycle of reviewing and revising codes collectively to strengthen the robustness of the analysis. The frequency of factors within these sub-categories was used to generate quantitative indicators with the aim of characterizing our material in terms of themes discussed during the interviews. The qualitative content analysis focused on the identification of similarities, differences, and recurring themes across different interviews through an inductive approach (Thomas, 2006), whereby key points and patterns emerged from the discussions between the co-authors involved in the coding process.

We integrate the results from the three approaches (literature review, workshop, and interviews) to present the outcomes of our PESTEL analysis, comparing the ways in which issues are considered according to the source of information.

# 4. Results

## 4.1. Overall distribution of PESTEL factors

We observe differences in the distribution of PESTEL factors depending on the type of knowledge source mobilized (Fig. 2). The academic literature collected through our systematic scoping review (Table A.1 in Supplementary Appendix) is dominated by studies on environmental issues (42 %), followed by economic (15 %) and legal (15 %) categories. In the participatory workshop, environmental (23 %) and social (19 %) issues came first, whereas economic factors (12 %) were less mentioned by workshop participants. In the stakeholder interviews, the hierarchy of factors follows a different pattern: legal (25 %), economic (18 %), and political (17 %) factors represent the prevalent categories in the coded transcripts. It is important to note that these

distributions, which highlight the thematic emphases of our material, are influenced by our methodological choices and the limitations of stakeholder participant representativeness outlined in Section 3. Nevertheless, this overview underscores the value of direct stakeholder consultation in rebalancing the importance given to environmental aspects in the scientific literature.

The distribution of PESTEL response factors according to the category of stakeholders is shown in Fig. 3 (see also Supplementary Appendix Tables A.3 and A.4 for additional details on the factors identified by the different groups during the workshop, and Table A.5 for the factors identified through the interviews). The PESTEL distribution of response patterns of industry stakeholders were similar for the participatory workshop and the interviews, with a dominance of economic and technological factors. In contrast, the response patterns of the policy-makers were dissimilar: during the participatory workshop, they primarily focused on political and environmental factors, whereas during the interviews they focused on legal and economic factors. These differences can be explained by the fact that the representatives of the group of authorities and policy-makers who attended the workshop were not the same as those who took part in the interviews, the former working in environmental or resource agencies with a regulatory role, while the latter were from institutions responsible for policy development. For NGO stakeholders, the pattern of the participatory workshop responses was dominated by political and social factors, whereas legal factors were prevalent during the interviews, reflecting the fact that the proportion of NGO participants with a background in law or policy was higher than in the interviews than in the workshop. These differences may also be due to the differing interaction contexts, with stakeholders having more interest in voicing their views on power relations in an interactive context such as a workshop, whereas interviews may be more favorable to discussing the technicalities of legal issues. Finally, the pattern of responses of academic researchers at the participatory workshop was slightly dominated by social factors, followed by political and legal factors.

The distribution of the PESTEL factors across main themes in the stakeholder interviews is presented in Fig. 4. The prevalent themes included the legitimacy of regulation (11.7 %), technological feasibility (8.0 %), economic issues related to metal markets (7.1 %), the influence of the broader political or geopolitical context (6.6 %), social pressures and growing public awareness (6.6 %), and environmental impacts (5.7 %).

## 4.2. Political aspects

### a. Main political factors identified through the literature review

Our survey of the literature showed that political factors influencing the dynamics of the deep-sea mining sector includes several challenges within the ISA.<fnref n="11" /> The ISA's decision-making opacity raises transparency concerns (Ardron et al., 2018; Heffernan, 2019; Willaert, 2022; Blanchard et al., 2023; Jaeckel et al., 2023). Infrequent meetings and a lack of external expertise garner criticism (Zalik, 2018). Conflicts of interest within the ISA and its Legal and Technical Commission (LTC) further complicate matters, potentially compromising the development of fair regulations (Levin et al., 2020). The ISA's dual mandate –DSM promotion and environmental protection– is also questioned for its conflicting nature (Cuyvers et al., 2018; Kirkham et al., 2020).

The organization and voting procedures of the ISA are questioned for limiting the influence of Global South nations (Lallier and Maes, 2016; Kim, 2017; Zalik, 2018). Imbalance in representation amplifies concerns about fairness and equity in decision-making processes. Meanwhile, private sector lobbying at the ISA introduces profit-driven motives,

<footnote n="11">¹¹ See also Supplementary Appendix Table A.2 for a synthesis of PESTEL factors identified through the literature review.</footnote>
<figure><img src="image_4.png" /><figcaption>**Fig. 2.** Distribution of factors across PESTEL categories identified through (a) the literature review (in % of articles), (b) the participatory workshop (in % of post-it notes), (c) the stakeholder interviews (in % of factors identified in coded transcripts).</figcaption></figure>

<figure><img src="image_5.png" /><figcaption>**Fig. 3.** Distribution of PESTEL factors by stakeholder category in (a) the participatory workshop (in % of post-it notes); (b) the stakeholder interviews (in % of factors identified in coded transcripts).</figcaption></figure>

potentially overshadowing environmental considerations in regulatory frameworks (World Economic Forum, 2022; Deberdt and James, 2024).

On the global stage, a number of states wish to turn to deep-sea mining to secure critical metal supplies amidst rising global demand (World Economic Forum, 2022; Yu, 2024). Deep-sea mining is viewed as a way of reducing dependence on land-based sources in politically unstable regions (Merrie et al., 2014). The inclusion of deep-sea mining in political discourse related to the transition to renewable energy legitiizes its importance (Childs, 2020; Hallgren and Hansson, 2021), while energy transition policies directly impact metal demand (Miller et al., 2021; World Economic Forum, 2022).

Conversely, energy conservation policies may reduce the demand for metals, influencing the urgency of deep-sea mining (Levin et al., 2020). Countries calling for a moratorium on deep-sea mining emphasize environmental concerns, reflecting a growing acknowledgment of potential risks and the need for precaution (Brooks, 2022; European Parliament, 2021, 2022).

## b. Additional political factors identified through the participatory workshop and stakeholder interviews

Stakeholders generally identified access to minerals, intertwined with considerations of geostrategic and economic interests, as a pivotal political driver (PW industry, NGO, and science groups). They also

considered that the adoption of regulations might trigger deep-sea mining (PW policy and industry groups). Strategic issues related to military/defense were also seen to potentially influence decisions about deep-sea mining (Interview Ind-3: “Geo-military issues are clearly shifting towards the deep oceans, both for controlling what happens there or going to war there, but also for access to critical metals used in defense technologies”). The militarization of the deep-sea raises questions about the intersection of national security interests and resource exploitation (Interview NGO-8: “We are seeing countries say they are mapping the seabed for scientific research or resource exploration, but it’s in fact about the detection of submarines”). Lobbying efforts by land-based mining actors were also identified as important drivers of policy decisions and regulatory frameworks (PW policy and science groups).

Participants considered that NGOs and citizen powers may play a substantial role in shaping political decisions (PW science group, Interviews Ind-4 and NGO-8), but in some countries States' attitudes towards activists can discourage their combativeness (Interview NGO-5: “Opportunities for the civil society to speak out against the destruction of the environment in autocracies like China or even totalitarian countries are limited. They have pushed out a lot of discourses”). The consideration of a moratorium was seen as a political decision (PW industry, NGO, and science groups), sometimes viewed as a genuine response to environmental concerns and sometimes as a political stunt (Interviews Pol-1, Ind-3: “In France, they’ve gone from we’re going to extract to we’re going
<figure><img src="image_6.png" /><figcaption>Fig. 4. Distribution of PESTEL factors and sub-factors identified through stakeholder interviews.</figcaption></figure>

to have a moratorium, and that's in less than 18 months. And it seems to be a political decision", and NGO-11: "We now have over 20 countries that are saying that we need a moratorium. Some because they want to mine in the long term but don't think there are ready, others because they have a real environmental conviction that sustainability is not possible"). Some stakeholders also questioned the broader political relevance and feasibility of an unconditional ban (Interviews Ind-6: "To say that we'll never exploit [deep-sea minerals] seems exaggerated to me, it's a political decision that makes no sense to me", NGO-8: "Governments that support a moratorium tend to say that they cannot democratically decide never to mine these minerals").

Stakeholders noted the connections between industry and research, and between industry and regulators, that influence political decisions (Interviews Pol-1: "Many representatives at the ISA also have links to industry", and NGO-10: "We see a lot of industry-funded research that align with the interests of the industry"). They also stressed the political influence of big corporations on Small Island Developing States (Interview Pol-1: "In the Pacific it generally appears to be big corporations versus very small island States, the big corporations paying almost nothing but moving their address to the small State") and the major influence of the USA (Interviews Pol-1: "I'd say the USA, so Lockheed Martin really, will have a major influence [on the future of deep-sea mining]", and NGO-11: "The ISA has its headquarters in Kingston because the USA wanted it to be in a country over which it has influence").

### 4.3. Economic aspects

#### a. Main economic factors identified through the literature review

The potential economic benefits derived from large quantities of metal-rich deep-sea deposits serve as a primary driver for the development of DSM activities (Petersen et al., 2020; World Economic Forum, 2022). These deposits hold the promise of contributing to global economic growth and meeting the rising demand for metals (Hallgren and Hansson, 2021; Sakellariadou et al., 2022). Some authors argue that DSM would assist in transitioning to green technologies (Sharma, 2022) and represents a development opportunity for low- and middle-income countries (Löf et al., 2022). However, uncertainties surrounding the

profitability of deep-sea mining pose significant challenges (Koschinsky et al., 2018; Hallgren and Hansson, 2021; Bisson et al., 2023). The costs associated with technology development are high (Cuyvers et al., 2018; Leal Filho et al., 2021) and production costs uncertain (Hallgren and Hansson, 2021). Additional costs include costs for exploration and for environmental impact assessments (Koschinsky et al., 2018) as well as potential costs associated with ecological compensation and payments under the common heritage of mankind regime (Ekau and Hornidge, 2022). These uncertainties may deter investments in the DSM sector that are needed to start commercial activities (Koschinsky et al., 2018; Zalik, 2018; Leal Filho et al., 2021). The economic viability of deep-sea mining also hinges on its ability to compete with other sources of metals, while potential impacts on markets and the global economy depend on factors such as production costs, available quantities, and the timing of entry into the market (World Economic Forum, 2022).

#### b. Additional economic factors identified through the participatory workshop and stakeholder interviews

Industry representatives considered that high ore grades in deep-sea deposits present economic opportunities and have the potential to address concerns about metal resource scarcity and secure a stable supply chain (PW industry group, Interview Ind-3: "There is a trend away from relying on global markets to supply critical raw materials. In the medium to long term, this trend supports seabed mining. Because it's an alternative source that countries that aren't necessarily rich in natural resources can secure"). However, market conditions, including changes in metal prices, global commodity markets, and consumer preferences, play a significant role in shaping profitability and investment decisions (Interviews Ind-5: "I don't think it's profitable in the current conditions. Because Nautilus Minerals [the company that attempted to explore and mine seabed mineral deposits in Papua New Guinea] has ruined its investors, but it hasn't extracted much. Will it be profitable in the future? I think yes, because metals prices are going to rise. If metals double or triple in price, the question of profitability will change dramatically"). The arrival of large quantities of deep-sea minerals on the market could hamper metal-saving innovation (e.g. lightweighting technologies) and decrease metal prices (Interviews NGO-8: "We're seeing technological innovation that emerges on a monthly
basis, around decreasing metal use in existing products for example. If you then flood the market with a load of minerals from the deep sea, that will probably put a bit of a damper on all of these interesting innovations that are emerging today" and NGO-11: "[DSM] will just increase the amount of metals onto the market, possibly lowering the price"). Deep-sea mining may compete with terrestrial mining for investment and market share (PW industry group). Furthermore, deep-sea mining companies may face market challenges if consumers and stakeholders boycott products using metal sourced from deep-sea mining activities due to environmental concerns (Interview NGO-9: "If their potential buyers refuse to buy these metals that come from the seabed, then their model is somewhat called into question"), as illustrated by the fact that several large corporations such as Google, Samsung, Philips, Volkswagen Group, Volvo Group, BMW Group, and Patagonia have supported a call for a moratorium on deep-sea mining.<fnref n="12" /> While the projected rising demand for metals found in DSM minerals is primarily driven by the need to build electric vehicle batteries to realize the electric mobility transition, technological advancements in battery chemistry are already paving the way for cobalt- and nickel-free alternatives that could shift the demand (Interview NGO-8: "Tesla has a battery that contains no nickel and no cobalt, two of the key minerals but that we're looking for in the deep sea, so it looks like innovation within the market is shifting us away from those deep sea minerals in any case").

Industry representatives also considered that contracts that could be awarded in EEZs or state funding for exploration and for technological development are important drivers for the development of the deep-sea mining sector (Interviews Ind-4: "Exploration and technological requirements require significant investments. [...] Some projects in the CCZ have received funding from their respective governments" and Ind-6: "If states approve DSM in their EEZ, then I think it's just a matter of time, money and technology"). NGO representatives also highlighted economic factors such as the impact of recycling, the circular economy, and the efficiency of metal treatment processes (Interview NGO-7: "With increased recycling and a circular economy, global mining needs could start to decrease. [...] At the moment they don't have the metallurgical processes that would allow extracting enough metals to make it commercially viable") as well as trade-offs with other activities that would be impacted by deep-sea mining such as marine genetic resources, fisheries, and submarine cables (Interview NGO-10).

## 4.4. Social aspects

### a. Main social factors identified through the literature review

UNCLOS established the mineral resources in the Area to be 'the common heritage of (hu)mankind' (CHM) and charged the ISA to ensure the equitable sharing of financial and other economic benefits among the nations of the world, with particular attention to developing countries, landlocked countries, and island states dependent on the ocean and its resources (Lodge, 2017; Miller et al., 2021; Jaeckel et al., 2023). As of 2024, the benefit-sharing system related to the CHM principle is still being negotiated at the ISA, with stakeholders holding differing views on the fairness of payment regime proposals (Cuyvers et al., 2018; Levin et al., 2020; Wilde et al., 2023). Notably, 47 African member states have expressed their concerns over low royalty rates in initial proposals, which they consider would not constitute a substantial compensation to humankind for the transfer of common resources to private ownership (Levin et al., 2020). We also found that DSM revenues are often argued to likely benefit a small number of companies from the high-income countries, to the detriment of countries that do not have the means to engage in DSM (Zalik, 2018; Miller et al., 2021; Ekau and Hornidge, 2022; Hyman et al., 2022). Although low-income states may still sponsor

a contractor, the revenue received by that state may be low, in particular if the contracting company is a subsidiary of a parent company that is not based in the sponsoring country (Casson, 2020; Willaert and Singh, 2021; Willaert, 2022; Holst, 2024).

It is widely acknowledged that social acceptance (also called social license to operate in the literature) is essential for the viability of deep-sea mining (Moffat and Zhang, 2014; Jaeckel et al., 2017, 2023; Hallgren and Hansson, 2021). As an alternative to land-based mining, DSM is presented by proponents as having the potential to reduce the human impact of the mining industry (Lodge, 2017). Nevertheless, DSM activities will likely interfere with other maritime uses such as telecommunications (Kung et al., 2021) and fishing (Thurber et al., 2014; Van Der Grient and Drazen, 2021; ISA, 2023). Furthermore, the benefits humans derive from deep-sea marine ecosystems extend beyond economic activities, encompassing cultural, spiritual, and educational values (among other ecosystem services such as carbon sequestration and storage), which influence public perception of activities that may impact this environment (Katona et al., 2022; Morais et al., 2022).

### b. Additional social factors identified through the participatory workshop and stakeholder interviews

Some stakeholders noted that the perceived social benefits generated by deep-sea mining, such as providing essential metals for low-carbon infrastructures, economic development, and revenue generation, might outweigh the potential environmental impacts on deep-sea ecosystems (PW science group and Interview Ind-6: "There will always be people against [DSM], but there will also be people for, in response to this energy transition, because the most important thing at the end of the day is that we can reduce our CO2 emissions. [...] I think that if we put everything into perspective, considering the green transition and economic development, this is an opportunity more than a threat"). They further noted that increasing environmental and social impacts of terrestrial mining operations may favor the social acceptance of deep-sea mining (Interviews Ind-3: "Perhaps ironically, I think the growing awareness of the importance of ESG [environmental, social and governance] will eventually play in favor of deep sea mining because I think there's greater transparency into supply chains [compared to terrestrial mining]").

However, NGO representatives argued that both forms of mining can coexist and that DSM will likely be additional to, and not a substitute of, terrestrial mining (Interview NGO-8: "I've never found a piece of evidence that suggests that land-based mining will stop if deep-sea mining begins. So deep-sea mining, as far as I can see, will not be instead of land-based mining, it will be in addition to land-based mining"). They stressed the need to transition to alternative industrial models and shift consumption patterns to decrease the need for resource extraction (PW NGO group). They also emphasized that societal attitudes towards deep-sea mining may be influenced by a change in the public's normative and cultural values, increasingly considering the importance of minimizing environmental impacts and preserving natural resources (e.g., frugality and degrowth movements). Some further advocated for the consideration of non-human life forms and the broader ecological integrity of the deep sea within the conceptualization of the CHM principle, as opposed to an anthropocentric viewpoint (PW NGO group).

Overall, stakeholders considered that the strong opposition of environmental activists and citizens exerting pressure on governments and industry can result in a moratorium or stricter regulations on deep-sea mining activities (PW policy and industry groups, Interviews NGO-7, NGO-8, NGO-10: "I think that civil society and international NGOs are currently playing an important role, in particular because we are able to mobilize people and provide technical and legal expertise [to support the moratorium]", and NGO-11). NGO campaigns and media coverage were perceived to play a significant role in shaping public opinion and raising awareness about deep-sea mining implications (Interviews Ind-3: "In European nations, perhaps not so much in North American, seabed mining is under pressure from environmental activists in particular. But I struggle to

<footnote n="12">¹² https://wwf.panda.org/wwf_news/?4541466/Business-Backlash-Against-Deep-Sea-Mining-Grows.</footnote>
imagine that same pressure in North America, Japan, Korea, India, and China", NGO-7: "With the current momentum, we [NGOs] can imagine succeeding in getting a moratorium adopted, we think it's 'winnable' as we say in campaign jargon", and NGO-10). In addition, ensuring informed consent of Indigenous people and considering cultural perspectives are increasingly considered essential to foster social acceptance (PW science group, Interviews Pol-1, Ind-5: "We [our company] are well aware that just because we're working in the middle of the Pacific doesn't mean that there won't be impacts or that there won't be concerns about neighboring populations. So we're being really transparent about what we're going to do", NGO-7, and NGO-8: "There should be a delegation of Indigenous peoples at the ISA if the institution was properly established"). Misuse of scientific knowledge and of data on deep-sea ecosystems and mining impacts was seen to potentially influence public perception and decision-making processes (PW science group). Industry representatives underscored that the acceptability of deep-sea mining may be linked to the number and size of mines (Interview Ind-6: "I think if there are a limited number of mines in all the oceans, that may be acceptable. If they multiply like oil drilling in the United States in hydraulic fracturing zones, it would no longer be acceptable").

## 4.5. Technological aspects

### a. Technological factors identified through the literature review

The deep ocean presents extreme conditions, with pressures that are hundreds of times greater than atmospheric pressure, total darkness, temperatures varying from near freezing to more than 400 °C near active hydrothermal vents, and variable topographies ranging from abyssal plains to seamounts (Rademaekers et al., 2015). Added to the distance separating the deposits from the surface, DSM faces real technological challenges in identifying and accessing the targeted minerals. Petersen et al. (2017) and Rademaekers et al. (2015) mention the difficulty of identifying variations in polymetallic nodule density with sufficient precision. Nodule exploitation requires very powerful systems for pumping nodules several thousand meters up to the production support vessel at the surface (Cuyvers et al., 2018; Cheng et al., 2023). The extraction of seafloor massive sulfides may face even more challenges than that of nodules, due to the need to excavate and crush the minerals before they can be lifted to the surface, and to the complex topographies around hydrothermal fields that can hamper ROVs' ability to operate (Cuyvers et al., 2018). In addition, the smoke plumes produced by active hydrothermal vents are used as an indicator to locate these potential deposits, but they are generally young and small hydrothermal sources of little economic interest (Petersen et al., 2017, 2020). Amon et al. (2022) state that inactive sources are more likely to be targeted for exploitation, as they are more abundant and larger than active ones, and that active sources represent a greater challenge given the acidic fluids and the extreme temperatures around them. The ore grades of massive sulfides are also very difficult to assess (Petersen et al., 2017), and vary greatly from one hydrothermal vent field to another, and even from one vent to another in the same area (Amon et al., 2022). Currently, the only way to estimate the composition of massive sulfides is to drill into them, a costly operation that is rarely carried out (Petersen et al., 2017, 2020).

The development and availability of technologies that minimize environmental disturbance during mining operations is another challenge that may have to be overcome in order to obtain social and regulatory approval (Cheng et al., 2023). While some robotic collection technologies are proposed to minimize the generation of sediment plumes (Liu et al., 2024), the loss of biodiversity and ecosystem functions associated with the extracted minerals is inevitable and the technological feasibility of effective restoration is currently unproven (Niner et al., 2018; DOSI, 2024). Cheng et al. (2023) also stress that the availability of efficient deployment and recovery technology for deep-sea mining vehicles will be essential for the viability of mining operations. In addition, the development of in-situ monitoring

technology will be essential for ensuring efficient, reliable, and safe operations (Guo et al., 2023). Despite all the challenges, knowledge and technology transfer from the oil and gas industry and land-based mining sectors are seen to potentially accelerate technological advancements in deep-sea mining (Rademaekers et al., 2015; Paillard, 2017).

### b. Additional technological factors identified through the participatory workshop and stakeholder interviews

Stakeholders underscored that technological development to overcome exploration and exploitation challenges may benefit from synergies with scientific and military interests. This includes the development of remotely operated underwater vehicles (ROVs), autonomous underwater vehicles (AUVs), semi-automation, new sensors, and advanced data services, which may have industrial, scientific, and military application (Interviews Ind-5: "There is considerable technological development currently taking place in drones and robotic solutions for exploring and monitoring the seabed" and NGO-8: "Military-industrial complexes are now interested in these technologies with dual uses"). Regarding mineral extraction, industry representatives acknowledged that technical optimization is needed to increase efficiency of operations and minimize environmental impacts (Interviews Ind-4: "There are still technical issues that need to be resolved. [...] How do the logistics work for a production system over these enormous distances? To what extent can we use technology to avoid harm or mitigate harm in the deep-sea environment? [...] We're going to continue to try and optimize the technology on our end" and Ind-5: "I think we need technological developments on environmental aspects, including noise, turbidity, light and electromagnetism").

NGO representatives contended that pressures for a rapid transition to green technologies and a lack of discussion on alternatives may accelerate deep-sea mining initiatives without adequate consideration of their technological maturity or environmental consequences (PW NGO group). They noted that key operational aspects of DSM remain unverified at commercial scale and argued that there is a lack of transparency regarding DSM technological maturity (Interviews NGO-9 and NGO-11). Industry stakeholders considered that all the technology is available and that DSM trials are needed to pursue the development of technologies aimed at limiting environmental impacts (Interviews Ind-4: "We already have all the technological elements to do it [DSM]. And to know if you can do something, you have to test it" and Ind-5: "I think that a pilot should be carried out, not for any commercial purpose but rather for scientific understanding, but a pilot that would enable progress to be made on the possibility of doing things cleanly. A very low-scale experiment, very closely monitored, to really quantify these impacts and test solutions"). They also perceived that the mobility of deep-sea mines, enhancing logistical capabilities and operational flexibility, would be an advantage over terrestrial mining (Interview Ind-6). Stakeholders also considered that enhanced recycling methods, metal-saving technologies, and substitution strategies (e.g. LiFePO₄ battery technology that does not require Cobalt or Nickel) could influence the need for DSM (PW NGO and science groups). They further highlighted technical challenges pertaining to the mineral structure of nodules, whose granulometry (nanometer-scale oxydes) is finer than that of terrestrial minerals, and uncertainties concerning the feasibility of a clean and efficient industrial process for the separation of minerals within nodules and metal treatment (Interviews Ind-6: "The metallurgical process is a very important issue because the nature of the geological formation of these deep-sea minerals implies different metallurgical treatments to those that have been developed for terrestrial minerals. I hope we will have a solution with a reasonable energy cost and without too much environmental impacts" and NGO-8).

## 4.6. Environmental aspects

### a. Environmental factors identified through the literature review

Expected environmental impacts of deep-sea mining identified in the
literature include: the removal of mineral substrates and associated loss of life dependent on these substrates (Gollner et al., 2017; Miller et al., 2018; Amon et al., 2022); the creation of potentially toxic plumes due to mining vehicles on the seafloor that can smother benthic organisms and larvae (Miller et al., 2018; Leal Filho et al., 2021; Amon et al., 2022; Frölicher and Jaccard, 2023); the release of sediments discharged from the ships introducing toxic metals into the water column and increasing water temperatures locally (Hauton et al., 2017; Leal Filho et al., 2021; Amon et al., 2022; Frölicher and Jaccard, 2023); introduction of noise, vibration, and light pollution affecting both benthic and pelagic species (Gollner et al., 2017; Miller et al., 2018; Santos et al., 2018; Drazen et al., 2020; Amon et al., 2022; Williams et al., 2022; Frölicher and Jaccard, 2023). Additional impacts may include fluid leaks, greenhouse gas emissions (Leal Filho et al., 2021; Amon et al., 2022), and disturbances to the ocean's carbon cycle (Levin et al., 2020; Miller et al., 2021; Frölicher and Jaccard, 2023). Finally, cumulative impacts – the combined effects of several human activities – are another major concern (Van Dover et al., 2014; Santos et al., 2018; Amon et al., 2022), in particular those that would stem from multiple mining events, fishing activities, and climate change (Washburn et al., 2019).

A significant challenge in assessing the environmental impacts of deep-sea mining is the limited knowledge of deep-sea ecosystems. This lack of understanding makes it difficult to develop and assess the effectiveness of mitigation strategies (Clark et al., 2016; Amon et al., 2022). Despite this, it is widely acknowledged that deep-sea mining will inevitably result in habitat destruction and biodiversity loss (Miller et al., 2018; Kaikkonen et al., 2021; Leal Filho et al., 2021; Amon et al., 2022; Ekau and Hornidge, 2022). The high endemicity of hydrothermal vent ecosystems, for instance, means that species unique to these environments could be wiped out (Gollner et al., 2017; Levin et al., 2020; Amon et al., 2022). In abyssal plains, the removal of nodules, which provide habitats for a rich biodiversity (Rabone et al., 2023), is an impact that will persist for millions of years (Gollner et al., 2017). Given the slow recolonization rates of species in deep-sea environments (Miller et al., 2018; Heffernan, 2019), recovery times for benthic fauna and sediments can span decades (Amon et al., 2022), challenging traditional mitigation strategies (Van Dover et al., 2017; Miller et al., 2018). In particular, ecological restoration in deep-sea environments faces very high uncertainty and is unlikely to contribute meaningfully to achieving a goal of no net loss of biodiversity (Van Dover et al., 2014, 2017; Niner et al., 2018; Levin et al., 2020; Amon et al., 2022).

Only a few studies have attempted to compare the environmental impacts of deep-sea mining to those of terrestrial mining (Alvarenga et al., 2022; Katona et al., 2023; Paulikas et al., 2020, 2022; Metaxas et al., 2024). These studies have remained qualitative regarding impacts on biodiversity. Such comparison is often deemed irrelevant due to the fundamentally different ecosystems and types of impacts involved (Hallgren and Hansson, 2021). Still, pressure is increasing for an informed societal debate on tradeoffs involved in securing additional minerals from either land or deep-sea. While Metaxas et al. (2024) have proposed a framework for comparing environmental impacts of deep-seabed and land-based mining, thresholds are still needed for quantitative indicators aimed at reflecting impact severity (ISA, 2022; Van der Grient and Drazen, 2022; Hitchin et al., 2023). Given the magnitude of uncertainties, the argument for precautionary regulations on deep-sea mining is strong (Boetius and Haeckel, 2018).

## b. Additional environmental factors identified through the participatory workshop and stakeholder interviews

Stakeholders generally shared the view that current knowledge gaps regarding the role, functioning, connectivity, and resilience of these ecosystems make it difficult to assess impacts of DSM and that a better understanding of deep-sea ecosystems is crucial for informed decision-making (PW policy, industry, and science groups). The diversity of impacts associated with different types of deep-sea minerals and locations,

including transboundary impacts between EEZs and international waters, complicates such assessment (Interviews NGO-8: "Of course, some of the environmental impacts can't be contained either within any EEZ, the ocean's dynamic, it's fluid and the impacts could indeed spread far and wide and we don't know to what extent yet. So there's always the risk that there might be transboundary impacts as well" and NGO-10). Some stakeholders considered that current Environmental Impact Assessments are insufficient and suggest that a minimum of 10 years of focused research is needed to close knowledge gaps (Interviews NGO-10 and NGO-11: "The scientific data are clearly not robust enough to authorize exploitation, and the scientific recommendations say that a minimum of 10 years of research is needed to fill the knowledge gaps before the mining code is established"). Some argued that DSM activities could help close these knowledge gaps by funding research and providing more data on deep-sea ecosystems (PW science group). However, others suggested that research funding dependence on industry raises ethical concerns as industry-funded research may lack or may be perceived to lack independence and transparency (Interviews Ind-5: "We [our company] know this [DSM] is a contentious issue. [...] We need to be very transparent"; NGO-10: "The reliance on contractors for environmental baseline studies is extremely problematic").

Some stakeholders considered that DSM can help fulfill the need for minerals for the green transition to reduce GHG emissions (PW industry and science groups). However, uncertainties about the potential negative effects of DSM on carbon sequestration via the perturbation of deep-sea sediments and disturbance of the geochemical cycles involved in the ocean's carbon pump demand caution to ensure that DSM mineral extraction does not have a negative effect on climate change that outweighs expected benefits from its contribution to the green energy transition (Interviews Ind-5: "We will also have to assess the impact [of nodule mining] on carbon stocks, bearing in mind that we will be affecting the first 5 to 8 cm and that carbon stocks are made up of meters of sediment. We're only taking a small amount, but I understand that it raises questions", NGO-7, NGO-9, and NGO-10: "One impact that we consider dangerous is the disruption of the deep ocean's function as a carbon sink, which does a lot to guarantee climate stability"). Proponents of DSM also argued that it could reduce the environmental impacts of terrestrial mining, which is associated with significant habitat destruction and pollution (PW industry group). However, opponents emphasized that DSM is unlikely to replace terrestrial mining (it would instead be additional) and that the pursuit of green technologies should be balanced against the full environmental cost of mining and mineral processing, including irreversible impacts, pollution, and energy consumption (Interviews NGO-7, NGO-10, NGO-11). In addition, DSM lacks the established rehabilitation and restoration techniques that exist for terrestrial mining (Interview NGO-8: "The reality is that there are no solutions for the restoration of [deep-sea] habitats. It's even more complicated than on land").

## 4.7. Legal aspects

### a. Legal factors identified through the literature review

Pickens et al. (2024) identified more than 30 outstanding regulatory issues in the current legal regime of the ISA that is deemed to govern the DSM industry in the Area. The authors conclude that it will likely take a long time to finalize and adopt all the rules, regulations and procedures for DSM. The challenges identified include: elaborating and integrating science-based thresholds into the regulatory framework of DSM exploitation (Hitchin et al., 2023); the appropriateness of Environmental Impact Assessment (EIA) requirements (Vanreusel et al., 2016; Guilhon et al., 2022); procedures for inspection, compliance, and enforcement (Deberdt and James, 2024); the underdeveloped international legal regime regarding liability for damages (Willaert and Singh, 2021); divergence of views on the proposed profit-sharing regime to distribute benefits among nations (Heinrich and Koschinsky, 2022; Wilde et al., 2023; Friedman, 2024b); the lack of an operational structure for The
Enterprise –the ISA’s arm intended to engage in mining activities on behalf of humankind (Thompson et al., 2018; Singh, 2021); the need for reasonable regard for other marine use and stronger governance integration in areas beyond national jurisdictions to ensure comprehensive management of the deep seabed (Christiansen et al., 2022; Friedman, 2024a). Nevertheless, the triggering of the “two-year rule” by Nauru, acting as sponsoring state of a private contractor owned by the Canadian corporation The Metals Company, in order to expedite the adoption of a mining code at the ISA, underscores the pressure to finalize regulatory frameworks (Singh, 2021; Jaeckel et al., 2023; Holst, 2024).

According to Jaeckel et al. (2017), the CHM principle, which underpins the governance of deep-sea resources, requires not only the sharing of benefits but also the conservation of natural resources (including biological resources) for both present and future generations. As such, the authors consider that the operationalization of the CHM principle implies taking measures that could act as a safeguard against premature exploitation of the deep seabed (Jaeckel et al., 2017). The ISA intends to fulfill its environmental protection mandate through area-based management tools such as Areas of Particular Environmental Interest (APEIs), which are areas of the seabed closed to any mining activities but open to scientific research (Lodge, 2017). However, under the current practice of the ISA, APEIs can be subject to modifications or eventually become open to mining, which has been criticized for defeating the protection purpose of APEIs (Amon et al., 2022). In addition, several studies have shown that APEIs lack biological representativeness when compared to mining contract areas, raising concerns about their effectiveness as conservation measures (Jones et al., 2021; Washburn et al., 2021). Furthermore, area-based management tools alone may not be sufficient to avoid species extinction and ensure the ecological connectivity that is essential to the functioning of deep-sea ecosystems (Blanchard and Gollner, 2022).

## b. Additional legal factors identified through the participatory workshop and stakeholder interviews

Stakeholders underscored the adoption of a comprehensive set of regulations as a pivotal factor influencing the start of DSM (all PW groups). Some suggested that deep-sea mining regulations being perceived as less stringent than terrestrial mining regulations could favor investments in DSM (PW industry group). Others contended that the lack of strong regulations and weak governance would be detrimental to the DSM industry, as it would hinder public trust and stakeholders' confidence in DSM potential to be a durable industry (Interviews Ind-3: "I think there is a scenario in which seabed mining occurs either in international or national jurisdiction with relatively weak governance. If that were to occur I think that would be problematic and I think it would realize a lot of people's concerns about seabed mining and then people would back away from it" and Ind-5). Some stakeholders believed that the inclusion of restoration requirements in the mining code would improperly convey the idea that deep-sea restoration is feasible, when current scientific knowledge suggests that it is unlikely to contribute meaningfully to the mitigation of environmental impacts (PW NGO group).

While the ISA must ensure a just and equitable decision-making process, concerns about its neutrality, corruption, and efficiency in environmental protection were shown to persist (Interviews Pol-1: "Another concern is the notion of 'effective control' in UNCLOS, currently through state sponsorship. [...] Many consider that the current ISA practice is inadequate", Ind-5: "One of the major problems with the ISA is that there's always this secret aspect. And for various reasons, that sticks to them. To improve transparency, we need to try to develop a system that is also innovative in this respect, so that we don't go back to the old coal mines with all the corruption and things like that.", NGO-7: "There's a lot of pushback against the non neutrality of the [ISA] Secretariat, which has been a real driving force in promoting the industry, actually.", NGO-8, NGO-9: "There are suspicions of corruption, cronyism between top officials at the ISA and top

executives at mining companies. [...] It's a very opaque institution which, in the way it operates, does not allow effective protection of ecosystems"). The ISA's procedures for decision-making do not guarantee the possibility of a vote at the Assembly (167 States) prior to the start of mining activities, as some procedures only require approval of the Council (36 States) or the LTC (Interviews Pol-1: "The Metals Company is ready to put forward a plan of work. If it goes through the Legal and Technical Commission and is approved by the LTC, then the Council will need a two-third majority to disapprove and that will be hard to make" and NGO-8: "What seems important to us is that this is not a decision taken by the Council, in which there are about thirty countries, whereas the members of the Assembly are 167 countries. It's supposed to be 'for the benefit of humankind', so it's up to everyone to decide"). Critics further argued that transparency concerns were reinforced by controversy over test mining approval by the LTC, without consulting the Council, in September 2022 where the contractor announced the decision before the ISA (Interview NGO-7: "We took issue with the way in which that was undertaken in terms of process at the ISA. Test mines are supposed to be approved by vote of the LTC in a full meeting of the LTC. And instead, as we discovered afterwards, it all happened by email silence procedure. People were given three days to object and nobody responded. Because of course, you know, the document was like 300 pages long. And the other thing that was very odd around that whole process was that The Metals Company was lined up and ready to go before they even got the green light. [...] That costs a lot of money, it's a lot of coordination and time and effort to get everyone ready to go. So either that was a big gamble on the part of The Metals Company, or they knew already that they would get the go ahead").

Debated issues regarding the possibility of a moratorium are twofold. First, the feasibility to install a moratorium or a ban without amending UNCLOS is questioned. Some contended that a moratorium could be accepted legally by the adoption of a general policy by the Assembly at the ISA, whereas a ban would require a reform of the ISA (Interviews NGO-7: "I think there was some concern, sometimes expressed by some countries, but notably also the Secretary General of the ISA, about the possibility that a moratorium would contravene UNCLOS in some way. I think there's been a slew of a legal analysis and opinions emerging in response to that indicated instead that a moratorium wouldn't contravene UNCLOS. And I think that could take the form of a general policy at the ISA, which could be elaborated by the ISA Assembly." and NGO-8: "A ban is not legally possible within the framework of the ISA. To move forward [with regard to preventing exploitation], we need to establish a moratorium, it's the only way"). The second aspect relates to the purpose of the moratorium and pre-identified conditions for lifting it. Some recommended specifying what aims and goals are to be achieved during the time of the moratorium, e. g. in terms of scientific research and closing knowledge gaps, what resources are needed, and what happens if objectives are not met by the end of the moratorium (Interviews Ind-3, NGO-9, and NGO-11).

Finally, interviewees argued that countries can also develop their own regulations on deep-sea mining within their EEZs. It may be easier to award licenses within national jurisdictions than in ABNJ (Interview Ind-5: "At the international level, we have over 150 countries that are members of UNCLOS, so there are a lot of countries with a lot of different interests that have their say. So it's obviously easier to work within a national framework, where it's the country itself that grants the license"), but national laws could also enforce decisions to prohibit deep-sea mining taken at national levels (Interview NGO-9: "In France, we could have something similar to the Hulot Law [imposing an end to exploration and exploitation of hydrocarbon fossil fuels on the French territory]— a law that would formally enshrine over time the position of not mining in the French EEZ"). Some stakeholders also highlighted potential cross-jurisdictional conflicts if mining occurs in a country's extended continental shelf where the seabed is under national jurisdiction and the water above is international (Interviews Ind-3 and NGO-10: "I find it hard to see how we can ratify the BBNJ [Biodiversity Beyond National Jurisdiction] treaty and authorize seabed mining on the extended continental shelf, because it just doesn't make sense. Even though there are two different bodies regulating
different things, in practice, seabed mining would defeat any objective of effectively protecting the ocean").

**5. Discussion and concluding remarks**

This study aimed to explore the drivers and barriers with regards to the emergence of DSM through a PESTEL analysis integrating both academic literature and stakeholder views. Distinct perspectives emerged among stakeholder groups, highlighting both areas of consensus and divergence. Notable points of agreement across all groups included the recognition of access to critical resources, economic profitability, and adoption of regulatory frameworks as key drivers. The consensus among groups also extended to certain barrier factors such as environmental knowledge gaps, challenges in addressing concerns of Indigenous peoples and local communities, as well as public pressure on governments and industry in countries where environmental discourses have not been marginalized.

A key area of contention was that industry actors framed DSM as a solution to metal resource scarcity and a means to secure supply chains, while NGOs argued that this framing ignores the potential of recycling and circular economy as well as the risk that DSM may undermine metal-saving innovation. Furthermore, industry representatives generally expressed confidence in the availability of necessary technologies to conduct DSM, whereas NGOs questioned the maturity of these technologies. Yet another key difference concerned the potential of DSM to reduce environmental and social impacts of land-based mining put forth by industry stakeholders, a view that was challenged by NGO stakeholders who contended that DSM would be additional rather than substitutive. Policy-makers and researchers often occupied a middle ground, acknowledging the knowledge gaps and uncertainties around some of these critical issues.

Taken together, the results of the participatory workshop and interviews indicated that stakeholders generally had a comprehensive understanding of the main issues addressed in the academic literature. Our findings also highlighted some issues of interest to stakeholders that we had not identified through the literature review. These include, for instance, political and technological factors related to the militarization of the deep-sea, which have been identified by both industry and NGO representatives as potential major drivers for DSM. While the role of military funding and interests has been analyzed in the context of deep-sea research (Oreskes, 2003, 2021), the literature remains limited regarding how these issues come into play in the context of DSM. Likewise, some stakeholders considered that substitution technologies for electric-vehicle batteries may drastically reduce the demand for metal found in deep-sea minerals. The role of substitution, which has emerged from the terrestrial mining and energy transition literature (Månberger and Stenqvist, 2018; Sovacool et al., 2020; Riofrancos et al., 2023), is still largely unexplored in the DSM literature. Some of these themes that are less prominent in the DSM literature correspond to issues that have only recently gained attention, and relates to the fact that many factors influencing DSM are dynamic and may be subject to shifts (Vivoda, 2024). A participatory approach is particularly relevant to address such dynamic factors as stakeholders can provide the latest insights on some issues (Lang et al., 2012).

This study complements and extends the literature on DSM drivers and barriers by providing a wide-ranging perspective spanning a breadth of disciplinary and non-academic perspectives. The findings confirm the prominence of economic and geostrategic factors as key drivers highlighted in previous research (Hallgren and Hansson, 2021; Hyman et al., 2022; Vivoda, 2024) as well as well-identified barriers such as legal challenges (Pickens et al., 2024), environmental impacts and knowledge gaps (Miller et al., 2018; Amon et al., 2022). In addition, the findings offer insights and critical reflections from stakeholders on a broad range of factors that goes beyond these established drivers and barriers, in some cases revealing nuanced disagreements among stakeholders and prompting further inquiry.

This study also contributes to the literature that aims to support the development research approaches for EBM in the context of DSM (Gurco and Cooper, 2012; Hyman et al., 2022; Vivoda, 2024). By systematically examining political, economic, social, technological, environmental, and legal factors, the PESTEL analysis aligns with the systems-level perspective needed for understanding the landscape in which EBM must operate (Curtin and Prellezo, 2010; Link et al., 2017; Guilhon et al., 2021) and addresses the fragmentation observed in the current literature on DSM drivers and barriers. Our findings further emphasize that these factors are often interrelated, echoing results from previous studies such as Koschinski et al. (2018), Levin et al. (2020), and Vivoda (2024). For instance, the adoption of clear and comprehensive set of regulations can trigger investment in DSM, which the industry needs to pursue technological developments aimed at improving the efficiency of mining operations and minimize environmental impacts. By considering all these dimensions together, the PESTEL analysis can help to tease out these interdependencies and trade-offs inherent in pursuing DSM (Guilhon et al., 2023). Capturing this complex interplay of interests and perspectives is essential for operationalizing EBM for DSM.

These contributions to the literature must be set in the context of several limitations of this study. First, the use of the PESTEL framework influenced the choice of keywords used to select the literature (Supplementary Material Table A.1), which purposely focused on keywords that could be unequivocally linked to at least one of the six PESTEL dimensions. This, however, has unintentionally limited consideration of some strands of literature in social sciences and humanities, including works in philosophy (Massimi, 2024), anthropology (Fache et al., 2021; Gentilucci, 2022; Helmreich, 2023), human geography (Peters, 2020; Verweijen and Dunlap, 2021), and environmental justice (Ranganathan, 2019, 2024; Villagomez and Johnson, 2024), all of which bring critical perspectives on DSM narratives (Carver et al., 2020; Klimašauskaitė et al., 2024) and remain largely underused in research approaches to support EBM (Tam et al., 2024). Likewise, the methodological choices also inadvertently restricted the inclusion of works that discusses the challenges faced by Indigenous communities in relevant governance arenas (Hau'ofa, 1994; Mulalap et al., 2020) and non-academic texts produced by these communities.<fnref n="13" /> This suggests that the aim of providing a holistic view was not fully realized. To address this weakness, future research could employ a purposive sample of both academic and 'grey' literature to better include the diverse scholarship in social sciences and humanities as well as non-academic texts. Second, our sampling approach for the workshop and the interviews resulted in an imbalance in the number of participants for each stakeholder group. In particular, the low participation of authorities and policy-makers in both the workshop and interviews suggest interpreting the results related to their group with caution. In addition, the predominance of scientists in the workshop participants, as well as prevalence of participants from France in the interviews, signals that their perspectives may be over-represented in the results. These imbalances in stakeholder participation limit the scope and generalizability of the findings and indicate that further research is needed to complement the results. Reflecting on the above limitations, we acknowledge that our methodological choices in the implementation of the PESTEL approach determined the literature taken into account and the stakeholders we managed to consult through a workshop or interviews, leading to an overrepresentation of academic perspectives from specific disciplines.

In conclusion, this study aimed to provide a systems-level understanding of the drivers and barriers shaping the emergence of DSM, by combining the results of a literature overview with a range of stakeholder perspectives through a PESTEL framework. The findings extend existing scholarship by addressing the fragmentation of the existing

<footnote n="13">¹³ see e.g. https://www.protectpri.com/navigating-together-toward-a-thriving-pacific/.</footnote>
literature related to DSM drivers and barriers, and by identifying both convergences and points of contention across stakeholder groups and the literature. The analysis reflects the complex interplay of interests and viewpoints that characterizes the debate surrounding DSM, providing a nuanced foundation for future research aimed at operationalizing EBM in the context of DSM.

### CRediT authorship contribution statement

**Manuel Bellanger:** Writing – review & editing, Writing – original draft, Methodology, Formal analysis, Conceptualization. **Pierre Scемama:** Writing – review & editing, Methodology, Formal analysis, Conceptualization. **Denis Bailly:** Writing – review & editing, Methodology, Formal analysis, Conceptualization. **Shani Friedman:** Writing – review & editing, Methodology, Formal analysis. **Ugo Massé:** Writing – review & editing, Methodology, Formal analysis, Conceptualization. **Olivier Thébaud:** Writing – review & editing, Methodology, Formal analysis, Conceptualization.

### Declaration of competing interest

The authors declare that they have no known competing financial interests or personal relationships that could have appeared to influence the work reported in this paper.

### Acknowledgements

The authors are grateful to all the stakeholders who participated in this study. In addition, we would like to thank Charline Guillou, Bleuenn Guilloux, and Louise Ras who helped organizing the participatory workshop and conducting the stakeholder interviews. This research is part of the DEEP REST project that was funded through the 2020–2021 Biodiversa and Water JPI joint call for research projects, under the BiodivRestore (GA N°101003777), with the EU and the following funding organizations: Agence Nationale de la Recherche (ANR-21-BIRE-0003), France, Belgium, through VDI/VDE-IT, Germany, Ireland, Fundação para a Ciência e a Tecnologia, Portugal, Fundo Regional para a Ciência e Tecnologia (FRCT), Portugal-Azores and State Research Agency (AEI), Spain.

## Appendix A. Supplementary data

Supplementary data to this article can be found online at https://doi.org/10.1016/j.resourpol.2025.105623.

### Data availability

Data will be made available on request.

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