DSCC Intervention – 7/11/23

Date: 7 November 2023

Thank you Mr Co-Facilitator

This intervention is on behalf of Greenpeace, WWF, the Ocean Foundation, Oceans North, Environmental Justice Foundation, Sustainable Ocean Alliance as well as the DSCC. 

Firstly we support Pew’s intervention earlier about stakeholder participation. Secondly, we support Ghana’s intervention and we strongly urge the need for a formal review procedure. We believe there is value in a formal regular review procedure undertaken regularly, as well as a structured review more frequently if needed. Environmental effects cannot wait 5 years, particularly if an environmental issue arises, there is a need to keep regulations under review. When the need arises to review the regulations, that should not be delayed such as for a five year period review. We would also note that completely removing the regulation would also require the Council to reach a decision via consensus every time to review the regulations. 

Lastly on paragraph 5, we are concerned about paragraph 5 that pertains to conditions for the amendment of regulations. Issues relating to the detriment to the environment must prevail over any detriment to contractors. It is critical that any amendment would be applicable to any and all contracts.

Thank you Mr Co-Facilitator.

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