In  [69]. They are large precautionary areas, each 400 km 2 with an inner core zone and surrounding buffer intended to protect the core, and minimum viable population sizes, from any sediment plume caused by mining. The nine APEIs allow for biogeographic representation based on three north-south and three east-west strata, reflecting strong productivity-driven gradients, in the absence of detailed **data** on the composition and distribution of benthic communities [78]. The APEIs also recognize high diversity of fragile fauna that will be very slow to recover from any mining impacts [3]. [39] highlight the fact that 'whilst contractors gather environmental and technical information on an annual basis, and report to ISA for the purposes of constructing a common baseline within their license areas, an 'Achilles heel' of the CCZ-EMP is that there is no requirement or incentive for contractors to carry out similar surveys in APEI's. Further to an interim preliminary evaluation report [68], in 2016 the ISA Legal and Technical Commission (LTC) also undertook an initial review of the current status of management implementation of the CCZ-EMP (ISBA/ 22/LTC/12). Other than workshops convened to consider specific taxa, implementation measures (such as **data** standardization and taxonomic inter-calibration and contractor plans and measures to ensure habitat and faunal recovery) have not been undertaken. LTC recommended the creation of two additional APEIs, workshops on APEI effectiveness and Impact Reference Zones 25 /Preservation Reference Zones 26 and the 25 Impact Reference Zones are "Areas which are representative of the environmental characteristics of a particular region to be used for assessing the effect of activities in that region on the marine environment." (ISA, < https://www.isa.org.jm/impact-referencezone >). 26 Preservation Reference Zones are "Areas representative of the mine site in which no mining shall occur to ensure representative and stable biota of the seabed in order to assess any changes in the flora and fauna of the marine environment caused by mining activities." (ISA, < https://www.isa.org.jm/preservation-reference-zone >).