December 31, 2019. Professor Payne published this new article in 46 Ecology Law Quarterly 191/37 Berkeley Journal of International Law 345 (2019). In it she contends that the design of a new treaty for conservation and sustainable use of biodiversity in the ocean space that lies more than two hundred nautical miles offshore (BBNJ), requires a multilateral solution, as the high seas border over 150 States, and even land-locked States have interests in its resources and planetary functions such as climate regulation. Varied problems of habitat and species damage from fishing, noise, and other pollution, physical damage from commercial shipping, and harmful impacts from land-based activities such as plastic and other pollution from solid waste disposal require a variety of approaches. The BBNJ agreement will need to be regulatory, to manage human activities in the high seas. It should define and allocate property rights for marine genetic resources. It should create policy tools to ensure management for long-term viability of marine populations. Some of the issues addressed here will also be faced by attempts to govern other areas beyond sovereign State control, including outer space and cyberspace.