In recent complex petroleum arbitration before ICSID, the "old-style" 2 stage process (decision on jurisdiction/final award) is increasingly being abandoned in favour of a 3 stage process (decision on jurisdiction/decision on liability/final quantum award). The panel's decision in this case is, unfortunately, consistent with this trend. (Another example of this is Burlington v. Ecuador (decision on liability made 2012), in which ConocoPhilips is again involved (having acquired Burlington).) The introduction of an additional phase obviously results in a more protracted process, which is frustrating for claimants. From the perspective of arbitration panelists and lawyers making money from the process, it is a wholly positive development!