Oppose Deep Seabed Mining
Deep Seabed Mining: Notice of Receipt of Application for Deep Seabed Mining Exploration Licenses and Announcement of Public Comment Period and Virtual Public Hearing
National Oceanic and Atmospheric Administration· Deep Seabed (U.S.-regulated international waters)Federal Register 2026-10975 ↗
A mining company wants federal permission to explore the deep ocean floor, and public comments can stop it.
What’s at risk
Deep ocean ecosystems in U.S.-regulated international waters face potential damage from seabed mineral extraction by American Deep Sea Minerals, Inc. Approving this license could open the door to full commercial mining of the ocean floor.
If this goes through
ADSM receives a federally approved exploration license that sets a legal precedent making future commercial deep seabed mining in U.S.-regulated waters significantly easier to permit.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
9 holes in the agency’s own analysis
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- ADSM's own financial disclosure shows the company holds only $150,000 in cash, with $100,000 earmarked solely for the NOAA license fee and just $50,000 left for pre-mobilization, compliance, and administrative costs, yet the application simultaneously asserts the company has the financial capacity to fund a multi-year, multi-cruise exploration program with vessels, AUVs, ROVs, and laboratory work. NOAA should require audited or otherwise verifiable financial statements demonstrating actual capacity to complete the four-year program before issuing the license, or extend the comment period until this gap is resolved.
- Section 2.1 claims ADSM 'demonstrates full technological capability to implement the four-year exploration program,' but the very next subsection admits no contracts exist with any vessel owner or equipment provider and that agreements will only be 'formalized' before exploration begins. NOAA should require executed agreements, not preliminary discussions, before making a technological-capability determination under 970.402.
- The application repeatedly leans on NOAA's 1981 Programmatic EIS to conclude that mapping, coring, and AUV/ROV work carry no potential for significant impact, without any reassessment of whether a 44-year-old finding still applies to the scale described (25 box cores in Year 1 alone, multi-year AUV/ROV deployments, dredging for bulk metallurgical samples). NOAA should explain why the 1981 PEIS remains an adequate basis for a no-significant-impact finding for this specific, more intensive program, or prepare updated project-specific environmental analysis.
- The document admits that no site-specific benthic biology surveys have ever been conducted in the actual license area, yet the entire environmental baseline section relies on data from neighboring, already-licensed areas of the Cook Islands EEZ to support a 'no significant impact' conclusion for exploration activities. NOAA should require in-situ baseline data for the actual license area before authorizing activities premised on assumptions carried over from adjacent, geologically similar but distinct areas.
Show all 11 points from the document
- ADSM's economic case for the license, including claims that high nodule abundance reduces environmental footprint, rests on resource figures the document itself footnotes as unverified. NOAA should require independent verification of these abundance and value figures before accepting arguments that rely on them to minimize projected environmental impact or justify the program's economic viability.
- The use-conflict analysis concludes that risks to pelagic fauna are 'low but non-negligible' and overall anticipated risks in the use conflict section are 'low to moderate,' yet the pelagic fauna subsection admits data on pelagic species distribution and behavior in the area is sparse. NOAA should not accept a low-risk characterization for marine mammals, turtles, and pelagic fish until the acknowledged data gaps are filled through dedicated baseline surveys.
- ADSM proposes Biodiversity Preservation Areas as a mitigation measure for potential undocumented or endemic species, but provides no locations, sizes, or selection criteria for these areas, leaving the primary conservation mitigation entirely undefined. NOAA should require ADSM to specify concrete BPA boundaries and criteria as part of the exploration plan rather than accepting a vague future commitment.
- To support its claim that sediment disturbance from Years 1-3 sampling will be minimal, the application cites MIT and Scripps plume studies of a prototype seafloor collector, a very different piece of equipment operating at a different scale than the box corers, multicorers, and dredges actually proposed for early years. NOAA should require ADSM to justify this analogy or commission gear-specific plume and disturbance analysis rather than relying on collector-trial data as a proxy.
- The vessel safety section states only that ADSM 'anticipates' using a foreign-flagged vessel over 300 gross tons, without identifying the specific vessel, its flag state, or confirming SOLAS and classification-society compliance, despite this being a threshold safety requirement under NOAA's regulations. NOAA should require identification of the actual vessel and proof of compliance before license issuance rather than accepting a promise of future submission.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
NOAA has received an application for a license to conduct seabed mining exploration activities that is fully compliant with the applicable information requirements of the Deep Seabed Hard Mineral Resources Act (DSHMRA or the Act) and the Act's implementing regulations. As part of the application review process, NOAA will hold one virtual public hearing on American Deep Sea Minerals, Inc.'s (ADSM) application and will accept written comments on the application submitted electronically via the instructions below.
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