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Deep-sea mining is really three separate industries targeting different ore types with wildly different impacts to the marine environment, but the focus for this hearing was on polymetallic nodules. These nodules are rich in cobalt, nickel, and manganese, but America has no capacity to refine nodules. Current proposals call for stockpiling nodules and the cheapest place to stockpile a nodule is to leave it on the seafloor.

My colleagues in the industry insist that nodule fields are more akin to deserts than rainforests. The opposite is true. The abyssal plains, where nodules are found, are more biodiverse than tropical rainforests with more unique species than almost any other ecosystem on the planet. Nodule fields are unique habitats and species abundance within nodules fields can be two to three times higher than the background abyssal plain. Unfortunately, because there are many species but few individuals, these species are especially vulnerable to extinction.

Mining the seafloor leaves permanent scars. Nodule fields take millions of years to form and recovery occurs over centuries, if at all. Impacts to the area around a mining site should be considered permanent. Beyond the seafloor, chemically-enriched plumes can spread for thousands of miles. The noise from mining equipment can deafen marine mammals. Ship traffic increases the risk of ship strikes to whales and other marine animals.

Within the U.S., mining will occur in areas connected to people with deep cultural ties to these waters. There has been near-universal, bipartisan opposition to deep-sea mining from the people of American Samoa, Guam, and the Northern Mariana Islands. Community support is not just an ethical imperative, but a practical one. A mining operation off the coast of American Samoa, will depend on American Samoan businesses and services. Without a good faith effort to build inroads in local communities, overseeing a large offshore operation is exponentially more challenging, expensive and complex. A rush towards commercial mining without building significant relationships within these communities cannot succeed.

The lack of urgency, environmental unknowns, and local opposition does not justify a rush to mine the seafloor. There are too many issues, both environmental and practical, that must be resolved before we can allow deep-sea mining to proceed.