We have reviewed the paper by the High Level Panel on Sustainable Ocean Economy, ‘What Role for Ocean-based Renewable Energy and Deep-Seabed Minerals in a Sustainable Future?’ by Lisa Levin, Diva Amon, Hannah Lily, Mark Hemer and Finn Gunnar Nielsen, and would like to offer the following comments.

Claim: A recent report commissioned by a deep-seabed mining company involved with three exploration tenements in the CCZ suggests that extracting half of the CCZ nodules would provide the manganese, nickel, cobalt and copper needed to electrify 1 billion cars, while releasing only 30 percent of the greenhouse gases of land mining (Paulikas et al. 2020). This conclusion has been questioned under various future global energy scenarios. Teske et al. (2016) conclude that an energy revolution, required to combat climate change, could take place without deep- seabed mining.

Response: The Metals Company does not claim that society’s energy transition cannot proceed without the injection of new minerals from deep-sea mining, as our recently released white paper makes clear. However, while there technically may be enough mineral resources on land to supply the green transition, for nickel and cobalt, and potentially for copper, the land-mining project pipeline will be insufficient to meet demand. That is because various supply chain risks exist. In the case of cobalt, child labour in the Democratic Republic of Congo, which supplies over 65% of the world’s supply, is rife. Furthermore, China has a stranglehold on cobalt processing and refinery. In the case of nickel, falling ore grades limit the expansion of sulphide ore projects, and scaling up nickel laterite projects in time would be both costly and ecologically disastrous.

The report places great stock in the ability of recycling, re-use and circular economy principles to facilitate reductions in the demand for metals – an assessment which is overly optimistic. To be sure, a circular economy is a preferred outcome and one that The Metals Company wholeheartedly supports.

However, progress on the creation of a circular economy must be driven by the underlying data and the distinction between local and global availability of recyclable metal stocks. In certain polities, notably in China, recycling and circular economy can help meet localized metal demand for certain types of infrastructure, which thus far does not include renewable energy technologies. Furthermore, under the transitions being advocated for by the International Renewable Energy Agency (IRENA) and the Paris climate accords, such initiatives will not suffice on a global scale.

Currently there is far too little existing metal stock in circulation that is available for recycling and this is likely to remain some years off. The World Bank has noted that even if mineral recycling rates reached 100%, primary metal production would still need to continue and that it is essential that this be undertaken in the most efficient and environmentally and socially responsible manner.

Most of this new demand will therefore need to be met by virgin metal extraction. While there is enough metal in terrestrial reserves to meet this demand in theory, in practice terrestrial metals and the mining industry is facing several serious challenges – falling grades, rising production costs, deposits in some of the most biodiverse places on the planet, heavy environmental and social costs. Collecting polymetallic nodules can greatly compress the social and environmental impacts of sourcing base metals.

Claim: The remoteness of most of the deep ocean combined with the harsh operating conditions (high pressure, low temperatures and darkness), requiring expensive and highly technical equipment, have resulted in limited exploration and scientific research. These constraints, and the vastness of the area in question, mean that the majority of the deep ocean, both within and beyond national jurisdictions, are poorly characterised and understood, or still completely unexplored.

Response: We agree that there is a significant need for greater research and The Metals Company is investing heavily to greatly enhance our understanding of the deep-ocean in the Clarion-Clipperton Zone region of the Pacific Ocean, to create the baselines called for in the report. We will be led in our efforts by a stellar international team of scientists including Dr. Jeff Drezen (University of Hawaii), Andrew Sweetman (Heriot Watt University), and a world-renowned scientific advisory committee chaired by Dr. Greg Stone, and including Dr. Bruce Robison (MBARI), and Dr Larry Madin (Woods Hole Oceanographic Institute).

We are conducting the world’s most integrated deep-sea research program from the surface of the ocean down through the water column to the abyssal plain. Abyssal plains are the most common habitat type on earth, though they vary considerably. Often referred to with the misnomer ‘desert,’ abyssal plains are among the more depauperate regions of the ocean, especially for easily visible benthic animals. This has led to some confusion as many scientists of late have been calling anything that is visible in this region ‘mega-fauna’, a term traditionally used for animals over 32kgs in weight. In the CCZ, the term means anything that may be observed with the naked eye. So we are conducting studies down into the microbial world because that is where the biodiversity can be found. Microbial studies are not included in any other resource extraction EIAs on the planet. Thus, this could be considered the most rigorous and comprehensive deep-sea study to date because we are studying everything from the surface to the deep seabed, and from the macro to the microbial level.

Whilst the immense size of the CCZ makes it difficult to discern if an organism is truly rare, we will thoroughly characterise pelagic and benthic biodiversity in our contract areas to discern if any are truly rare and combine these with data from APEIs and preservation zones to develop a better understanding. We will not apply for an exploitation license until all of these studies are complete and we have the answers we need. No deep-seabed mining will take place until these rigorous environmental studies have been conducted, vetted, reviewed and approved. If studies show there will be serious harm then the global community through the ISA can decide that mining will not occur.

Based on a two-year comprehensive desktop study, we see deep-ocean nodules as posing less biodiversity risk than land-based mining and are conducting the world’s largest integrated seabed-to-surface deep-ocean discovery program to fully assess the impacts of our operations. Our program will take in over 100 studies, involving over 100 researchers and scientists who will freely publish their findings over the next three years. This will make the eastern CCZ one of the most intensely studied regions of the deep ocean. We will generate massive amounts of new knowledge and data which will be shared freely to anyone wishing to analyse it and to extract new information about the deep ocean.

Claim: However, deep-seabed mining poses a risk for biodiversity loss, forced species migrations and loss of connectivity, potentially leading to species extinctions in the deep ocean (Van Dover et al. 2017; Niner et al. 2018). This is of particular concern as many deep-sea species may have genetic compounds that could have biotechnical or pharmaceutical use in the future.

Response: An important consideration is that any extractive industry, wherever and however it is conducted, cannot be done without negative externalities. The collection of polymetallic nodules is not zero-impact and will disturb the top 5 – 15 centimetres of sediment on the seabed and remove most (but not all) of the nodules in parts of licensed collection areas that certain deep-sea wildlife need for their life functions.

However, it is equally important to remember that that there are six times more species on land than in the ocean and that biomass in ocean sediment is three orders of magnitude less than in terrestrial soils. As a society, we must make fundamental and challenging choices about which species to protect – all of which are value-laden and deserving of deep consideration.

Some biodiversity loss is inevitable, and we plan to take every precaution to ensure that harm is minimal. A third of the CCZ has already been set aside as Protected Areas (Areas of Particular Environmental Interest), an area larger than those licensed out for exploration by the ISA. Contractors will establish additional protected areas of between 10-30% of their contract zones, so it may be possible to protect more than half of the CCZ. These protected areas will ensure that the animals in the area have plenty of habitat on the abyssal plain, the largest ecosystem on the planet.

Such protections would ensure that deep-ocean stocks of marine genetic resources would not be diminished to any meaningful degree and would remain available for medical research. Whilst great emphasis is given to the value of marine genetic resources, perhaps of more importance is the protection of our planet’s rainforests, which have already yielded large numbers of valuable genetic sequences and medically important substances and will likely continue to yield further such resources if they can be preserved.

Furthermore, any assessment of the biodiversity risks associated with deep-sea mining must be carefully weighed against the wider risks facing our planet, including risks to climate, human health and terrestrial biodiversity that would occur if some deep-sea mining, especially collection of polymetallic nodules, did not occur. We will also take reference samples of sediment in areas before we disturb them, storing them for future use and analysis to further mitigate the risk of microbial diversity loss.

Claim: If deep-seabed mining moves forward, it must be approached in a precautionary and adaptive manner, so as to integrate new knowledge and avoid and minimise harm to habitats, communities and functioning (Jaeckel 2017; Niner et al. 2018)

Response: The Metals Company fully agrees and is basing our entire operations around the precautionary approach. We are investing heavily in a suite of technologies that will allow us to adaptively manage the impacts of our operations in real time. We are developing a virtual replica of the deep-ocean environment. This will consist of a ‘digital twin’ involving sophisticated sensors and underwater drones which will feed a continuous stream of data into the cloud, enabling us to make adjustments to operations to minimise our impact. In a world first, this system will be open, providing stakeholders and the International Seabed Authority with a dashboard for visibility, and further underlining DeepGreen’s commitment to full transparency.

Claim: Another poorly understood issue is the length of time that biological communities affected by deep-seabed mining will take to recover.

Response: In understanding ecosystem recovery, context is key. The report cites a number of studies that found faunal density and diversity had yet to fully recover after at least two decades. However, without a comparison of equivalent mining practices on land, it is difficult to discern whether this is a good or bad outcome.

As it happens, substantial data show both biological and biogeochemical recovery of the seabed. Our science team is encouraged by DISCOL studies that show positive seafloor microbial recovery after 26 years.  Compared to a study of microbial recovery in terrestrial soil after mining: after 37 years, there had been only incomplete recovery.

Claim: There is likely to be solid waste material left after metal extraction, and disposal mechanisms for this waste could be comparable with those used for terrestrial mine tailings, some of which are introduced into the deep ocean via pipe.

Response: First and foremost, it is essential to understand that not all deep-sea mining is created equal, and each resource comes with its own set of unique characteristics and associated impacts. Whilst the report provides visual representation of the different forms of deep-sea mining, its consideration of the impacts assumes that these are largely uniform.

Polymetallic nodules are a very unique resource for a number of reasons. Unlike hydrothermal vents and seamounts, abyssal plains have far less biomass and polymetallic nodules can be collected without cutting or drilling.

They also happen to contain high concentrations of nickel, cobalt and manganese—the same metals that make up most electric vehicle batteries—as well as copper needed for electric wiring. It is like having several mining projects in one, although the nodules are sitting unattached on top of the deep seabed and therefore don’t require the removal of millions of tons of overburden and waste rock, or human settlements or tropical rainforests to get at the ore. Nodules are also unique because they don’t contain toxic levels of heavy elements and this makes it possible to process them with near-zero solid waste and no toxic tailings—which means no tailing dam collapses, eco- and human toxicity. Once nodules have been collected and raised to the surface, they will be sent to shore for near-zero waste processing – a true step-change in the metals industry.

Claim: There are calls for pilot testing and further scrutiny of the issue, as well as for a moratorium or precautionary pause… A major aim of such a pause is to allow scientific research to advance, possibly in conjunction with the Decade of Ocean Science for Sustainable Development.

Response: We take our analysis of the urgency of this timeframe from the Intergovernmental Panel on Climate Change’s (IPCC) Special Report on Global Warming of 1.5°C which warns that to avoid overshooting a 1.5°C rise in average global temperature, we must reduce CO2 emissions by 45% below 2010 levels by the year 2030 and reach net zero by 2050. In this context, the reduction of every possible gigatonne of emissions is urgent.

While we absolutely would like to see increased research intensity in this regard, given the urgent timeframe for the decarbonisation of the global economy, time is a luxury we simply do not have. As the report notes, producing the metals critical for low-carbon technologies from polymetallic nodules can offer meaningful reductions in CO2 emissions compared to land-based mining – by our analysis as much as 70%.

Claim: It has also been noted that deep-seabed mining may cause a loss of cultural or spiritual value associated with a pristine ocean, or traditional sense of ownership of or identification with the ocean and its resources

Response: It is important to consider that Pacific States’ connection with and reliance upon the ocean provides them with a unique perspective, and they are arguably better placed to responsibly develop these resources as they value the ocean and have strong cultural connections to it.

Pacific States are acutely vulnerable to climate change and sea level rise and those states that are supportive of deep-sea mining do so because they recognise the benefits of participating in a system specifically designed and developed to allow Developing States who have historically been left out of new industry to pursue a self-determined development path.

As part of the Social component of our Environmental and Social Impact Assessment, The Metals Company will engage with stakeholders from amongst our Pacific sponsoring states to ensure that the collection of polymetallic nodules does not infringe upon the spiritual and cultural value they attribute to the ocean.

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