The deep-sea may be vast and unexplored, but it is incredibly important. It encompasses 75% of the ocean’s volume and is the largest and least explored of Earth’s biomes. Some scientists believe that the deep sea and its water column may be the largest carbon sink on Earth. Plus, new species are still being found there, and sometimes, entirely new ecosystems are discovered.

A UN body called the International Seabed Authority (ISA) is responsible for governing and protecting the deep seabed on behalf of humankind as a whole. In practice, the ISA Secretariat routinely prioritizes the interests of pro-mining governments and companies over the protection of our fragile ecosystems.

The Republic of Nauru turned the deep-sea mining world on its head this summer when it invoked Article 15, colloquially known as the Trigger, starting a 2-year countdown on the finalization of mining regulations for polymetallic nodules in areas beyond national jurisdiction.

Deep-sea mining has been given the go-ahead to commence in two years, after the tiny Pacific island nation of Nauru notified the UN body governing the nascent industry of plans to start mining.

The stakeholder consultation process is to provide the stakeholder community — citizens of the Republic of Nauru, scientists, government and non-governmental officials, industry representatives, and other interested members of the public — with the opportunity to discuss, review, comment, and guide revisions to the Nauru Ocean Resources Incorporated (NORI) Collector Test Environmental Impact Statement (EIS) received by the ISA. Stakeholder consultation is recommended by the ISA’s Legal and Technical Commission.

NORI (a wholly owned subsidiary of The Metals Company of Canada) Stakeholder Consultation Process concludes on Friday November 19, 2021

This is a call to action for people to SUBMIT comments on the Environmental Impact Statement for a Deep Sea Mining Test Collection. Exploratory mining is the first step towards exploitation of the deep sea. Until Nov 19th, we have the opportunity to submit comments on the Collector Test EIS, to show that there is widespread opposition to deep seabed mining. Please feel free to copy and paste the included comments into the entry fields within the NORI Collector Test consultation web page.

There are two categories: 1.General Comments 2. Specific Comments . So, for example, you can simply copy the ‘General Comments’, and paste them directly into the General Comments field.

To submit comments, follow this link:

1. Scroll down to the form under the heading “Participate in the Stakeholder Consultation Process & Submit Written Comments”.

2. In the “specific comments” boxes, include the page number and section that correspond to the responses.

3. Copy and paste the responses below as a guideline or use them as a template to write your own comments.

General Comments

In light of the already-substantial research around deep sea disturbances due to mechanical strain, the proposed NORI-D collector test to be conducted within the Clarion-Clipperton Zone (CCZ), under the management of The Metals Company (TMC), should not be allowed to go any further.

The most notable, and comprehensive research to date being DISCOL (DIS-turbance and re-COL-onization experiment in a manganese nodule area of the deep South Pacific) conducted in 1989 by Hjalmar Thiel and his team of researchers.  In 2015, 26 years later, scientists returned to the DISCOL site located within the Peru Basin, and discovered that little to no life had returned to baseline levels — including characteristic animals such as sponges, soft corals, and sea anemones, amongst many others.  In the words of Thiel himself, “The disturbance is much stronger and lasting much longer than we ever would have thought.”  Over a quarter of a century later, and still next to no life has returned to the area where the tests were conducted.  It is clear that there is no feasible process which could in any way mitigate the kinds of disturbances created by the tests TMC wants to perform.

The Prototype Collector Vehicle (PCV) that will be used during NORI-D will, at the very least, totally disturb the top 1-10 cm of sediment on the sea floor in order to extract the polymetallic nodules.  This incredibly invasive process will rip apart benthic communities that have taken thousands of years to develop. Possibly even more destructive are the two sediment plumes that will result both from the PCV’s articulation (rolling, tracking, turning, sucking, and depositing fine sediment and crushed nodules) and the return pipe from the Surface Support Vehicle (SSV) where the unwanted fine sediment, warmed seawater, and crushed nodules will be returned to a depth of 1200 meters.  This agitated combination of silt and heavy metals will blanket, and coat countless organisms, preventing them from breathing, and eating.  It will also block bioluminescent light that some use to attract prey and find mates.  This is an unacceptable level of loss and disturbance, and the International Seabed Authority (ISA) must act unanimously to halt all such tests.    

The ISA has the historic opportunity to fulfill its mandate of “ensuring the effective protection of the marine environment from harmful effects that may arise from deep-sea-related activities.”  Without question, the NORI-D collector test will be harmful, and more importantly catastrophic to the living communities of megafaunal, macrofaunal, meiofaunal, and microbial organisms that live in the NORI-D test area, and beyond.  The campaign will not yield any further insight — the destructive, and long-lasting disturbances of polymetallic nodule collecting are unavoidable within the domain of seabed mining.

Indeed, even within the context of ALARP, or the mitigation of harms to ‘as-low-as-reasonably-possible,’ it would be hard to imagine a more devastating activity than seabed mining within the incredibly complex, and fragile ecosystem of the benthic-abyssal plains within the CCZ, and globally over any portion of the seabed.

Please act quickly to halt this test, and any subsequent proposals for such activities which will cause irreparable harm to the seabed and its living communities.

For the Specific Comments Section go to this link in Cryptpad:

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