[House Hearing, 119 Congress]
[From the U.S. Government Publishing Office]


                      EXPLORING THE POTENTIAL OF
         DEEP-SEA MINING TO EXPAND AMERICAN MINERAL PRODUCTION
=======================================================================

                           OVERSIGHT HEARING

                               BEFORE THE

                      SUBCOMMITTEE ON OVERSIGHT AND 
                              INVESTIGATIONS

                                 OF THE

                     COMMITTEE ON NATURAL RESOURCES
                     U.S. HOUSE OF REPRESENTATIVES

                    ONE HUNDRED NINETEENTH CONGRESS

                             FIRST SESSION

                               __________

                        Tuesday, April 29, 2025

                               __________

                           Serial No. 119-18

                               __________

       Printed for the use of the Committee on Natural Resources
       
[GRAPHIC NOT AVAILABLE IN TIFF FORMAT]       

        Available via the World Wide Web: http://www.govinfo.gov
                                   or
          Committee address: http://naturalresources.house.gov
          
                              __________
                                
                  U.S. GOVERNMENT PUBLISING OFFICE
60-289                      WASHINGTON : 2026

=======================================================================
                     COMMITTEE ON NATURAL RESOURCES

                     BRUCE WESTERMAN, AR, Chairman
                  ROBERT J. WITTMAN, VA, Vice Chairman
                   JARED HUFFMAN, CA, Ranking Member

Robert J. Wittman, VA,
Tom McClintock, CA			Joe Neguse, CO
Paul A. Gosar, AZ			Teresa Leger Fernandez, NM
Aumua Amata C. Radewagen, AS		Melanie Stansbury, NM
Doug LaMalfa, CA			Val Hoyle, OR
Daniel Webster, FL			Seth Magaziner, RI
Russ Fulcher, ID			Jared Golden, ME
Pete Stauber, MN			Dave Min, CA
Tom Tiffany, WI				Maxine Dexter, OR
Lauren Boebert, CO			Pablo Jose Hernandez, PR
Cliff Bentz, OR				Emily Randall, WA
Jen Kiggans, VA				Yassamin Ansari, AZ
Wesley P. Hunt, TX			Sarah Elfreth, MD
Mike Collins, GA			Adam Gray, CA
Harriet M. Hageman, WY			Luz Rivas, CA
Mark Amodei, NV				Nydia Velazquez, NY
Tim Walberg, MI				Debbie Dingell, MI
Mike Ezell, MS				Darren Soto, FL
Celest Maloy, Utah			Julia Brownley, CA
Addison McDowell, NC			Vacancy
Jeff Crank, CO
Nick Begich, AK
Jeff Hurd, CO
Mike Kennedy, UT

�
�               Vivian Moeglein, Staff Director
�                 William David, Chief Counsel
�              Ana Unruh Cohen, Democratic Staff Director

                  http://naturalresources.house.gov
                                 ------                                

              SUBCOMMITTEE ON OVERSIGHT AND INVESTIGATIONS

                        PAUL GOSAR, AZ, Chairman
                     LAUREN BOEBERT, CO, Vice Chair
                   MAXINE DEXTER, OR, Ranking Member

Lauren Boebert, CO                   Yassamin Ansari, AZ
Mike Collins, GA                     Pablo Jose Hernandez, PR
Mark Amodei, NV                      Vacancy
Nick Begich, AK                      Jared Huffman, CA, ex officio
Bruce Westerman, AR, ex officio
                              -----------
                              
                               CONTENTS

                              ----------                              
                                                                   Page

Hearing Memo.....................................................     v
Hearing held on Tuesday, April 29, 2025..........................     1

Statement of Members:

    Gosar, Hon. Paul, a Representative in Congress from the State 
      of Arizona.................................................     1
    Dexter, Hon. Maxine, a Representative in Congress from the 
      State of Oregon............................................     3
    Huffman, Hon. Jared, a Representative in Congress from the 
      State of California........................................     4
    Westerman, Hon. Bruce, a Representative in Congress from the 
      State of Arkansas..........................................    44

Statement of Witnesses:

    Barron, Gerard, CEO and Chairman, The Metals Company, 
      Raleigh, North Carolina....................................     6
        Prepared statement of....................................     8
        Questions submitted for the record.......................    17
    Gunasekara, Oliver, CEO and Co-Founder, Impossible Metals, 
      San Jose, California.......................................    19
        Prepared statement of....................................    21
        Questions submitted for the record.......................    22
    Currie, Duncan, Legal Advisor, Deep Sea Conservation Center, 
      Christchurch, New Zealand..................................    25
        Prepared statement of....................................    27
        Questions submitted for the record.......................    28
    Peacock, Thomas, Professor of Mechanical Engineering, 
      Director, Massachusetts Institute of Technology, Cambridge, 
      Massachusetts..............................................    37
        Prepared statement of....................................    39
        Questions submitted for the record.......................    41

Additional Materials Submitted for the Record:

    Submissions for the Record by Representative Dexter

        The People of American Samoa Stand Against Deep-sea 
          Mining, Letter.........................................    64
        BBSEA Critical Minerals for Defense Report...............    65
        Biodiversity Loss From Deep-Sea Mining, Correspondence...    66
        Companies Calling for a Deep-Sea Mining Moratorium.......    66
        Current Biology--How many metazoan species live in the 
          world's largest mineral exploration region?, Article...    67
        Deep Sea Mining Isn't Worth The Risk, Report.............    68
        Shipping Giant Maersk Drops Deep Sea Mining Investment, 
          Exclusive..............................................    69
        International Energy Agency (IEA) Page on Critical 
          Minerals, Study........................................    70
        International Seabed Authority Metals, Study.............    71
        ISA Fact Sheet on the Composition of Polymetallic Nodules    72
        Marine Expert Statement Calling for a Pause to Deep-Sea 
          Mining.................................................    73
        Long-Term Impact and Biological Recovery in a Deep-Sea 
          Mining Track, Article..................................    74
        Mining Company Seeks Trump Support to Shortcut Access to 
          Seabed Metals, Article.................................    75
        The Ocean Economy to 2050, Publication...................    76
        Seafood Market Statement Supporting a Pause on Deep-Sea 
          Mining.................................................    77
        Trump Order Encourages Controversial Deep-Sea Mining for 
          Critical Minerals, Article.............................    78

Supplemental Materials Submitted for the Record:

    Submissions Submitted for the Record by Mr. Barron

        Department of Commerce, NOAA, Deep Seabed Mining, Final 
          Technical Guidance Document, September 1981............    79
        Department of Commerce, NOAA, Deep Seabed Mining Report, 
          December 1981..........................................    80
        Department of Commerce, NOAA, Deep Seabed Mining, Report 
          to Congress, December 1983.............................    81
        Department of Commerce, NOAA, Deep Seabed Mining, Report 
          to Congress, December 1987.............................    82
        Department of Commerce, NOAA, Deep Seabed Mining, Report 
          to Congress, December 1989.............................    83
        Department of Commerce, NOAA, Deep Seabed Mining Report, 
          Report to Congress, December 1991......................    84
        Department of Commerce, NOAA, Deep Seabed Mining Report, 
          Report to Congress, December 1993......................    85
        Department of Commerce, NOAA, Deep Seabed Mining Report, 
          Report to Congress, December 1995......................    86
        Department of Commerce, NOAA, Deep Seabed Mining, Final 
          Programmatic Environmental Impact Statement, September 
          1981...................................................    87
        Department of Commerce, NOAA, Deep Seabed Mining, Final 
          Programmatic Environmental Impact Statement, November 
          1994...................................................    88
        15 CFR Part 970--Deep Seabed Mining, Regulations for 
          Exploration Licenses, Electronic Code of Federal 
          Regulations............................................    89
        30 USC Ch. 26--Deep Seabed Hard Mineral Resources........    90
        15 CFR Part 960--Licensing of Private Remote Sensing 
          Space Systems..........................................    91
        Department of Commerce, NOAA, Deep Seabed Mining, Draft 
          Environmental Impact Statement, May 1984...............    92
        Department of Commerce, NOAA, Deep Seabed Mining, Final 
          Environmental Impact Statement on Issuing Exploration 
          Licenses to Kennecott Consortium, July 1984............    93
        Department of Commerce, NOAA, Final Environmental Impact 
          Statement on Issuing Exploration Licenses to Ocean 
          Management Inc., July 1984.............................    94
        Department of Commerce, NOAA, Final Environmental Impact 
          Statement on Issuing Exploration Licenses to Ocean 
          Minerals Co., July 1984................................    95

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  To:        House Committee on Natural Resources Republican Members

From:     Natural Resources Subcommittee on Oversight and 
        Investigations Staff, Michelle Lane 
        ([email protected]) x6-4137 and Lucas Drill 
        ([email protected]) x5-0500

Date:     April 28, 2025

Subject:   Oversight Hearing titled ``Exploring the Potential of Deep-
        Sea Mining to Expand American Mineral Production''
________________________________________________________________________
        
    The Subcommittee on Oversight and Investigations will hold an 
oversight hearing titled ``Exploring the Potential of Deep-Sea Mining 
to Expand American Mineral Production'' on Tuesday, April 29, 2025, at 
10:15 a.m. in 1324 Longworth House Office Building.
    Member offices are requested to notify Jace McNaught 
([email protected]) by 4:30 p.m. on April 28, if their 
Member intends to participate in the hearing.
I. KEY MESSAGES

     Minerals, particularly critical minerals, are essential to 
            contemporary life. The House Committee on Natural Resources 
            Majority has repeatedly emphasized the importance of 
            critical minerals and securing American mineral supply 
            chains.

     Republican Members of Congress and the Trump 
            Administration have championed an all-of-the-above approach 
            to mineral exploration and extraction to counter 
            longstanding foreign influence, particularly by China, and 
            secure domestic mineral supply chains.

     The sea floor is lined with critical and other hardrock 
            minerals, often found in the form of polymetallic nodules, 
            which are similar in size to golf balls. While the 
            technology and research to mine in the deep-sea has existed 
            for decades, global supply chains, increased reliance on 
            adversarial foreign nations for critical minerals, and an 
            uptick in general demand for these minerals have increased 
            interest in deep-sea mining.

     American seabed mining companies are leading the global 
            race to explore deep-sea mineral deposits and develop 
            technology enabling efficient mineral harvesting from the 
            sea floor.

     Now is the time to reform permitting processes to unleash 
            crucial terrestrial mining projects and embolden seabed 
            mining operations, which together will secure American 
            mineral supply chains.

II. WITNESSES

     Mr. Gerard Barron, CEO and Chairman, The Metals Company 
            and The Metals Company USA, Raleigh, NC

     Mr. Oliver Gunasekara, CEO and Co-Founder, Impossible 
            Metals, San Jose, CA

     Dr. Thomas Peacock, Professor of Mechanical Engineering 
            and Director, Environmental Dynamics Laboratory, 
            Massachusetts Institute of Technology, Cambridge, MA

     Mr. Duncan Currie, Legal Advisor, Deep Sea Conservation 
            Coalition, Christchurch, New Zealand (Minority witness)

III. BACKGROUND
Minerals are Essential to Contemporary Life
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    .epsMinerals, particularly those identified by the U.S. Department 
of the Interior's (DOI) U.S. Geological Survey (USGS) as critical to 
America's national security, economy, or energy infrastructure, are 
essential to contemporary life. The House Committee on Natural 
Resources has repeatedly emphasized the importance of minerals and 
securing American mineral supply chains.2 The Committee has 
highlighted the countless applications of hardrock minerals and the 
exponentially rising global mineral demand. In addition, the Committee 
continues to speak to the rapidly increasing difficulty of meeting 
mineral demand due to permitting delays, legislative restrictions, and 
America's near-total mineral dependence on foreign nations like 
China.3
    Spurred by this battered current state of domestic mineral supply 
chains,4 Republican Members of Congress 5 and the 
Trump Administration 6 have championed an all-of-the-above 
approach to mineral exploration and extraction policy, which includes 
not only streamlining permitting for terrestrial mining projects and 
encouraging American companies to continue investing in space mining 
technologies,7 but also diving deep to harvest minerals 
lining the sea floor.
    Recognizing this need, on April 24, 2025, President Trump issued an 
Executive Order, Unleashing America's Offshore Critical Minerals and 
Resources, that made clear that the United States must immediately 
``accelerate the responsible development of seabed mineral resources,'' 
invest in deep sea mapping and technology to ``quantify the Nation's 
endowment of seabed minerals,'' and ``ensure secure supply chains for 
our defense, infrastructure, and energy sectors'' through seabed 
mining.8
Seabed Mining
    Seabed mining is the process of ``extracting sediment and mineral 
resources from the seafloor.'' 9 These mineral resources 
prominently include three types of deposits:

    The first, polymetallic nodules, typically exist on abyssal plains, 
look like potato-shaped rocks, and contain cobalt, copper, manganese, 
nickel, and other metallic rare earth elements (REEs) that are 
essential to the production of batteries, electronics, and 
steel.10 The nodules develop over millions of years as 
minerals create thin concentric layers around small hard fragments like 
shells or shark teeth.11 The nodules can vary greatly in 
size, from about 2 to 20 centimeters, and are estimated to exist 
worldwide in numbers as abundant as 210 trillion dry tons.12
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    Polymetallic nodules are the most prominent form of seabed 
minerals targeted for extraction, with several methods for harvesting 
having been proposed. These include:

  1.  A ``remotely operated collector vehicle fitted with caterpillar-
            like tracks that uses a water stream aimed at nodules 
            laying on the seafloor to create a pressure drop and 
            suction effect to lift sediment with nodules into a 
            collector system.'' 14 This method functions as 
            a vacuum-like system for harvesting polymetallic nodules.

  2.  An ``autonomous underwater vehicle that hovers over the seafloor 
            and uses robotic arms with a vision system to pick 
            individual nodules from the seafloor.'' 15 This 
            method is empowered by artificial intelligence to avoid 
            picking up objects other than nodules.16

    Nodules were discovered as early as the 1870s during the HMS 
Challenger expedition,17 but extraction and processing 
methods were not adequately explored until the 1970s.18
    The second type of deposit, polymetallic sulfides, is usually found 
on sea ridges and ``precipitate from hydrothermal fluids at 
hydrothermal vent sites.'' 19 These sulfides often contain 
copper, gold, iron, lead, silver, and zinc.20 To mine 
sulfides, a ``[r]emotely operated mining machine that cuts and/or 
drills into the hard substrate of the hydrothermal vent chimney to 
extract internal minerals'' is required.21
    The third, ferromanganese or cobalt-rich crusts, are typically 
found across ocean basins and shallower exclusive economic zones (EEZs) 
in volcanically active regions.22 These crusts form on hard 
surfaces like rocks ``from seawater rich in dissolved metals,'' and 
contain cobalt, manganese, nickel, platinum, and other metallic 
REEs.23 To mine crusts, a ``[r]emotely operated mining 
machine that scrapes across the surfaces of geologic features to remove 
surficial mineral crusts'' is most effective.24
    Two other types of mineral deposits, placers (heavy mineral sands) 
and phosphorites (sedimentary rocks), both occur in shallow waters 
close to shore. They contain relatively low concentrations of minerals 
and are, therefore, of little interest to commercial seabed mining 
operations.25 Additionally, seabed mining techniques have 
been historically used to extract diamonds from the waters of South 
Africa and Namibia.26
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    Seabed mining can occur within two distinct geographic areas:

  1.  Exclusive Economic Zones (EEZs): Areas to which coastal nations 
            ``may claim sovereign rights for the purpose of exploring 
            and exploiting the natural resources of its continental 
            shelf.'' 28 A nation's domestic laws regulate 
            seabed mining activities within EEZs.29 EEZs 
            typically extend up to 200 nautical miles from shore and 
            usually feature waters less than 200 meters (approximately 
            656 feet) deep.30 In the United States, the EEZ 
            encompasses the U.S. Outer Continental Shelf (OCS), which 
            extends from about 3 nautical miles from 
            shore,31 where state-controlled waters 
            end,32 to about 200 nautical miles.33 
            Seabed mining in the U.S. EEZ is regulated by DOI's Bureau 
            of Ocean Energy Management (BOEM).34

  2.  Areas Beyond National Jurisdiction (ABNJ): Areas beyond EEZs, 
            also known as the high seas or international waters, 
            include all areas beyond approximately 200 nautical miles 
            from the shores of coastal nations.35 ABNJ 
            commonly feature depths beyond 200 meters, at which seabed 
            mining is also called deep-sea mining.36 ABNJ 
            seabed mining is generally regulated by the United Nations 
            Convention on the Law of the Sea (UNCLOS) and its 
            established International Seabed Authority 
            (ISA).37 In the United States, which is not a 
            party to UNCLOS, ABNJ seabed mining is regulated by the 
            U.S. Department of Commerce's (DOC) National Oceanic and 
            Atmospheric Administration (NOAA).38 The most 
            prominent hotspot of ABNJ seabed mining interest is known 
            as the Clarion-Clipperton zone (CCZ) in the Pacific 
            Ocean.39

Domestic (EEZ) Governance Framework for Seabed Mining
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    Seabed mining within the United States EEZ is regulated by 
BOEM, which has two primary functions related to seabed mining and 
critical minerals: 1) evaluating the U.S. OCS for mineral resources; 
and 2) leasing submerged lands for critical mineral exploration and 
development.41 BOEM's administration of OCS leases, pursuant 
to the Outer Continental Shelf Lands Act of 1953,42 most 
directly impact the seabed mining industry. While BOEM's Marine 
Minerals Program has ``supported work to evaluate critical mineral 
resources on the OCS'' to meet its first mission,43 BOEM has 
not ``held any lease sales for critical minerals on the OCS or issued 
any critical mineral leases'' to meet its second, more essential, 
mission to secure domestic mineral supply chains.44
    The failure to lease areas within the U.S. EEZ is due largely to a 
fatal flaw in BOEM's regulatory scheme that poses a heavy economic 
burden coupled with unnecessary risk on aspiring American seabed mining 
operations.45 BOEM's scheme is a two-step process. First, an 
entity interested in exploring U.S. seabed mineral deposits for later 
commercial purposes must apply to BOEM for a prospecting 
permit.46 Data collected by the permit holder must then be 
shared with BOEM. Crucially and problematically, ``a prospecting permit 
is separate from a lease to develop minerals in an area, and the 
prospecting permit does not convey any preferential right to a lease.'' 
47 Put simply, a company that expends considerable resources 
prospecting for seabed minerals under a BOEM prospecting permit must 
then begin the leasing process from scratch and compete with other 
seabed mining entities for the right to extract the minerals it located 
and studied.
    The BOEM leasing process itself is also burdensome. The leasing 
process can start with an unsolicited request for a lease sale to BOEM 
or can be initiated by BOEM.48 Regardless, BOEM must publish 
a request for interest detailing the mineral lease sale in the Federal 
Register.49 BOEM lease sales must be awarded through 
competitive cash auctions.50 Then, once a lease is awarded, 
BOEM must approve three plans before any seabed mining activities may 
start: 1) a delineation plan describing how the lessee will locate and 
characterize the minerals to be extracted; 2) a testing plan describing 
pilot mining and equipment testing activities; and 3) a mining plan 
that includes ``comprehensive detailed descriptions, illustrations, and 
explanations of the proposed OCS mineral development, production, and 
processing activities, as well as plans to address environmental 
impacts and plans to clear the lease area when mining activities end.'' 
51 Each of these approved plans must then be strictly 
adhered to during all seabed mining operations.52 Pursuant 
to the Inflation Reduction Act of 2022, BOEM's regulations and 
processes also apply to ``submerged lands offshore of U.S. territories 
as part of the OCS.'' 53
    Despite the burdens of BOEM's regulatory scheme, at least one 
American company, Impossible Metals, ``has submitted a request to 
commence a leasing process for exploration and potential mining of 
critical minerals in the deep sea off the coast of American Samoa.'' 
54 This first-of-its-kind request from Impossible Metals to 
BOEM may facilitate increased interest in seabed mining in the U.S. 
EEZ.
    Additionally, President Trump's April 2025 Executive Order aimed at 
revitalizing American seabed mining dominance directs DOI, through 
BOEM, to ``establish an expedited process for reviewing and approving 
permits for prospecting and granting leases for exploration, 
development, and production of seabed mineral resources'' found in the 
OCS.55 This new expediated process ``should ensure 
efficiency, predictability, and competitiveness for American 
companies'' as BOEM's regulatory scheme is reviewed and 
streamlined.56
International (ABNJ) Governance Frameworks for Seabed Mining
[GRAPHIC] [TIFF OMITTED] T0289.008

    There are two major international entities that regulate ABNJ 
seabed mining. In addition, the United States has also established its 
own international regulatory scheme:

  1.  UNCLOS. In 1982, the United Nations (UN) ``established a 
            framework governing activities on, over, and under the 
            world's ocean.'' 58 UNCLOS ``considers minerals 
            collected from ABNJ as common heritage of mankind, meaning 
            seabed resources are available for everyone's use and 
            benefit, including Small Island Developing States, 
            Landlocked Developing Countries, and Least Developed 
            Countries.'' 59 UNCLOS entered into force in 
            1994. The United States did not ratify UNCLOS and is not a 
            party to the convention.60 The U.S. does, 
            however, recognize that some portions of UNCLOS reflect 
            customary international law.61

  2.  ISA. UNCLOS established the International Seabed Authority (ISA) 
            as ``an autonomous organization that regulates and controls 
            mineral-related activities in ABNJ for parties to UNCLOS.'' 
            62 Because the U.S. is a member of the UN, it 
            holds observer delegate status at the ISA despite not being 
            party to UNCLOS.63 The ISA has issued 31 
            exploration contracts to public and private seabed mining 
            companies, including 17 for polymetallic nodules in the 
            CCZ, which contains ``more copper, cobalt, nickel, and 
            manganese than all known land deposits combined.'' 
            64 The ISA ``has yet to develop a regulatory 
            regime for the extraction of seabed minerals and therefore 
            has not issued exploitation contracts'' for the extraction 
            of deep-sea minerals.65 The ISA's deadline to 
            establish this regulatory regime is 2025. Notably, China 
            and Russia are both parties to UNCLOS and hold exploration 
            contracts issued by the ISA in the CCZ. China, in 
            particular, has actively sought ``seabed mining 
            partnerships far beyond its shores,'' which presents 
            security concerns to the United States as China's seabed 
            exploration activities generate data that can be used for 
            future deep-sea mineral harvesting and military 
            purposes.66

  3.  U.S. Law and NOAA. NOAA regulates U.S. seabed mining activity 
            beyond the boundary of the U.S. EEZ. In 1980, Congress 
            passed the Deep Seabed Hard Mineral Resources Act (DSHMRA) 
            that established a framework for ``authorizing U.S. 
            citizens to explore for and recover minerals from the 
            seabed in ABNJ'' by enabling NOAA ``to issue exploration 
            licenses and commercial recovery permits to U.S. citizens 
            for deep-seabed mining activities.'' 67 NOAA 
            must ``prepare and publish an environmental impact 
            statement for its issuance'' of an exploration license or 
            commercial recovery following National Environmental Policy 
            Act (NEPA) processes.68 To be clear, ``the lack 
            of accession by the United States to UNCLOS does not 
            preclude NOAA from issuing exploration licenses or 
            commercial recovery permits pursuant to DSHMRA.'' 
            69 In fact, in 1984, ``NOAA issued exploration 
            licenses for four sites located in the CCZ.'' 70 
            Two of these exploration licenses, USA-1 and USA-4, were 
            renewed in 2022 and are still held by Lockheed 
            Martin.71 However, these licenses were 
            originally issued prior to UNCLOS entering into force and 
            before the establishment of the ISA.72 Today, it 
            is unclear whether new NOAA recovery permits would be 
            recognized as legitimate by UNCLOS parties, and it is 
            possible that the ISA could attempt to issue permits to 
            other companies from UNCLOS party nations in the same areas 
            as U.S. companies permitted by NOAA.73

    Nevertheless, leading American scholars claim that the NOAA 
regulatory scheme is sufficient to allow American companies to mine the 
deep sea without the U.S. ratifying UNCLOS.74 Because of 
this confidence, at least one American company, The Metals Company USA, 
has ``initiated a process'' with NOAA ``to apply for exploration 
licenses and commercial recovery permits under existing U.S. 
legislation.'' 75 Moreover, President Trump's April 2025 
seabed mining Executive Order directs DOC, through NOAA, to ``expedite 
the process for reviewing and issuing seabed mineral exploration 
licenses and commercial recovery permits in areas beyond national 
jurisdiction.'' 76 This expedited process seeks to 
explicitly reinvigorate NOAA's ABNJ regulatory authority, which gives 
U.S. companies like The Metals Company USA the conviction, 
predictability, and competitiveness necessary to lead the world in 
seabed mineral exploration, identification, and 
collection.77
Regulatory and Permitting Reform is Essential for Successful Seabed 
        Mining Operations
    Navigating domestic and international regulatory frameworks to 
harvest minerals from the sea floor presents unique challenges for 
seabed mining stakeholders. Additionally, efficiently processing and 
refining these minerals once recovered is a vital consideration for 
mining operators without a clear solution, barring permitting reform. 
Today, although some foreign mineral processing facilities can extract 
some minerals from polymetallic nodules, no such facilities exist in 
the United States. Further, no purpose-built facility exists to 
effectively extract all the valuable minerals found in each nodule 
brought up from the sea floor.78 According to experts, one 
purpose-built facility could not only unleash polymetallic nodule 
processing capabilities but also create approximately 1,500 direct and 
10,000 indirect jobs.79 Yet, until more processing 
facilities are constructed, particularly in the United States, reaping 
all the benefits of an all-of-the-above approach to securing domestic 
critical mineral supply chains, which includes seabed mining, remains a 
moving target.
    Seabed mining efforts by U.S. entities, in the U.S. EEZ and in 
ABNJ, collectively represent a willingness to dive deep and use natural 
resources found in our waters effectively. As technology progresses at 
a rapid pace, costs are further reduced and collaboration in the seabed 
mining industry continues, the U.S. could not only develop the ability 
to harness vast mineral resources, but also apply these technologies to 
mining operations on land and in space to secure U.S. mineral supply 
chains.
    Like most sectors, new and innovative technology has historically 
driven the mining industry. Today, promising new technologies in 
withstanding pressure, artificial intelligence, mapping, data, 
processing, and refining efficiencies promise to upend the industry 
just as updates in machinery, robotics, and basic safety equipment did 
in years past.80 The time is now to embrace permitting 
reform for seabed and land-based mining as the United States seeks to 
secure its domestic supply chain. This is crucial not only for 
developing emerging technologies and strengthening our economy, but 
also for ensuring national security.
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                   OVERSIGHT HEARING ON EXPLORING THE.
            POTENTIAL OF DEEP-SEA MINING TO EXPAND AMERICAN 
                             MINERAL PRODUCTION

                              ----------                              


                        Tuesday, April 29, 2025

                     U.S. House of Representatives

              Subcommittee on Oversight and Investigations

                     Committee on Natural Resources

                            Washington, D.C.

                              ----------                              

    The Subcommittee met, pursuant to notice, at 10:15 a.m. in 
Room 1324, Longworth House Office Building, Hon. Paul Gosar 
[Chairman of the Subcommittee] presiding.
    Present: Representatives Gosar, Westerman; Dexter, and 
Huffman.
    Also present: Representatives Hunt, Webster; and Case.

    Dr. Gosar. The Subcommittee on Oversight and Investigations 
will come to order.
    Without objection, the Chair is authorized to declare a 
recess of the Subcommittee at any time.
    The Subcommittee is meeting today to hear testimony on 
exploring the potential of deep-sea mining to expand American 
mineral production.
    Under Committee Rule 4(f), any oral opening statements at 
the hearing are limited to the Chairman and the Ranking Member, 
as well as the Ranking Member and the Chairman of the Full 
Committee. I therefore ask unanimous consent that all other 
Members' statements be made part of the hearing record if they 
are submitted in accordance with Committee Rule 3(o).
    Without objection, so ordered.
    I ask unanimous consent that the following Members be 
allowed to sit and participate in today's hearing: the 
gentleman from Florida, Mr. Webster; the gentleman from Texas, 
Mr. Hunt; and the gentleman from Hawaii, Mr. Case.
    Without objection, so ordered.
    I recognize the Full Committee Chair, Mr. Westerman.
    I will now open with my opening statement.

STATEMENT OF THE HON. PAUL GOSAR, A REPRESENTATIVE IN CONGRESS 
                   FROM THE STATE OF ARIZONA

    Dr. Gosar. Good morning, everyone. Thank you to our 
witnesses who came today to testify on this important issue: 
exploring the potential of deep-sea mining to expand American 
mineral production.
    From the moment President Trump began his second term, the 
House Committee on Natural Resources majority and the Trump 
administration have worked tirelessly to unleash America's 
natural resources and restore our Nation's energy and mineral 
dominance. Doing so has meant not only leading an effort to 
reform burdensome regulations and permitting processes to 
unlock key resources within America's land borders, but also 
looking to other areas like the sea floor of the U.S., the 
Outer Continental Shelf, and the deep, high seas that are rich 
with critical mineral deposits.
    Under former misguided Democratic leadership, the U.S. 
abandoned our ability to explore, extract, and process critical 
minerals that are foundational to nearly all modern 
technologies and amenities. Nothing pleased our foreign 
adversaries like China more than America's surrender to radical 
preservationist NGOs and their foreign-funded donors who waged 
lawfare against sound, multiple-use resource management 
policies.
    Seizing the opportunities left behind by America's absence, 
China has completely dominated global critical mineral supply 
chains. Right now, China controls approximately 60 percent of 
the worldwide critical mineral production, 90 percent of the 
processing, and 75 percent of the manufacturing. This outsized 
global influence has allowed China to cripple America's access 
to critical minerals at a whim.
    Harvesting the minerals found in abundance on the sea 
floor, both in the U.S.-controlled and international waters, 
can significantly help America buck the supply chain yoke 
placed on us by China and reestablish mineral independence. 
Current estimates place a value of up to $16 trillion on sea 
floor critical minerals around the world. Estimates of seabed 
minerals in U.S. waters alone suggest that seabed mining could 
add over $300 billion to America's GDP over the next decade and 
create more than 100,000 jobs. And as our mineral 
identification capabilities increase through additional seabed 
exploration, these estimates are more likely to increase.
    Recognizing this reality, last Thursday, April 24, 
President Trump issued an executive order intended to 
invigorate American seabed mining dominance by accelerating the 
process for reviewing and approving permits for exploration and 
extraction under long-standing U.S. law.
    Unsurprisingly, the very next day the same Chinese 
authorities who have flouted nearly every humanitarian, labor, 
and environmental law on the books in their quest to control 
global mineral mining, including on the sea floor, accused 
President Trump of the United States of violating international 
law and harming the overall interests of the international 
community. Deja vu. This Chinese reaction only highlights that 
President Trump and the Republicans in Congress are charging 
ahead in the right direction.
    I challenge my colleagues in this room to think about the 
widespread economic, energy, technology, and national security 
implications of seabed mining and about our duty to ensure that 
the United States, with its world-best environmental, 
humanitarian, and labor standards, leads the charge to harvest 
sea floor critical minerals. Together we must work to secure 
America's mineral supply chains and champion an all-of-the-
above approach to mineral and energy development.
    Thank you. I now recognize the Ranking Member, Ms. Dexter, 
for her opening statements.

   STATEMENT OF THE HON. MAXINE DEXTER, A REPRESENTATIVE IN 
               CONGRESS FROM THE STATE OF OREGON

    Dr. Dexter. Thank you, Mr. Chair, and thank you to our 
witnesses for joining us today. I appreciate the opportunity to 
educate ourselves on an issue of profound environmental and 
economic consequence: deep-sea mining. It is unfortunate, 
indeed, that our President has already issued an executive 
order on this topic, even knowing that we had this hearing 
forthcoming, showing his disregard for transparency and public 
input.
    Let me be clear from the outset. Deep-sea mining is a high-
risk, low-reward endeavor. It carries grave risks to our oceans 
and communities with no credible evidence of return on 
investment. Supporters of deep-sea mining argue it will meet an 
urgent demand for minerals like cobalt, nickel, copper, and 
manganese, currently essential for electric vehicles and 
renewable energy. But the math simply does not add up.
    The industry's financial models are based on wildly 
optimistic assumptions and fail to reflect the volatility and 
reality of global mineral markets. Between 2016 and 2023, 
electric vehicle production skyrocketed by 2,000 percent. Yet 
over that same period nickel prices only rose 28 percent, 
copper 21 percent, and cobalt prices fell by 10 percent. If 
prices remain stagnant or even dropped during the most 
significant boom in EV production to date, it is a stretch to 
assume prices will spike in the future to support a new, highly 
capital-intensive mining operation in one of the most hostile 
environments on Earth.
    It is important to note that China, the world's largest 
producer of electric vehicles and responsible for 61 percent of 
global rare Earth mineral production, has already moved away 
from using cobalt in EV batteries. If cobalt were truly 
essential to the future of clean energy, they wouldn't be 
leaving it behind.
    We also need to be honest about what is actually in the 
seabed. Polymetallic nodules contain only four commercially 
viable metals. Claims that deep-sea mining will solve supply 
chain needs for rare Earth elements or national security 
critical materials are exaggerated and grossly misleading. 
These minerals are not found in significant quantities on the 
ocean floor, and extracting them from nodules is inefficient 
and environmentally devastating.
    And let's talk about cost. Deep-sea mining is no different 
than other high-risk industrial endeavors. It demands massive 
upfront capital investment. The record shows that two-thirds of 
large-scale industrial extractive projects go over budget, 
often by 50 percent or more. There is no reason to believe 
deep-sea mining will fare any better, especially given the 
extreme challenges of working at depths of 13,000 feet, where 
intense pressure, freezing temperatures, and corrosive 
conditions make operations both technically and financially 
risky.
    We have already seen what this risk looks like in practice. 
The company leading the charge, The Metals Company, projected 
it could extract 12 million tons of material per year. But in 
2022, after a 2-month test, it recovered just 3,000 tons, less 
than 1 percent of its target. That is not a proof of concept; 
it is a red flag.
    And now that these startups are running out of cash, they 
are looking to the Trump administration for a bailout. 
President Trump's executive order to fast-track deep-sea mining 
permits in international waters allows companies like The 
Metals Company to bypass the International Seabed Authority. 
Such a move would violate international law, strain relations 
with Pacific communities, and set a dangerous precedent for 
unilateral exploitation, opening the door for adversaries like 
China and Russia to justify expanding their own maritime 
activities.
    The industry itself seems to recognize the writing is on 
the wall. Major corporations like Google, BMW, Samsung, and 
Volkswagen have pledged not to source minerals from deep sea. 
Financial institutions including Lloyds and Standard Chartered 
are refusing to back deep-sea mining. Even longtime backers 
like Maersk and Lockheed Martin have pulled their support.
    The deep-sea mining industry lacks not just a social 
license to operate, it lacks a business case. Meanwhile, viable 
alternatives are emerging. Battery innovation is reducing the 
need for cobalt and nickel, and investment in recycling the 
circular economy technologies is growing rapidly. By 2050 
nearly half of all cobalt and nickel needs could be met through 
recycling alone.
    We do not need to bulldoze the bottom of the ocean to power 
our clean energy future. The economic argument is a mirage, the 
financial risk is immense, and the consequences to ecosystems, 
to fisheries, to Indigenous communities, and to our global 
climate are too great to ignore.
    I urge my colleagues to reject deep-sea mining as a viable 
path forward, and instead invest in the sustainable, science-
based alternatives that truly support our clean energy and 
conservation goals.
    Thank you, Mr. Chair, I yield back.

    Dr. Gosar. I thank the gentlewoman. I now recognize the 
Full Committee's Ranking Member, Mr. Huffman from California, 
for his 5 minutes.

   STATEMENT OF THE HON. JARED HUFFMAN, A REPRESENTATIVE IN 
             CONGRESS FROM THE STATE OF CALIFORNIA

    Mr. Huffman. Thank you, Mr. Chairman. Mr. Chairman, I think 
we agree on something: this country needs an effective and 
comprehensive strategy to meet our mineral needs to transition 
to a clean energy economy. We might not agree on that last 
part, but we agree on the need for a mineral strategy.
    Unfortunately, that is not what we are talking about here 
today. Deep-sea mining is a dirty, destructive, and unproven 
industry threatening to decimate one of the last untouched 
ecosystems on Earth. And despite what proponents claim, it is 
not the great silver bullet that solves our critical minerals 
problem. It is much more likely that it will create a whole new 
class of problems, especially if it is pursued in the reckless 
cowboy manner reflected in President Trump's imperial edict.
    At its core, deep-sea mining involves deploying massive 
industrial machinery to scrape the ocean floor, sucking up the 
top few inches of sediment and the unique life that resides in 
it in search of metal-rich nodules. That sediment, crushed 
marine life and nodules, are all pumped to the surface where 
the minerals are extracted and the waste is simply dumped back 
in the ocean. On a commercial scale, this would unleash a chain 
reaction of destruction. We can't even fully measure it, let 
alone fully mitigate it.
    What we do know is this: the deep sea plays a crucial role 
in regulating carbon; it is home to an extraordinary wealth of 
biodiversity; and it provides habitat for species that we are 
only now beginning to understand and to discover. A single 
seabed mining operation could affect an area the size of a 
small country. Toxic plumes could travel hundreds, even 
thousands of miles, disrupting entire mid-water food webs, 
including tuna, whales, and other species that support our 
economy.
    And the damage would be permanent. There is one deep-sea 
mining test that shows visible damage and a fourfold decrease 
in foundational microbial activity 26 years after the early 
test run.
    And look, say what you will about land-based mining, but at 
least we can require remediation, cleanup. We can even have 
mining companies sometimes leave parks and other nice things 
when they are done. You can't do that with deep-sea mining. You 
simply wreck it and move on.
    And here is the kicker. For all that destruction, deep-sea 
mining doesn't even pencil out. The industry has very 
questionable market prospects because battery technology is 
rapidly changing. Anyone remember nickel cadmium batteries? 
They are essentially obsolete now. Today EV markets are already 
moving away from the nickel, cobalt, copper, and manganese 
found in deep sea nodules towards other minerals. Folks who 
want to make money on this are skating to where the puck is or 
was, not skating to where the puck is going to be. I will 
mention Tesla, for example, just to make my friends across the 
aisle happy. It already builds half of its EVs without nickel 
and cobalt.
    Part of the poor economic outlook is the sheer engineering 
and technical challenge of this, as well, operating in a harsh 
environment, machinery that has to survive crushing pressures 
three to four miles below the surface, freezing temperatures, 
enduring extreme salinity and corrosion, and somehow you got to 
repair all of that machinery without easy access to 
infrastructure.
    Trials to date have been riddled with failure. No one has 
demonstrated that deep-sea mining can work at scale or even 
turn a profit.
    Making matters worse, deep-sea mining is not an alternative 
to land-based mining, as its supporters claim. There is no 
reason to think any country would scale back land mining, even 
if seabed mining were to defy gravity and become reality. The 
minerals from deep-sea mining are likely to be significantly 
more expensive than those from terrestrial mining so we could 
end up doubling down on environmental harm, getting all the 
land-based mining and wrecking the ocean. That is not progress. 
It is subsidized plunder.
    Fortunately, the global community, including banks, 
insurers, and businesses, are not buying it. Two dozen 
countries have already called for a moratorium, including 
countries where mining exploration has been tried. The Global 
Tuna Alliance and other seafood industry groups have called for 
a halt to deep-sea mining because of the risk that it poses to 
disrupting feeding, breeding, and migration patterns for tuna. 
Indigenous leaders across the Pacific have also raised powerful 
objections. Their spiritual, cultural, and economic connection 
to the ocean is deep and enduring, and mining threatens to 
sever that connection forever.
    Instead of pursuing this reckless fantasy, we should be 
scaling up on solutions we know are effective: battery 
innovation, recycling infrastructure, product redesign, 
building a true circular economy that keeps materials in use 
and ecosystems intact. We have Federal laws, the Inflation 
Reduction Act, and the IIJA, that have started us in that 
direction. Let's work together down that path, instead of 
chasing the folly of deep-sea mining.
    Thank you, Mr. Chairman, I yield back.

    Dr. Gosar. I thank the gentleman from California. We will 
allow the Chairman of the Full Committee to speak when he comes 
in, but now we are going to introduce our witnesses.
    Mr. Gerard Barron, CEO and Chairman of The Metals Company 
and The Metals Company USA, Raleigh, North Carolina; Mr. Oliver 
Gunasekara, did I say it right, Gunasekara?, CEO and Co-
Founder, Impossible Metals, San Jose, California; Mr. Duncan 
Currie, Legal Advisor, Deep Sea Conservation Coalition, 
Christchurch, New Zealand; and Mr. Thomas Peacock, Professor of 
Mechanical Engineering and Director, Environmental Dynamics 
Laboratory, Massachusetts Institute of Technology, Cambridge, 
Massachusetts.
    Let me remind the witness that under Committee Rules, you 
must limit your oral statements to about 5 minutes. You are 
going to see a little timer in front of you. When it goes 
green, you get going. When you start to see yellow, start 
wrapping it up. And when it is red, stop. OK? There are going 
to be a lot of questions coming your way this day.
    I have the pleasure to see your full statement when we are 
done. So after that, I now recognize Mr. Barron for his first 5 
minutes.

   STATEMENT OF GERARD BARRON, CEO AND CHAIRMAN, THE METALS 
                COMPANY, RALEIGH, NORTH CAROLINA

    Mr. Barron. Committee Chairman Westerman, Ranking Member 
Huffman, Subcommittee Chairman Gosar, Ranking Member Dexter, 
and distinguished members of the Committee, thank you for the 
opportunity to share my views on the potential of deep-sea 
mining to American critical mineral production.
    And as a veteran of the deep sea minerals industry and the 
Chairman and CEO of The Metals Company, I can say with 
certainty that this industry is at an inflection point where 
America can take the lead. I intend to make this case across 
three key points.
    First, America's mineral dependence is reversible. And from 
the 1880s to the 1970s, America was a mining and processing 
powerhouse. And since domestic production sank, leaving America 
dangerously dependent on adversaries. And we can change this 
without sacrificing American landscapes or communities.
    Four days' sailing from San Diego lies the Clarion-
Clipperton Zone, where polymetallic nodules sit 2.5 miles deep 
on the sea floor. And they are rich in nickel and cobalt and 
manganese and copper. And these nodules hold more of these four 
minerals than all known land-based reserves combined. And just 
1 billion tons of the 21 billion tons of nodules in the CCZ 
could supply over 450 years of the United States manganese 
needs, 150 years of cobalt needs, and 80 years of nickel needs. 
Developed over 20 years, a billion tons could create more than 
100,000 jobs, generate $300 billion in GDP, and revitalize 
shipyards, offshore industries, and manufacturing.
    And second, the U.S. pioneered this industry, the 
technology, and the robust regulations. And over 60 years ago, 
American consortia successfully developed and tested nodule 
mining technologies, and they developed U.S. regulations that 
spanned five administrations. And NOAA led the world in deep-
sea mining mineral governance, building a full framework 
pioneering environmental science through the deep ocean mining 
environmental study, and delivering a decade of rigorous impact 
studies and reports to Congress. It set the global standard for 
responsible seabed development long before international 
negotiations began. And by 1989, America had a regulatory 
regime for seabed mining that was environmentally responsible, 
commercially viable, and consistent with international law.
    And the same cannot be said for the efforts at the United 
Nations, where a 1982 Law of the Sea Treaty's seabed mining 
provisions were so unworkable that industrialized nations, 
including the United States, refused to ratify it and still 
have not.
    And after finalizing exploration regulations in 2000, the 
ISA took 14 years just to begin drafting a mining code, and has 
missed adoption deadlines in 2020, 2023, and likely again in 
2025. This is not incompetence; this is a deliberate strategy 
by activists, land mining nations, and green coalition 
governments to stall by any means necessary. Meanwhile, China 
has become the largest holder of ISA mineral rights, pushing 
draft regulations that ban U.S.-flagged vessels and ports while 
favoring state-backed enterprises. And while TMC and western 
explorers lead offshore technology, China is close behind. And 
with its dominance in land-based processing, it is clear why 
deep-sea mining is one of China's core resource strategies.
    And third, the real-world data has debunked every major 
activist claim against deep sea nodule collection. Onshore the 
benefits are clear: 100 percent of the nodule is used, with 
near zero solid waste, no toxic tailings, and far lower life 
cycle impacts than land-based mining. Offshore the facts are 
just as strong, and I direct the Committee to my written 
submission for a detailed rebuttal of the common environmental 
myths used to confuse the public.
    And in closing, with seabed minerals America can end 
critical mineral dependence; reclaim leadership in offshore 
innovation; inspire generations of American engineers, 
scientists, and mariners; and create over 100,000 American jobs 
and generate hundreds of billions in GDP. And as evidenced by 
President Trump's executive order signed last week, this 
Administration recognizes the ability for seabed mineral 
resources to expand American mineral production and ensure the 
Nation's energy security and industrial competitiveness for 
generations.
    Thank you for your attention and your commitment to 
securing America's mineral future.
    [The prepared statement of Mr. Barron follows:]
Prepared Statement of Gerard Barron, Chairman & CEO, The Metals Company

    Committee Chairman Westerman, Ranking Member Huffman, Subcommittee 
Chairman Gosar, Ranking Member Dexter, and distinguished Members of the 
Committee, thank you for the opportunity to share my views on the 
potential of deep-sea mining to expand American production. Deep-sea 
mining in the high seas is an industry that has been sixty years in the 
making and is now at an inflection point where it can enable America, 
the original pioneer of this industry, to reclaim its leadership of the 
industry and transform its dangerous mineral dependence on foreign 
adversaries into dominance in a matter of years. My views have been 
shaped by 25 years of experience in deep-sea minerals, with the last 7 
years as Chairman & CEO of The Metals Company, a Nasdaq--listed 
explorer of polymetallic nodules in the East Pacific Ocean off the 
western seaboard of the United States.
    To appreciate the potential of this industry, the maturity of the 
regulatory regime and the state of knowledge about its risks, we must 
rise above the noise of campaign slogans that are disconnected from 
history, disconnected from the reality of terrestrial mines and 
processing plants and disinterested in the trade-offs involved in the 
making of the physical world around us. This testimony is structured 
around five key messages:

    1. America's mineral dependence is reversible.
    2. America is reclaiming leadership of the industry it pioneered.
    3. America's foresight to invest in the national regulatory regime 
and not surrender decision-making powers to an intergovernmental 
organization are a competitive advantage.
    4. Better resource and better technology produce better metals.
    5. Real-world data dispels every catastrophizing claim made by 
environmental activists.
1. America's mineral dependence is reversible.
    U.S. Faces Critical Mineral Crisis as China Dominates Global Supply 
Chain. China's Halt of Critical Minerals Poses Risk to U.S. Tech and 
Defense Industries. U.S. Faces Uphill Battle to Secure Critical 
Minerals Supply Chains Amid Global Tensions.
    Against the backdrop of alarming headlines, it may be hard to 
recall that once upon a time--starting in the 1880s and until 1970--the 
United States was a mining and processing powerhouse, supplying Europe, 
Asia and Latin America with many base metals including copper, lead, 
zinc, aluminum and nickel. The U.S. had a positive trade balance for 
base metals from 1896 to 1970 (USGS 2016; Northrup 2003).
    Since then, domestic production of base metals has declined 
significantly, leaving the United States with a persistent deficit and 
dangerous dependence on foreign adversaries. We can change this. Having 
invested the last 14 years in the exploration and development of deep 
seabed mineral resources off the western seaboard of the United States, 
I believe it is possible to make America a mining and processing 
powerhouse again. It is possible to reverse mineral dependence and even 
establish dominance in critical minerals like nickel, cobalt and 
manganese. It is possible to accomplish this without asking people to 
give up their land, sacrifice their way of life or allow their 
remaining natural landscapes to be defaced. It is possible without 
asking anyone in the United States to accept a mine into their backyard 
or asking people in a developing country on a different continent to do 
so.
    It takes about 4-5 days of sailing from San Diego to reach the vast 
fields of polymetallic nodules sitting on the abyssal seafloor at over 
2.5 miles depths in the area known as the Clarion-Clipperton Zone 
(CCZ). All four base metals contained in these nodules--nickel, cobalt, 
copper and manganese--are on the United States critical minerals and 
materials lists. No comparable terrestrial resource exists and it would 
take three separate mines to produce this combination of base metals on 
land. The CCZ is estimated to host over 20 billion tonnes of nodules 
containing more nickel, cobalt and manganese than all terrestrial 
reserves combined (Morgan 1999, ISA 2010). This resource can offer 
mineral security for many generations. To give you a sense of scale--at 
current levels of American consumption--a one-billion-tonne nodule 
resource contains 450+ years of manganese, 150+ years of cobalt and 80+ 
years of nickel (USGS 2024).
    If a one-billion-tonne resource were developed over 20 years, it 
could generate an order of magnitude of 100,000+ jobs and $300+ billion 
in GDP (TMC 2024). Imagine revitalized shipyards building and repairing 
a fleet of U.S. flagged production, survey, supply and transport 
vessels. Imagine a new generation of American mariners, offshore 
production engineers and operators as well as deep-sea scientists. 
Imagine a new era in offshore innovation in survey, monitoring and 
production technology--even nuclear-powered production vessels. Cast 
your eyes back to shore and imagine new deep-water terminals and new 
nodule processing and refining industry producing feedstocks for 
domestic manufacturing of steel and special alloys, battery precursors 
and battery cells. No more need for nickel, manganese and cobalt 
imports. Imagine reversing the trade balance and exporting manganese 
alloys, steel and battery-powered goods to the rest of the world.
    This type of transformation is not unprecedented. At the start of 
the 20th century, as oil explorers were venturing into the shallow 
water, few could imagine that one day 30% of American oil production 
would come from offshore--yet by 2010 it was a simple fact of life (EIA 
2011). I believe 100% of American demand for manganese, nickel and 
cobalt and some copper could come from offshore. We will not need to 
wait a century: offshore production could start within two years and 
ramp up within a decade.
2. America is reclaiming leadership of the industry it pioneered.
    The Brits may have discovered polymetallic nodules in the CCZ some 
150 years ago, but it was an American geologist, John Mero, who in the 
1960s imagined turning vast fields of polymetallic nodules into a new 
source of base metals for the United States (Mero 1965). It was US-
based consortia who successfully tested nodule mining technology in the 
1970s (NOAA 1981a). These were the times when the United States could 
put a man on the moon and build technology to recover polymetallic 
nodules from the abyss in the middle of the Pacific Ocean.
    Alongside pioneers of industry, the National Oceanic and 
Atmospheric Administration (NOAA) was a pioneer in its own right. Under 
its Deep Ocean Mining Environmental Studies (DOMES) program running 
from 1975 to 1981, NOAA completed several environmental research 
cruises and developed a Programmatic Environmental Impact Statement 
(PEIS) for the DOMES area that included the CCZ. 25 people across 
government agencies and universities were listed as preparers of this 
impressive 300+page volume that was shared widely--with key Senate and 
House Committees, 40 federal departments and agencies, 10 states, 9 
embassies of foreign countries, 57 special interest groups and 359 
individuals. The development of this volume was a public affair with 28 
public meetings and workshops held over a period of 6 years and 
involving Federal and State government, academia, environmental and 
public groups, industry and private individuals (NOAA 1981a).
    NOAA also produced a Technical Guidance Document to inform nodule 
explorers' efforts to collect environmental information for site-
specific EISs (NOAA 1981b) and went to develop the total of five such 
site specific EISs as part of its process to grant exploration licenses 
(NOAA 1984abcd, 1994). Starting in 1981 and until 1995, NOAA has been 
regularly reporting on Deep Seabed Mining to Congress, producing the 
total of 7 reports. In its last report in 1995, NOAA stated that in the 
1990s its environmental research efforts had focused on determining the 
biological effects of the increased sedimentation on the seafloor 
(i.e., seafloor plumes) that would result from deep seabed mining 
operations. NOAA's 1975-80 DOMES Project had basically eliminated 
virtually all other environmental concerns which were raised about deep 
seabed mining, pending verification during monitoring of further at-sea 
mining system tests. To address the issue of seafloor plumes, NOAA 
developed a Benthic Impact Experiment program and, after an initially 
less successful device, commissioned an American company Sound Ocean 
Systems Inc (now Okeanus) to build a better machine to simulate benthic 
disturbance. The machine came to be known as the Disturber 2.0, and as 
the name suggests was designed to maximize sediment disturbance to 
study worst case scenarios. It was used not just by NOAA but was 
borrowed--along with the NOAA team for consistency of use--by several 
other governments around the world including Japan, India and a group 
of Eastern European countries to conduct disturbance experiments of 
their own (NOAA 1995).
    The question that loomed large from the beginning of these efforts 
was who should regulate the exploration and commercial recovery of 
seabed minerals in international waters.
3. America's foresight to invest in the national regulatory regime and 
        not surrender decision-making powers to an intergovernmental 
        organization are a competitive advantage.
    Efforts to regulate the sea go back centuries, with the 17th-
century concept of ``freedom of the seas'' by Hugo Grotius (Grotius 
1609) and early 20th-century attempts by the League of Nations (Hudson 
1930). The United Nations turned its focus to regulating seabed 
minerals in 1967 when the UN General Assembly established the Committee 
on the Peaceful Uses of the Seabed and the Ocean Floor beyond the 
Limits of National Jurisdiction (Seabed Committee; UNGA 1967). The 
committee laid the groundwork for UNCLOS III, which officially started 
its first session in New York in December 1973. The U.S. was an active 
participant and leader in those negotiations from the beginning. This 
process has been going on for so long, most diplomats who worked on 
this issue back then are long since retired or no longer living.
    As U.S.-based consortia successfully completed their mining tests 
and NOAA made great progress on their environmental impact assessment, 
the U.S. Congress passed the Deep Seabed Hard Minerals Resources Act in 
1980 (DSHMRA). Originally intended as an interim measure in 
anticipation of the eventual international regime that would be 
ratified and come into effect with regard to the United States, the Act 
created a legal framework to enable U.S. citizens to explore and 
recover seabed minerals in the high seas and authorized NOAA to develop 
implementing regulations. NOAA delivered implementing regulations for 
exploration licenses in 1981 (NOAA 1981c) and proceeded to issue four 
exploration licenses, known as USA-1, USA-2, USA-3 and USA-4. NOAA then 
invested over six years in the development of implementing regulations 
for commercial recovery permits, with multiple iterations and several 
rounds of public hearings and comments. Final regulations came into 
force in 1989 (NOAA 1989). Under the authority vested with NOAA under 
DSHMRA, NOAA kept delivering its bi-annual reports to Congress on Deep 
Seabed Mining until 1995. These U.S. regulatory developments between 
1975-1995 spanned five different administrations--three Republican 
(Ford, Reagan and Bush) and two Democratic (Carter and Clinton). It is 
worth remembering that the 1970s was the decade of hallmark statutes on 
environmental protection: the National Environmental Policy Act of 
1970, Clean Water Act of 1972, Marine Mammal Protection Act of 1972, 
Endangered Species Act of 1973 and Magnuson Fishery Conservation and 
Management Act of 1976 were all explicitly referenced in DSHMRA and 
implementing regulations. By 1989, America had developed a robust 
regulatory regime for deep-seabed mining in the high seas that was 
fully consistent with international law, commercially viable, and 
environmentally responsible.
    The same could not be said about the parallel efforts at the United 
Nations. The UNCLOS III conference culminated in the adoption of the 
UNCLOS treaty on April 30, 1982, where Part XI dealing with seabed 
mining and establishing an intergovernmental regulator the 
International Seabed Authority (ISA) was so unworkable that several 
industrialized nations refused to sign or ratify the convention. The 
United States, under President Reagan, led the opposition including 
countries like the United Kingdom, Italy and West Germany--objecting to 
anti-competitive and restrictive provisions including production 
controls and mandatory transfers of technology. An effort to cajole 
industrialized nations into ratifying UNCLOS took another 12 years and 
a new implementing agreement modifying the contents of Part XI of 
UNCLOS--including changing the structure of the ISA and removing 
mandatory technology transfers--was agreed in 1994. The Democrat 
administration at the time was of the view that the 1994 Agreement 
could potentially meet the objections to the treaty outlined by 
President Reagan in 1982 and might therefore provide a basis for the 
United States to join the treaty. Most of those on the other side of 
the aisle did not have such confidence. Despite President Clinton 
signing this agreement, U.S. Senate voted against the ratification of 
UNCLOS and the 1994 agreement due to several concerns that could be 
generalized to unwillingness to surrender U.S. sovereign power to 
global bureaucrats. In its 1995 report to Congress, NOAA reported that 
investment from the U.S.-based consortia had dropped partly because of 
the regulatory uncertainty posed by the prospect of the U.S. 
ratification of UNCLOS and the 1994 Implementation Agreement. NOAA also 
stated that ``while the specific concerns among the licensees 
differ[ed] somewhat, the licensees essentially viewed the new regime as 
presenting economic and political risks that they do not face under 
[DSHMRA].''
    The ISA started in earnest in 1996 and adopted its exploration 
regulations for polymetallic nodules in 2000 (ISA 2013). These were 
largely based on equivalent provisions under DSHMRA and NOAA 
implementing regulations since, until 1997, the U.S., as a provisional 
member of the ISA, had a presence and influence on the development of 
the regulations. ISA did not start working on the exploitation 
regulations until 2014 when Fiji raised the issue (ISA 2014). Having 
been an active participant in the ISA proceedings in Kingston, Jamaica 
since 2009, I can report that the reservations expressed by the Senate 
and the original American licensees have unfortunately proven to be 
valid. As a company, we were committed to the grand vision of a 
regulatory regime that would set a new international benchmark for 
regulating seabed activities and protecting the marine environment 
while making sure that developing nations benefit from the development 
of seabed minerals. What we learned over the years is that a consensus-
driven multi-lateral organization is not a construct that can produce a 
viable mining code or act as a regulator. If a committee entrusted with 
the task of designing a horse could at least be expected to produce a 
camel, an intergovernmental committee can only produce years of 
workshops, formal meetings, informal meetings and informal informals 
(sic!) but no final regulations. Despite taking the fully developed 
NOAA regulations as their starting point, the ISA failed to deliver on 
its goal to adopt the final mining code in 2020, 2023 and will almost 
certainly fail again in 2025. Lockheed Martin, a U.S. exploration 
licensee who hedged their bets by securing the ISA contracts under the 
UK sponsorship, saw the writing on the wall several years before me 
when they distributed a memorandum to ISA delegates in Kingston stating 
that unless real progress was made on the mining code, Lockheed would 
exit the industry. They were out in March 2023 (Reuters 2023).
    It would be easy to jump to the conclusion that the ISA's 
indefinite drift is a function of incompetence. It is not. Delay, 
delay, delay is a strategy--a deliberate, self-proclaimed ``Fabian 
military strategy'' adopted by the environmental activists who allied 
themselves with countries that have significant domestic land mining 
interests and/or the greens in their coalition governments (Vescovo 
2022). Their tactics to wear down the industry proponents and scare 
Member States focused on delivering on the ISA mandate would make the 
Roman general Quintus Fabius Maximus Verrucosus proud: they include 
catastrophizing claims, demonizing of key players (including the ISA 
itself), relentless harrassment of all industry stakeholders and 
systematic disruption of all industry events (including a ``mostly 
peaceful'' and ``completely safe'' at-sea disruption of an 
environmental research campaign by Greenpeace). While effective in 
destroying commercial industry, these tactics are no match for China 
whose five ISA exploration contracts make it the largest holder of 
seabed mineral rights and who has been arguing for positions that would 
eventually make the mining code work for its State-Owned Enterprises--
and no private companies. Indeed, the current ISA draft exploitation 
regulations take us right back to 1982: they reflect an over-
bureaucratic, statist, anti-competitive approach to seabed mining; one 
in which private enterprise is penalized and the exercise of sovereign 
rights by nation states is subjected to scrutiny by an international 
body dominated by countries that do not share the values of the United 
States. Having balked at this approach in 1982, President Reagan would 
have been even more shocked by the state of affairs in 2025.
    The United States have participated in the ISA proceedings as an 
Observer since the beginning of this would-be-regulator but have not 
been able to undo draft regulations detrimental to U.S. interests 
(e.g., draft regulations that prohibit the use of U.S. ports or U.S. 
flagged vessels which would make transporting CCZ nodules directly to 
America for processing impossible). There have been four distinct 
attempts (1994, 2004, 2007, 2012) where UNCLOS ratification was 
seriously considered by the Senate or its committees but failed to 
reach a full floor vote. Despite continued advocacy (resolutions in 
2018, 2021, 2023), there have been no formal ratification attempts in 
years. I have come to view this as the competitive advantage of the 
United States--deep seabed mining is a freedom of the high seas and 
America already has a robust regulatory regime to regulate U.S. 
citizens willing to pursue it. America now also has the President 
willing to put this regime to good use (Trump 2025).
4. Better resource and better technology produce better metals.
    Resource, resource, resource--it all starts with the quality of the 
resource. It is well understood in the mining world, that no amount of 
operational innovation and excellence can fix your mining project if 
your starting point is a low-grade resource with toxic levels of 
deleterious elements. The many advantages of the CCZ polymetallic 
nodule resource were obvious not only to industry but to NOAA already 
back in 1981 (NOAA 1981a). The resource is abundant and high-grade--
1.4% nickel, 1.1% copper, 0.2% cobalt and 29% manganese--or over 3% in 
nickel equivalent compared to the average grade of terrestrial nickel 
deposits that are now trending at half that. CCZ nodules do not contain 
toxic levels of deleterious elements which makes it possible to turn 
all of nodule mass into products (TMC 2021).
    In its 1981 PEIS for the DOMES area, NOAA compared the 
environmental impacts of nodule mining to land mining and arrived at 
the conclusion that ``impacts due to land mining would be substantially 
reduced.'' We have come a long way since then, both in offshore mining 
and onshore processing technology. Robot miners tested in the 1970s 
sank into the sediment, leaving behind 50-80 cm-deep tracks in the 
seafloor (Jones 2025). With better buoyancy and precision hydraulic 
nodule pickup, our robot miner tested in 2022 only entrains just the 
top 3 cm of sediment, dramatically reducing the scale of disturbance. 
In the 1970s, it was difficult to measure exactly how much seafloor mud 
(``sediment'') was suspended by the robots during mining and sediment 
that made it to the mining vessel along with nodules, was separated and 
discharged at the surface. Today, we have several methods to measure 
how much sediment we disturb; more than 90% of entrained sediment is 
separated inside our machines and discharged back to the seafloor in a 
tight footprint due to better discharge head design that maximizes the 
natural tendency of the plume particles to stick together 
(``flocculate'') and create a gravity-current that resettles within 
hours to days. The amount of sediment that is lifted to the surface is 
limited (<8% of total entrained mass) and it is no longer discharged at 
the surface but returned at 2,000 meters-depth (``midwater plume'') 
where any returned sediment does not interact with the food webs of 
fisheries (TMC 2025).
    When it comes to onshore operations, we can now deliver a quiet 
revolution. Back in 1981, as U.S.-based consortia were in the early 
stages of developing and testing various nodule processing flowsheets, 
NOAA contemplated a situation where only three metals would be produced 
with waste streams containing manganese stockpiled for potential future 
use. While many mineral processing operations today extract as little 
as a few kilograms of metal from 1,000 kilograms of ore and spend 
considerable effort on managing massive waste streams and toxic 
tailings, we have been able to extract all four metals and productize 
all of nodule mass, leaving almost no solid waste for us to manage (TMC 
2021).
    Multiple academic and commercial studies have been published 
assessing the lifecycle impacts of modern nodule mining, processing and 
refining operations and comparing them to conventional production 
routes. NOAA's conclusion stands--impacts are considerably lower (TMC--
lifecycle 2025).
5. Real-world data dispels every catastrophizing claim made by 
        environmental activists.
    We know more about the moon than the deep sea. The first written 
record of this argument goes back to 1954 (Deacon 1954). For over 
seventy years, it's been consistently repeated by oceanographers and 
deep-sea biologists looking for research funding and by environmental 
activists looking to delay deep seabed mining. There have been 300 
offshore research campaigns focused on deep-sea minerals in the high 
seas, including at least 10 mining tests and 5 benthic impact 
experiments; almost 150,000 research papers have been published on 
polymetallic nodules. Yet, according to the anti-deep-sea-mining (anti-
DSM) campaign, we still don't know enough and we are also unlikely to 
arrive at this sufficient-knowledge-nirvana in the foreseeable future.

    As a CEO of a company that over the last 14 years has:

    --Invested over $600M in polymetallic nodule exploration and 
development;
    --Completed 22 successful offshore environmental research campaigns 
together with 20+ of the world's leading deep-sea research institutions 
and contractors;
    --Together with our partner Allseas, delivered the first successful 
pilot of integrated nodule collection technology since the 1970s while 
closely monitoring its environmental impacts with our research 
partners;
    --Together with our partners in the United States, Canada and 
Japan, completed bench, pilot and industrial scale processing pilots 
and smaller scale refining tests;
    --Amassed over a petabyte of environmental data (more than all 
other deep-sea minerals explorers combined and starting to get closer 
to the likes of the Library of Congress who manages over 20 petabytes 
of digital data . . . )

    As the CEO of that company, I can tell you with some pride and 
confidence that we know enough to get started. We know enough to 
understand the environmental risks and how to manage them. We also have 
enough real-world data to take on every catastrophizing claim made by 
environmental NGOs against the polymetallic nodule industry in the CCZ. 
And that is saying something as over the last 5 years, as the anti-DSM 
campaign ramped up to stop this industry before it begins, we have seen 
a Cambrian explosion in claims, with pressure groups like Greenpeace 
deploying considerable creativity to scare policy makers and the 
public. Picking nodules from the abyssal seafloor has been rumored to:

    --Strip-mine the oceans triggering catastrophic biodiversity loss 
in animals not known to science;
    --Turn pristine deep-sea ``rainforests'' into wasteland that will 
never recover or will take millions of years to do so;
    --Generate clouds of seafloor mud (``seafloor plumes'') that will 
travel for thousands of kilometers, smothering all filter-feeding 
animals in their path;
    --Generate midwater plumes that will also travel for thousands of 
kilometers, forcing tuna to have toxic sediment for breakfast and 
eventually end up as toxic--metal laden tuna meals on your plate;
    --Generate noise levels that will destroy marine mammals across the 
vast expanses of the Pacific Ocean;
    --Make climate change worse by disrupting the planet's largest 
carbon sink;
    --Poison marine life and humans with radioactivity;
    --End nodule production of dark oxygen, a newly imagined source of 
oxygen that may or may not be responsible for the origin of life on 
Earth and possibly other planets;
    --Be the single worst thing to ever happen to our stressed oceans;
    --And, to top it off, violate sacred ocean spaces that are central 
to Pacific Indigenous cosmologies and cultural heritage.

    At this point, I think nothing would surprise me. What could 
however surprise members of the esteemed Committee who may have been 
exposed to the controversial coverage of deep-sea mining in the media, 
is what we know with a reasonably high level of confidence because we 
have decades of research, field tests and validated models to support 
these statements:

    --Scale: the entire area currently under exploration in the CCZ 
accounts for 0.3% of the global oceans. There is more area under 
protection than under exploration. If even half of the exploration area 
were to be developed over 30 years, the resulting annual footprint 
would be less than 10,000 square miles. For comparison, trawling is 
estimated to impact around 2,000,000 square miles every year.
    --Environment: Contrary to the creative illustrations and 
misleading images of coral reefs often accompanying deep-sea mining 
articles, the best terrestrial comparison for the abyssal seafloor is 
not a rainforest but a desert. There are no plants. The living biomass 
is measured in 10s of grams per square meter, not 15,000-30,000 grams 
measured in the rainforests. Non-microbial species richness in measured 
in 1,000s, not millions like in the rainforests.
    --Biodiversity loss: We expect to leave half the nodules unpicked 
in our areas, leaving plenty of habitat for animals who need nodule 
surfaces to live. That's in addition to all the areas that have been 
set aside for protection.
    --Seafloor plume: Will not travel for 1,000s of kilometers. 95% of 
disturbed sediment resettles within 1 kilometer of origin within hours 
to days.
    --Midwater plume: Will also not travel for 1,000s of kilometers. 
The midwater plume takes the form of a pancake that rapidly dilutes to 
the range of natural background variation within kilometers 
horizontally and within 10s-100s of meters vertically. The cut-off 
selected for mid-water plume modelling is the upper limit of natural 
range of Total Suspended Solids (TSS) variation of 0.07 mg/l or more 
than 7,000 times more conservative than the permissible TSS in drinking 
water as per U.S. guidelines of 500 mg/l. Dissolved metals from the 
midwater plume dilute to background levels within 1.5 km of discharge. 
Any bioaccumulation in tuna fisheries is highly unlikely due to 
discharge at 2,000 m depths where the physical interaction between the 
plume and the food web of fish stocks is limited. Both tuna's 
breakfasts and yours are safe.
    --Noise: The loudest source of noise in our operations is the 
surface production vessel. Using behavioral thresholds from NOAA, our 
operations will generate noise that can impact the behavior of marine 
mammals within a 3.8 km radius from the production vessel. This is 
typical of drill ships used around the world. We will have observers 
onboard to spot mammals and halt operations if necessary.
    --Climate change: While the oceans are our planet's largest carbon 
sink, most carbon is dissolved in water. Deep-sea sediments in the 
abyssal plains and rises are so carbon poor that they store less than 
0.1% of total oceanic carbon despite covering almost 90% of the 
seafloor area. With our current technology, we would not be able to 
make climate change worse even if we tried.
    --Recovery: When a UK-funded research campaign revisited the 1979 
mining site of one of the U.S.-based consortia (then OMCO, now Lockheed 
Martin) 44 years later, they returned with plenty of good news: plumes 
had ``no detectable or slightly positive biological impacts;'' full 
recovery of sediment macrofauna and foraminifera in the tracks and 
areas covered by plumes; the return of structural complexity to the 
ecosystem; and megafauna attached to the nodules that were left behind 
(Jones 2025). When my team revisited our own 2022 mining test site just 
a year after, we could already measure material recovery. We expect 
better technology will lead to faster recovery.
    --Radioactivity: Nodules are less radioactive than the granite in 
the walls of the Capitol building. Basic PPE (Protective Personal 
Equipment like gloves and masks), good ventilation of nodule storage 
spaces and resisting the temptation to swallow a nodule is what it 
takes to address any health concerns of human workers.
    --Dark oxygen: Landers that measure oxygen fluxes at the seafloor 
are finnicky devices. The most likely explanation for the errant oxygen 
measurements that contradict over a decade of consistent measurements 
of oxygen consumption in CCZ nodule fields is poor protocol in 
deploying these devices. The paper that posited the controversial 
hypothesis that CCZ nodules produce ``dark oxygen'' has so far 
attracted an unprecedented five rebuttals.
    --Cultural heritage: We have commissioned cultural heritage 
specialists to carry out detailed baseline studies of both tangible and 
intangible cultural heritage (TCH/ICH)--the first ever for a deep-sea 
minerals project in international waters, consistent with international 
good practice (such as the International Finance Corporation's 
Performance Standards). Some have suggested that our exploration area 
is part of the sacred deep-sea creation space and should be considered 
critical cultural heritage. Baseline research, however, did not 
identify evidence to support this claim. While some perspectives hold 
that the deep sea as a whole is sacred, we understand this to reflect a 
broader cosmological worldview rather than a documented instance of 
traditional use as defined under IFC standards.
    I do not want to leave you with the impression that picking up 
nodules from the abyss in the CCZ is an environmental free lunch. The 
activity has measurable negative impacts on the receiving environment. 
But we have gone to great lengths to improve our nodule collection 
technology and should we be allowed to proceed, plan to monitor the 
impacts closely and adapt our operations to minimize our impacts 
further.

                               * * * * *

    In closing, I would like to impress on you that the potential in 
front of us is not to merely expand American mineral production.
    --The potential in front of us is to eliminate American dependence 
on foreign sources of supply for three critical minerals--nickel, 
cobalt and manganese--and expand domestic production of copper.
    --The potential in front of us is to turn the United States into 
the world's leading exporter of manganese, be it as alloy or steel or 
any of the downstream products the world needs and America is willing 
to manufacture.
    --The potential in front of us is to put American regulatory 
advantage to good use and demonstrate to the world that America still 
has what it takes to venture into the new frontiers with eyes wide open 
and putting the lessons learned from regulating extractive industries 
of the past to good use.
    --The potential in front of us is to re-energize American deep-sea 
scientific community and inspire a new generation of oceanographers and 
marine biologists to join the offshore environmental exploration, 
management and monitoring programs.
    --The potential in front of us is to reshore the long-lost mineral 
processing and refining industry and, with the help of American allies 
like Japan and South Korea, bring back the cleaner, safer and more 
automated version of that industry and keep using that infrastructure 
for recycling the same metals for generations to come, eventually 
ramping down offshore production as we build out our recyclable metal 
stocks.
    --The potential in front of us is to create 100,000+ American jobs 
and $300B+ in GDP.
    As evidenced by President Trump's Executive Order Unleashing 
America's Offshore Critical Minerals and Resources signed on April 24, 
2025, this administration recognizes the historic opportunity before us 
and will not to let this potential go to waste.
[GRAPHICS NOT AVAILABLE IN TIFF FORMAT]
                                 
    Questions Submitted for the Record by the Hon. Maxine Dexter to 
                           Mr. Gerard Barron

Mr. Gerard Barron did not submit responses to the Committee by the 
appropriate deadline for inclusion in the printed record.

    Question 1. Will NORI apply to the International Seabed Authority 
(ISA) for an exploitation plan of work on June 27 as originally stated, 
or at all?

    Question 2. You have described the International Seabed Authority 
as acting in bad faith, in ``indefinite drift'', in breach of their 
obligations under UNCLOS, and said ``commercial industry is not welcome 
at the ISA.'' \1\ Will The Metals Company (TMC), through its subsidiary 
NORI, continue to hold and as necessary extend exploration contracts 
with the ISA? Or will NORI cancel its contracts with Nauru and the ISA? 
If the latter, what are the repercussions for NORI breaking its 
contracts with Nauru and the ISA?

    \1\ https://metals.co/ceo-statement-on-isa-and-usa/
---------------------------------------------------------------------------
    Question 3. Given the recent peer-reviewed findings that thousands 
of species new to science depend on nodule ecosystems, how does TMC 
justify disturbing these habitats irreversibly?

    Question 4. Do you accept that the deep seabed is the common 
heritage of humankind?

    Question 5. Do you believe that if the United States unilaterally 
approves deep-sea mining in the Area, it may lead to an unregulated 
free-for-all in the deep sea? If not, why not?

    Question 6. Is applying through NOAA a backdoor attempt to claim 
legitimacy in U.S. waters without proper Congressional or international 
mandate?

    Question 7. Does TMC's rush to start deep sea mining commercially 
undermine the very idea of a fair, precautionary, and science-based 
process that the international community is trying to build?

    Question 8. I want to understand the implications for Nauru of 
TMC's subsidiary making an application to NOAA. Have NORI or TMC 
obtained their approval to do so? Will Nauru benefit financially from 
any prospective mining under approval by NOAA?

    Question 9. Can you provide details about the geographical areas 
and site coordinates that TMC USA has applied for, and clarify whether 
these are the same contract areas that TMC subsidiaries hold ISA 
contracts for? Specifically, do these areas overlap or coincide with 
the NORI D contract area, or the contract area held by TOML?

    Question 10. In your written testimony, you assert that seabed 
mining will ``create 100,000+ American jobs and $300B+ in GDP''. Please 
substantiate this claim with detailed projections.

    Question 11. If the technology proposed by Impossible Metals is 
proven at scale, they argue it will offer a less damaging option to 
mine the seafloor than TMC's proposed methodology. How would that 
impact TMC's economic case and social license?

    Question 12. DeepGreen, now known as The Metals Company, reportedly 
met with Chinese companies and has offered to partner with them. Please 
describe in detail any existing relationships or partnerships The 
Metals Company has with Chinese companies and the Chinese government.

    Question 13. During the hearing, you stated that the impacts on 
tuna were well studied and not a concern. Can you substantiate this 
claim with peer reviewed, published, scientific articles that address 
the migration of tuna due to climate change, the potential uptake of 
metals-bioavailable or not-by marine life like tuna, and the potential 
for long-term impacts on various tuna populations due to full scale 
mining, not just one collector test? If damage to the tuna fishing 
industry were to occur, will you commit to paying damages for the loss?

    Question 14. Allseas is widely known to own the Hidden Gem, the 
surface vessel, the collectors, and risers for deep sea mining. As 
Allseas is hosted in Switzerland, and has a substantial presence in the 
Netherlands, on what basis do you consider that those countries would 
permit Allseas to carry out the mining activity which would constitute 
a breach of the United Nations Convention on the Law of the Sea?

    Question 15. If you were to receive approval for a permit today, 
what is your estimate of how long it would be before you would be able 
to commence exploration activities?

    Question 16. You argue that it's in the national security interest 
of the United States to develop processing capabilities in the United 
States, which is reflected in President Trump's recent Executive Order.

    16a) How many processing plants would need to be built in the 
United States to process the minerals you expect to be harvested from 
the seabed?

    16b) What is the cost of building one of these processing plants?

    16c) Who will fund the processing plants?

    16d) What is the timeline for building one of these plants?

    16e) According to recent analysis, these processing plants will 
need special retrofitting to be able to most effectively process 
minerals from polymetallic nodules. Does the United States have the 
technical knowledge or workforce to do that?

    16f) Where will you sell your nodules/minerals before theoretical 
U.S. processing plans come online?

    Question 17. Please explain why you an seeking subsidies from U.S. 
taxpayers if your mining ventures are projected to be as inexpensive 
and profitable as you claim.

    Question 18. How can you assure taxpayers that if they subsidize 
TMC you would not leave them with significant debt, as your former 
company did in Papua New Guinea? What guarantees would you put in place 
to ensure that does not happen?

    Question 19. Why do you think other countries and contractors would 
not start mining in the same area as you as soon as the U.S. sets a 
precedent of unilateral authorization?

    Question 20. Do you expect the U.S. government to defend your 
operations in the high seas against other countries' claims/operations 
in the same areas?

    Question 21. How will you ensure that the minerals and metals 
coming from your process will not go to Chinese or Chinese-operated or 
controlled processing plants? How will you differentiate them from 
those that are processed in China/ by Chinese-controlled or operated 
processing plants?

                                 ______
                                 

    Dr. Gosar. Thank you, Mr. Barron. I now recognize Mr. 
Gunasekara. Did I say it right?
    OK, for your 5 minutes, thank you.

STATEMENT OF OLIVER GUNASEKARA, CEO AND CO-FOUNDER, IMPOSSIBLE 
                  METALS, SAN JOSE, CALIFORNIA

    Mr. Gunasekara. Chairman Gosar, Ranking Member Dexter, 
Chairman Westerman, Ranking Member Huffman, distinguished 
members of the Committee, thank you for the opportunity to 
testify today.
    My name is Oliver Gunasekara. I am the CEO and Co-Founder 
of Impossible Metals. I came to this country 20 years ago as a 
proud, naturalized citizen, having been inspired by the kind of 
innovation only possible in America. I am an entrepreneur, and 
I have founded three American companies. I founded Impossible 
Metals because I recognized critical minerals have the same 
strategic importance as coal in the 19th century, oil in the 
20th century. It is an essential resource that will determine 
America's prosperity, security, and leadership for the 21st 
century.
    The demand for critical metals is accelerating. We can meet 
the shortfall, but only with new minerals because recycling, 
substitution, or demand reduction failed to meet America's 
needs. There just is not enough material in circulation for 
recycling to move the needle in the next 25 years. Substitution 
comes with compromises such as a reduced driving range. With 
new mineral sources, the only remaining option would be a 
diminished economy, families having one less car or turning off 
the air conditioner.
    AI and robotics now enable a low-cost, clean way to collect 
minerals from the vast untapped resources of the deep sea. 
Technology can meet the moment for our Nation, enabling the 
United States to secure resources our global competitors seek 
to deny us, and to do so more responsibly than most believed 
were possible even a few years ago.
    Impossible Metals is an American company that will 
responsibly harvest nickel, copper, cobalt, manganese, and rare 
Earth elements from the deep sea. These minerals are vital for 
America's defense, infrastructure, and energy industries. Our 
underwater robots hover to collect the mineral-rich nodules 
from the sea bed through an AI-driven selective harvesting. We 
pick up nodules individually, avoiding all visible life, and 
leaving 60 percent of the nodules untouched to preserve the 
marine biodiversity.
    Today a new land-based mine in the U.S. takes 29 years. 
Seabed mining is the vital alternative. We can deliver critical 
minerals at commercial scale in just 3 years, 10x faster, 10x 
cheaper, 10x lower impact, and without relying on China.
    No commercial deep-sea mining has yet occurred. For the 
last 60 years we have been preparing for this moment. We now 
have enough data to understand the limited impacts of deep-sea 
mining. In fact, each project must document any environmental 
impacts and how they are addressed before commercial deep-sea 
mining can start.
    Deep-sea mining is not just an option. It is the inevitable 
future of global mineral production. The critical questions we 
face today are about who will set the standards and how will it 
be conducted. America must lead to secure the economic and 
national security interests, ensure environmental stewardship, 
and protect human rights. We can do so because we are the 
technology leader, and because we have an enormous reserve of 
nodules in our own domestic waters.
    We have the chance to build a new American industry 
leveraging American resources. Success would generate 300 
billion in domestic economic output over 10 years, and create 
more than 100,000 jobs. The biggest barrier is legacy 
regulations. Regulatory uncertainty has inhibited investment 
and slowed domestic production, but the government can unlock 
this industry. The Trump administration last week took bold 
action, and Congress should support and build on that.
    First and foremost, we must unlock domestic resources. The 
Bureau of Ocean Energy Management has authority to offer leases 
in U.S. waters believed to contain over a billion tons of 
minerals. Impossible Metals has formally requested that the 
Bureau initiate this leasing procedure, with a decision 
expected by late May. Congress should support and streamline 
this process.
    Going further, Congress can accelerate this industry by 
adding nodules to the defense stockpile, building domestic 
mineral processing capabilities, accelerating exploration, and 
funding American innovation. By acting decisively, America can 
ensure energy abundance and create hundreds of thousands of 
quality jobs and establish a robust, responsible leadership in 
critical industry of the future.
    Thank you for inviting me, and I look forward to your 
questions.
    [The prepared statement of Mr. Gunasekara follows:]
     Prepared Statement of Oliver Gunasekara, CEO and Co-Founder, 
                           Impossible Metals

[GRAPHICS NOT AVAILABLE IN TIFF FORMAT]

                           *****

The full document is available for viewing at:

https://docs.house.gov/meetings/II/II15/20250429/118089/HHRG-
119-II15-Wstate-GunasekaraO-20250429.pdf

                                ------                                


     Questions Submitted for the Record to Oliver Gunasekara, CEO, 
                           Impossible Metals

              Questions Submitted by Representative Dexter

    Question 1. When up to 70% of benthic life is estimated to depend 
on nodules, how can we be assured there will not be a major loss of 
biodiversity under Impossible Metals' (IM) proposals?

    Answer. Our technology is designed to hover above the seabed, using 
cutting-edge AI (computer vision) to select nodules that, by location 
and careful inspection, do not harbor megafauna--exponentially reducing 
sediment and ecosystem disturbance. This environmentally conscious-by-
design approach enables us to leave 30% by mass/60% by volume of the 
nodules undisturbed. We regard this as an important way to preserve 
ecosystems, especially compared to existing alternative sources of 
critical minerals that can result in significant deforestation, ground 
and drinking water pollution, and other catastrophic environmental 
effects.
    We seek to play by the rules, and existing law requires federal 
agencies to assess the environmental effects of their proposed actions 
prior to making decisions. We expect that this will include 
Environmental Impact Assessments for seabed mining projects, and that 
these assessments will specifically address biodiversity impacts based 
on data that is relevant to the specific project site. These 
assessments must be submitted to the regulator before a lease sale and 
typically include public comment periods, assuring all interested 
parties can provide relevant data.

    Question 2. Although projected to be smaller than TMC's, the 
benthic plume produced by IM will still be sufficient to cover deep sea 
life forms by far more sediment than they are adapted to. The natural 
sedimentation rate is only of the order of 1-2 mm/thousand years. How 
will IM ensure the sediment load it creates at commercial scales does 
not interfere with the viability of benthic organisms and the 
ecological services they provide?

    Answer. The statement ``the natural sedimentation rate is only of 
the order of 1-2 mm/thousand years'' is incorrect. This number ignores 
benthic storms on the seabed floor, which significantly increase the 
sediment rate.
    As Dr. Peacock testified, the sedimentation disturbance of even 
traditional technologies has been shown to be \1/3\ to \1/5\ of the 
level hypothesized before actual testing took place. Our modeling shows 
that our approach will decrease disturbance by an additional order of 
magnitude, and we will validate this modeling in a deep sea test to 
demonstrate the lower rate of disturbance. The exploration leasing 
process will enable further data collection.
    It is expected that any lease sale will contain clear, science-
based requirements on environmental standards, such as for sediment 
disturbance. Prospective bidders will document their ability to comply 
with these standards in advance of a lease sale award, based on data 
such as the modeling and testing data described above. We also expect 
monitoring requirements to verify compliance on an ongoing basis.
    That said, all forms of mining have impacts on the environment, 
which is why innovation is critical to reduce these impacts, and why we 
have designed our systems to be by far the most environmentally 
sensitive method of securing these critical minerals. Today, 75% of 
nickel comes from Indonesian rainforests. The rainforest is destroyed 
to access the nickel laterite ore. We should mine for critical minerals 
in locations with the least environmental impacts, not the highest, 
with American environmental and social regulations.

    Question 3. Is it correct that for a full-scale deep-sea mining 
operation you would need around 100 of your mining robots operating at 
the same time, and if so, what are the implications for animals in the 
water column of these machines, including from noise and from light?

    Answer. Using a fleet of small AUVs rather than a single large 
collector presents both economic and environmental advantages. It 
reduces the risk of a single point of failure, increasing overall 
uptime, and allows a distributed fleet of low-impact AUVs to reduce 
concentrated impacts in a particular location. Nodules can be left 
behind in a pattern over the whole large collection area, rather than 
leaving wide swaths of affected areas alternating with rows of 
untouched areas.
    The Eureka III underwater robots will also significantly reduce 
noise and light impacts compared to alternatives. The noise profile of 
the AUV is designed to be low, mainly due to the buoyancy pumps and 
thrusters. We expect the noise from the Eureka III to be significantly 
less than other systems, including other vessels and offshore drill 
ships that operate today. Our Eureka III vehicles only turn on their 
lights when they are hovering above the seabed. The lights are off in 
the water column. Unlike other approaches, Impossible Metals also does 
not plan to require dynamic positioning of the support vessel, 
significantly reducing disturbance in the area closest to the surface, 
where most ocean life lives.
    Expected noise and light impacts would be further elaborated in an 
Environmental Impact Assessment.

    Question 4. How much would it cost to build, operationalize, 
maintain, and monitor that entire fleet?

    Answer. Each Eureka III is estimated to cost $1.8M to build and to 
have a 25-year life with a regular maintenance program where we spend 
around $180K each year on preventive maintenance.
    We have published the sixth version of our detailed economic model 
on our website that outlines the specific costs of building, 
operationalizing, maintaining, and monitoring the fleet of AUVs over 
the lifecycle of a representative project. Last updated in March 2025, 
this includes slides, a webinar, and a detailed spreadsheet.
    This model estimates that a deep sea mining project in the Clarion-
Clipperton Zone (CCZ) using Impossible Metals' technology at scale 
would generate $4 billion in revenue per year and around $1 billion in 
profit per year.

    Question 5. You claim that your mining will result in minerals that 
are ``10x'' cheaper than those that are produced on land. Please 
explain why that is the case, what you are including in your cost 
estimates, and how large the error bars are.

    Answer. The average all-in sustainable (AISC) cost for a nickel 
mine in 2024 was $14,979 per metric ton, including mining and 
processing costs, according to Woods Mackenzie. Our latest (v6) 
economic model estimates a cost of $743 per metric ton of nickel-
equivalent metals for a Eureka III system, or approximately 1/20th the 
cost of the average land-based nickel mine. Due to variation in the 
price of land nickel mines and alternative potential comparisons, as 
well as the assumptions involved in any economic model, 10x is a more 
realistic figure.
    Key assumptions include metal pricing, mineral processing costs, 
royalties, share of nodules left undisturbed, and the cost of 
alternative sources. More detail is available in the published model 
and slides. Please see: https://impossiblemetals.com/blog/introducing-
our-latest-concept-economic-model-v6/.

    Question 6. If you were to receive approval for a permit today, 
what is your estimate of how long it would be before you would be able 
to commence exploration activities?

    Answer. Two to three years.

    Question 7. Please explain why you are seeking subsidies from U.S. 
taxpayers if your mining ventures are projected to be as inexpensive 
and profitable as you claim.

    Answer. Congress has the opportunity to accelerate the development 
of a new industry that will create jobs and ensure that America leads 
in this field, and that those jobs are created here. It will also 
ensure the United States has the critical minerals we need for national 
security.
    Government investments in research and development have 
historically delivered strong returns to the taxpayer in economic 
growth and associated tax revenue, innovation, and global leadership, 
and investments in domestic processing capacity would strengthen 
America's industrial base and ensure developers do not need to send 
supplies to foreign countries for processing. This is particularly 
important for strategic industries like critical minerals.
    A RAND Corporation paper from April 2025 said: ``Seabed mining 
presents an opportunity for the United States and its allies to 
diversify critical mineral supply chains, bolstering critical mineral 
supply reliability and security. . . . A global seabed mining industry 
could produce amounts of nickel and cobalt--key elements for lithium-
ion batteries--that are equal to the projected United States demand in 
2040.''

    Question 8. You argue that it's in the national security interest 
of the United States to develop processing capabilities in the United 
States, which is reflected in President Trump's recent Executive Order.

    8a) How many processing plants would need to be built in the United 
States to process the minerals you expect to be harvested from the 
seabed?

    Answer. Assuming each deep sea mining concession could, at scale, 
produce 7 million metric tons of dry nodules per year, and 3 
concessions are operating concurrently, that would imply 21 million 
metric tons of nodules per year. Based on CCZ grades and 80% recovery 
rates, that would imply the following amount of metal produced per 
year:
[GRAPHICS NOT AVAILABLE IN TIFF FORMAT]

    Note, demand for these metals is growing at 7.5% CAGR.
    An average processing plant will likely process 2-5 million metric 
tons annually. So the U.S. would need at least 4 plants to process this 
amount of nodules and satisfy half of the current United States' demand 
for nickel, all domestic cobalt demand, and 10% of domestic copper 
demand.

    8b) What is the cost of building one of these processing plants?

    8c) Who will fund these processing plants?

    8d) What is the timeline for building one of these plants?

    Answer. Impossible Metals does not plan to build or own the 
processing plants; we plan to contract with processing plants to 
process nodules into pure metals. Therefore, we do not have detailed 
insight into prospective processing plants' capital costs, financing 
approaches, and timelines.

    8e) According to recent analysis, these processing plants will need 
special retrofitting to be able to most effectively process minerals 
from polymetallic nodules. Does the United States have the technical 
knowledge or workforce to do that?

    Answer. We see three phases for nodules processing:

  1. Stockpile nodules in United States locations that have good 
            transport logistics, energy for processing, and close 
            proximity to upstream customers.

  2. Reuse existing nickel processing plants in friendly nations like 
            Japan, Australia, and Canada. This will require some 
            retrofitting, but will be performed at existing facilities 
            in friendly locations. This has already been demonstrated 
            without refitting at a Japanese facility.

  3. Develop new bespoke mineral processing facilities in the U.S. 
            adjacent to the stockpiles.

    The United States may lack all the technical knowledge or workforce 
for domestic mineral processing facilities, but we have a little time 
to invest and acquire this knowledge and workforce if Congress and the 
Administration act.
    More broadly, if the United States were to lack seabed mining and 
processing capabilities over the long term, it would be forfeiting 
access to what is perhaps the world's largest, most accessible, and 
lowest environmental impact source of these critical minerals--allowing 
China and other strategic competitors to control this resource and its 
economic and strategic benefits.

    8f) Where will you sell your nodules/minerals before theoretical 
United States processing plants come online?

    Answer. As outlined above, we plan to use friendly nation 
processing facilities in the interim. Even if the processing happened 
in friendly nations, the offtake could still be sold to the U.S. 
industrial base.

    Question 9. How will you ensure that the minerals and metals coming 
from your process will not go to Chinese or Chinese-operated or 
controlled processing plants? How will you differentiate them from 
those that are processed in China or by Chinese-controlled or operated 
processing plants?

    Answer. We have no intention to use Chinese or Chinese-operated or 
controlled processing plants. Existing federal policy reinforces this 
intention. The Inflation Reduction Act of 2022 has several applicable 
tax credits and incentives, but only if the minerals do not come from a 
foreign entity of concern, e.g., China. Chinese export restrictions and 
intellectual property policies, and economic barriers between the 
countries, further decrease the desirability of Chinese processing.

                                 ______
                                 

    Dr. Gosar. Thank you very much, Mr. Gunasekara.
    Now, Mr. Currie, you are recognized for 5 minutes, all the 
way from New Zealand.

      STATEMENT OF DUNCAN CURRIE, LEGAL ADVISOR, DEEP SEA 
         CONSERVATION CENTER, CHRISTCHURCH, NEW ZEALAND

    Mr. Currie. Thank you, Mr. Chairman, and a privilege to 
give evidence before this important Committee on this crucial 
issue of deep-sea mining.
    I have practiced international ocean law for over 35 years. 
I have attended negotiations at the International Seabed 
Authority since 2012, and I advise the Deep Sea Conservation 
Coalition in matters of international law. I presented written 
submissions to this Committee that cover a range of concerns 
with deep-sea mining. In this oral testimony I will focus on 
why deep-sea mining is unnecessary, and why pursuing it would 
bring the U.S. only problems, not solutions.
    Firstly, seabed mining is unnecessary. The four metals that 
can be practically sourced from nodules--copper, cobalt, 
nickel, and manganese, none of which are rare Earth elements. 
Because manganese and copper are expensive, nodules are really 
all about nickel and cobalt. The market for these is volatile, 
with prices currently relatively low. As we have heard from the 
members this morning, EV batteries are moving rapidly to 
lithium iron phosphate technology, which uses no cobalt or 
nickel.
    The OECD tells us that the economic case for deep seabed 
mining is not evident. Terrestrial mines are more cost 
effective for these minerals. The technology is tried and 
tested. Terrestrial deposits will meet foreseeable future 
demands, especially as technological advancements and battery 
chemistries continue to move away from critical minerals.
    Stockpiling, as was suggested in last week's executive 
order, will support future demand and makes a great deal of 
sense, particularly for cobalt and nickel.
    The circular economy has an important role to play. Reuse, 
repurpose, recycle.
    There is no commercial deep-sea mining happening anywhere. 
There are no full-scale mining machines built. The technology 
required would operate 5,000 meters deep, much deeper than oil 
and gas installations, in hostile environments. It will be 
monumentally expensive to build all of the ships, mining 
equipment, and monitoring systems necessary for this industry.
    The junior companies before you today have weak financing 
and sub-scale, unproven technology that cannot be relied on. 
The Metals Company grew out of Nautilus Minerals, which failed 
in Papua New Guinea, ending with a company in liquidation and 
costing Papua New Guinea over $100 million.
    Next, seabed mining is harmful. In addition to damaging the 
sea floor and removal of the nodules, the damage from benthic 
plumes and noise impacts, The Metals Company would discharge a 
mid-water plume of sediment, metal particles, and dissolved 
metals into the water column. The Metal Company sometimes likes 
to confuse the benthic or sea floor plume with the mid-water 
plume. They are separate, and it is the mid-water plume that 
will travel hundreds of kilometers.
    Even if Impossible Metals technology does avoid mid-water 
plume, there is no way to avoid the fundamental removal of 
nodules which has critical impacts on deep sea ecosystems. The 
plume would likely impact valuable fisheries and ecosystems 
crucial to the U.S. and Pacific countries, as well as potential 
marine genetic resources used for pharmaceuticals.
    Next, scientific knowledge is inadequate. Scientific 
information and understanding about the deep sea is critically 
lacking. Ninety percent of five thousand species in the 
Clarion-Clipperton Zone are still undescribed, and we are only 
now discovering that deep sea oxygen is being produced, 
possibly by the nodules themselves. This illustrates what we do 
not know about the deep sea.
    Next are international repercussions. The 1982 Convention 
on the Law of the Sea governs the ocean. It is known as a 
constitution for the ocean. The deep sea is universally 
acknowledged to be the common heritage of humankind. The 
treaty's purview includes maritime boundaries, extended 
continental shelf claims, and freedom of navigation for 
vessels. The U.S. can endanger all of those if it issues 
permits unilaterally. Mr. Barron did not tell you that the U.S. 
has signed the 1994 implementing agreement, which addressed a 
lot of the issues that the U.S. had with the early problems 
with, excuse me, the 1992 convention.
    And as we have heard from the members already, insurance 
companies and financial institutions are turning their backs on 
deep-sea mining. There is global opposition to deep-sea mining, 
and this includes the United States and territories across the 
Pacific. Thirty-two countries support a moratorium or a pause 
which would put an end to the current discord and chaos, allow 
the necessary science to be gathered, and for the implications 
of deep-sea mining to be understood.
    The deep sea is a treasure trove of biodiversity and home 
to untold wonders and possibilities. Destroying these 
possibilities and going it alone will be disadvantageous to the 
United States economically, scientifically, and 
environmentally.
    I look forward to your questions. Thank you, Mr. Chairman 
and members.
    [The prepared statement of Mr. Currie follows:]
     Prepared Statement of Duncan Currie, Legal Advisor, Deep Sea 
                         Conservation Coalition

[GRAPHICS NOT AVAILABLE IN TIFF FORMAT]

                          *****

The full document is available for viewing at:

https://docs.house.gov/meetings/II/II15/20250429/118089/HHRG-
119-II15-Wstate-CurrieD-20250429.pdf

                                ------                                


  Questions Submitted for the Record to Duncan Currie, Legal Advisor, 
                    Deep Sea Conservation Coalition

              Questions Submitted by Representative Dexter

    Question 1. In your oral testimony, you suggested that unilateral 
actions to mine the international seabed as envisioned under President 
Trump's recent Executive Order, ``Unleashing America's Offshore 
Critical Minerals and Resources,'' will have consequences beyond the 
deep-sea mining regime of the United Nations Convention on the Law of 
the Sea. Can you elaborate?

    Answer. Unilateral action to mine the deep-seabed beyond national 
jurisdiction (called the ``Area''), as International Seabed Authority 
Secretary-General Leticia Carvalho said, not only threatens the 1982 
United Nations Convention on the Law of the Sea, and decades of 
successful implementation and international cooperation, but also sets 
a dangerous precedent that could destabilize the entire system of 
global ocean governance.
    The 1982 Convention not only regulates activities in the Area, such 
as deep-sea mining, but also is central to the governance of maritime 
boundaries, the freedom of navigation, exclusive economic zones, the 
continental shelf, shipping, protection and preservation of the marine 
environment, and marine scientific research. It is known as the 
`constitution of the oceans'. These matters are of great importance to 
the United States. By acting outside the Convention, the United States 
would weaken the Convention and may lead to other States likewise 
acting in contravention of the Convention.
    Three legal observers to date have come to similar conclusions that 
unilateral mining would be unlawful: one as early as 2021, well before 
the current controversy. Coalter Lathrop in a blog observes that while 
the United States did not sign UNCLOS, it did sign the 1994 Part XI 
Implementing Agreement, because, as the U.S. President said at the 
time, ``the Agreement meets the objections the United States and other 
industrialized nations previously expressed to Part XI''. Lathrop 
observes that ``[t]he object and purpose of the Implementing Agreement 
was the creation of a common management regime for the Area and its 
mineral resources. Unilateral U.S. permitting in areas beyond U.S. 
jurisdiction, as contemplated in the Executive Order, would severely 
undermine that common management regime and would constitute a 
violation of U.S. obligations as a signatory to the Implementing 
Agreement.'' This is contrary to the Vienna Convention on the Law of 
Treaties, whereby signatories including the United States are obliged 
to refrain from acts which would defeat the object and purpose of the 
1994 Implementing Agreement.
    The author examines recent State practice, and concludes with 
respect to ``the prohibition against unilateral mining activities, 
``[i]s this prohibition a rule of customary international law? Almost 
certainly, yes.'' ``There is widespread state practice that subscribes 
to the common management of the Area and its resources, including the 
continuous U.S. practice since 1994 . . . Any attempt by the United 
States to characterize itself as a persistent objector to the formation 
of the customary rules governing the mineral resources of the Area 
would be made in the teeth of U.S. practice over the last fifty-five 
years, which is, at best, inconsistent.'' He concludes that ``[t]he 
solution is not to destabilize the international order of the oceans 
that the United States has so intentionally and successfully crafted 
since the closing days of World War II.''
    An earlier blog from April 2025 by Cavalcanti de Mello Filho came 
to a similar conclusion: the common heritage of humankind principle has 
become customary international law, and the argument that the U.S. has 
been a ``persistent objector'' to this rule since its formation is 
flawed, for the U.S. objection has not been ``maintained 
persistently.'' He goes further and suggests that in any case, the 
common heritage principle is arguably a peremptory norm of 
international law: a core principle that admits of no exception, 
derogation, or objection. In his view, the issuance of mining permits 
for The Metals Company would be a serious breach of the principle.
    Joanna Dingwall's book is particularly interesting because it dates 
back to 2021. She concluded that ``Given that state conduct within the 
regime has been overwhelmingly consistent, this gives credence to the 
argument that elements of the UNCLOS deep seabed regime (such as the 
prohibition on unilateral mining activities) now have customary status. 
Secondly, the widespread acceptance and recognition of the regime 
within the broader international community also supports the conclusion 
that there is a customary prohibition on mining in the Area outside of 
the regime.'' (p. 172)
    In addition, acting unilaterally is accompanied by myriad legal 
difficulties. To name a few:

     No State or natural or juridical person shall claim, 
acquire or exercise rights concerning the minerals recovered from the 
Area except in accordance with Part XI of UNCLOS. Otherwise, no such 
claim, acquisition or exercise of such rights shall be recognized. 
(Article 137(3)). This would raise questions as to the ownership of any 
metals taken from the deep seabed, and very likely complications along 
the supply chain, including processing and including the use of the 
metals in products. Note that article 137 as part of the regime of the 
common heritage of (hu)mankind is customary international law and thus 
binding on the United States of America.\1\ Therefore, simply stated, 
the United States does not own the minerals from the Area that it is 
purporting to licence.
---------------------------------------------------------------------------
    \1\ Joanna Dingwall. International Law and Corporate Actors in Deep 
Seabed Mining. 2021. https://doi.org/10.1093/oso/
9780192898265.001.0001). Page 162.

     The general conduct of States in relation to the Area 
shall be in accordance with the provisions of Part XI, the principles 
embodied in the UN Charter and other rules of international law in the 
interests of maintaining peace and security and promoting international 
co-operation and mutual understanding (Article 138). Other States will 
need to avoid being party to a breach of the Convention: for instance, 
Allseas Group, which owns the mining vessel and equipment that The 
Metals Company intends to use to carry out any mining, is Swiss-based 
and operates in the Netherlands. Both the Netherlands and Switzerland 
are parties to the Convention and are prohibited from participating in 
---------------------------------------------------------------------------
any unilateral mining (see the answer to question 4).

     Other States may be encouraged by any United States 
unilateral mining to follow suit. This could lead to further breakdown 
in the Convention, massive environmental destruction and even conflict.

    In terms of national security, concern was expressed as early as 
2016 about tensions over UNCLOS, maritime claims and freedom of 
navigation (Colin, 2016). Any failure to adhere to UNCLOS and 
consequent weakening of the authority of UNCLOS can have adverse 
consequences for United States security interests in the ocean from 
Asia to the Pacific and the Atlantic ocean, including freedom of 
navigation and claims to extended continental shelves.
The Pacific Region
    The proposed mining area in the Clarion-Clipperton Zone is in the 
north Pacific Ocean. If the U.S. were to take unilateral decisions to 
mine or even explore for exploitation purposes in the Area, outside of 
the framework of UNCLOS, it would pose multiple layers of risk to the 
Pacific region and to the long-standing relationships between the U.S. 
and Pacific States.
    Such actions, contrary to international law, would be in direct 
conflict with Pacific regional commitments and the foundation upon 
which regional aspirations are built.
    The `Boe Declaration on Regional Security' adopted by the Pacific 
Island Forum Leaders at Nauru in 2018 explicitly references the 
importance to regional security of adherence to international law;
    ``6. (vi) We reaffirm the importance of the rules-based 
international order founded on the UN Charter, adherence to relevant 
international law and resolution of international disputes by peaceful 
means.''
    In 2022, the 18 Members of the Pacific Island Forum endorsed the 
`2050 Strategy for the Blue Pacific Continent.' The articulated Vision 
places peace and security at the centre of the strategy, ``As Pacific 
Leaders, our vision is for a resilient Pacific Region of peace, 
harmony, security, social inclusion and prosperity, that ensures all 
Pacific peoples can lead free, healthy and productive lives.''
    The peace and stability that exists via the rules-based order under 
UNCLOS, benefits all States, not just Pacific Island States. Their 
collective aspirations are built on agreed rules and norms of 
engagement as set out in international law.
    The signalled unilateral action is threatening to take resources 
that belong to the international community which the United States does 
not have the jurisdiction to take, and to persist in this effort is 
likely to receive responses from many States and international 
organizations in different forms that could be severely detrimental to 
U.S. trade, international relations, and maritime security. Unilateral 
deep-sea mining will undermine the United States reputation and 
position of influence in the Pacific, which could strengthen the 
influence of other regional powers.
    The Pacific Ocean, and the life that exists within it, has 
sustained Peoples of the Pacific for thousands of years. Vastly diverse 
Pacific cultures revolve around and are dependent upon a healthy ocean. 
It is well understood that deep-sea mining would negatively impact 
ocean health, thus potentially threatening the well-being of Pacific 
communities, their livelihoods and economies.
    In terms of national security, concern was expressed as early as 
2016 about tensions over UNCLOS, maritime claims and freedom of 
navigation (Colin, 2016).

    Question 2. Can you clarify your concerns about the mid-water plume 
that would be generated by deep sea mining, especially in response to 
the evidence presented by Dr. Peacock during the hearing?

    Answer. This is an important issue as the United States could be 
held liable for damage caused to the environment from deep-sea mining, 
including transboundary harm and impacts on commercial fisheries, all 
impacts which could result from the mid-water plume.
    Dr. Peacock said in his written testimony that in 2022 in the 
Clarion-Clipperton Zone, his team participated in a test which included 
discharging sediment, metal fragments and dissolved metals at 1,200 
metres depth, creating a midwater sediment plume. However, his further 
testimony only discussed the `benthic' plume or the plume created by 
the collector on the seafloor. As I noted in my written testimony, 
plumes of wastewater, sediment, and residual metals discharged from 
ships during mining--expected to be discharged into 1,200-2,000 metre 
depths from most proposed mining methods--could flow hundreds of 
kilometers horizontally away from the mining sites, as well as 
potentially spread vertically: a finding from Dr, Peacock's own 
laboratory (Munoz-Royo et al., 2021). This plume would be a long-
lasting plume created throughout the duration of mining activities, 
with plumes from each mining contract area using the technology.
    One challenge highlighted in the Munoz-Royo et al. study is 
defining the limit of the plume: to what sediment concentration does a 
plume need to dilute to before it is no longer a plume? The study 
presents several scenarios whereby the plume length and height are 
determined based on different dilution factors, and unsurprisingly, the 
dilution factor (the lowest is still two times the natural background 
particle concentration) influences the size of the plume. More 
importantly, none of these sediment concentration levels are linked to 
biological impacts. That is, whether and to what extent sediment 
concentrations created across the plume will harm midwater communities.
    There is currently limited empirical evidence available for deep-
sea animals exposed to suspended sediment concentrations (there are 15 
peer-reviewed studies), and all but one study focus entirely on benthic 
environments. The one peer-reviewed study for the midwater (Stenvers et 
al., 202) focused on a jellyfish and showed negative acute and 
energetically costly responses when exposed to sediment concentrations 
of at least 17 mg/l. This jellyfish was obtained from a Norwegian 
fjord, which is a naturally more turbid area compared to the deep 
waters of the Clarion-Clipperton Zone. This is important as organisms' 
sensitivity to increased suspended sediment concentrations are affected 
by the level of naturally occurring sediment concentrations. That is, 
for example, organisms that occur in naturally turbid areas (e.g., 
estuaries) are less sensitive to sediments than organisms from 
naturally clear waters (e.g., lakes), as shown by van der Grient & 
Drazen (2022). Meaning, it is highly possible that animals from the 
Clarion-Clipperton Zone are more sensitive than the ones from the 
Norwegian fjord, and would respond in negative ways at much lower 
sediment concentrations (only a few mg/l)--and therefore also respond 
across a larger part of the plume-as modelled by van der Grient & 
Drazen (2022).
    The midwater plume can elicit a range of responses (van der Grient 
& Drazen 2022); a plume could disrupt feeding, breathing, communication 
and buoyancy of deep pelagic species. As the deep pelagic and shallow 
water (epipelagic) food webs are connected via diurnal vertical 
migration, impacts in the deep can be transferred via prey-predator 
interactions to shallower-occurring species, including commercially-
important species, as well as whales and species currently ranked as 
endangered (Martin, 2021, Chin and Hari 2020; Thompson et al., 2023; 
Drazen et al., 2020).
    A paper (Dowd, preliminary results presented at a scientific 
conference) is expected to show that zooplankton could be negatively 
impacted as they could (i) get confused and ingest sediment particles 
instead (and starve even feeling full), (ii) reject sediment particles 
but this comes with an increased energetic cost (iii) have their food 
source diluted--which is a problem as it is already an oligotrophic 
region, and food availability can affect the strength of animal 
responses to suspended sediments, with lower food availability 
resulting in stronger negative responses (Kang, 2012).
    The midwater plume is also expected to contain elevated 
concentrations of toxic metals, which could be incorporated and 
bioaccumulate into ocean food webs, with impacts on the health of 
marine ecosystems and humans via our seafood supply (Hauton et al., 
2017; Drazen et al., 2020). Additionally, independent monitoring of the 
BGR/GSR trials by the Mining Impact consortium found that dissolved 
metals were also released from benthic plumes. In presenting this 
research, it was noted that these generally exhibit a higher toxicity 
than solid metals (Haeckal et al., 2024). Last, sediments from the 
Clarion-Clipperton Zone contain persistent organic pollutants (POPs), 
which accumulate in the food web (Sacket et al., 2024). Discharging 
such sediments in the midwater could introduce these POPs into the 
water column and the pelagic food web.
    Many commercially important species are highly migratory, such as 
tuna, and any contamination of fishes through the food chain could 
percolate through the wider stock distribution. Climate change is 
driving increasing overlap between eastern Pacific tuna fisheries and 
deep-sea mining. Climate models suggest that tuna distributions will 
shift in the coming decades, increasing the potential overlap between 
fishing and mining activities within and around the CCZ, which could 
represent substantial economic and health risks for nations fishing in 
the region (van der Grient & Drazen, 2021; Amon et al., 2023). The full 
Committee's Ranking Member, Rep. Huffman, and Subcommittee Ranking 
Member, Rep. Dexter, observed that toxic plumes could travel hundreds, 
even 100s of miles.
    Note that this is estimated from a point--mining operations will 
move in space, so the spread of plumes will increase because of changes 
in mining operations as well. How such operations affect spread of 
plumes have not been modelled for either type of plume, and instead we 
only have estimates for a plume released from a stationary point.
    If discharged too shallow, they could disrupt pelagic food webs, 
including tuna, whales and other species that support our economy. The 
Global Tuna Alliance and other seafood industry groups have called for 
a halt to deep-sea mining because of the risk that such plumes could 
pose to disrupting feeding, breeding and migration patterns for tuna. 
The Global Tuna Alliance's 48 industry partners account for 32% of the 
global tuna trade. The effect on economically valuable tunas will 
depend on the depth of the discharge plume. This depth is not, for 
example, currently taken up in the ISA draft regulations on 
exploitation, and instead will rely on the decisions of a mining 
contractor. Their choice of discharge depth may depend on financial, 
technological and logistical constraints, factors which are at this 
moment unclear in how they may influence a mining operation. Intentions 
can be clarified by the industry, but given the potential high risk of 
this factor, an intention or promise may not be sufficient, as market 
forces could result in the shallowing of a discharge if it is cheaper. 
It must be properly considered whether this unregulated factor is 
acceptable in the management of the Blue Economy. In addition, it is 
important to understand that different depths have different 
oceanographic dynamics, such as the direction, seasonal positioning and 
strength of currents and the effect of passing eddies, and these 
factors can influence the spread of a plume. For example, the seasonal 
shifts in the North Equatorial Current and North Equatorial 
Countercurrent and presence of eddies have not been taken up in any of 
the plume models investigating midwater discharges thus far (Fiedler & 
Talley 2006; Perelman et al., 2023).
    Modeling independent of the DSM industry predicts that it could 
take only three months for sediment particles discharged in The Metals 
Company (TMC)'s subsidiary TOML's (Tonga) licence area to reach the 
waters of Kiribati and Hawaii with unknown consequences (@ 11-13.30 
min). As described in the associated technical paper, this prediction 
is derived from accredited oceanographic models utilising the most 
rigorous data available as of 2022, and references the 2022 
publications from Dr. Peacock's laboratory.
    Dr. Peacock also indicated that during prototype trials by GSR that 
in-situ monitoring of the benthic plume showed that 2-8% of the 
sediment plume generated was suspended up to around 15 feet above the 
seabed. The fate of this lighter portion is unknown, however research 
(Gazis et al., 2025) highlights variability in sediment deposition in 
the CCZ due to site-specific currents and physical processes. This 2-8% 
portion of the sediment plume could be significant taking into the 
potential high sensitivity of deep-sea animals to suspended sediments 
given the naturally clear waters, and accounting for the cumulative 
impacts over the multiple 30 year plus licence periods and the 
employment of multiple commercial-scale machines, which as noted by Dr. 
Peacock are 3 times larger than tested prototypes.
    It is worth repeating that the benthic (seafloor) plume is separate 
from the midwater (discharge) plume. Impossible Metals' technology 
proposes not to create a midwater discharge plume, but the benthic 
plume remains a significant concern. It is also worth noting that 
Impossible Metals proposes a yet-to-be proven mining method which, in 
theory, would reduce sediment plumes relative to other proposed 
seafloor mining machines. However, the resulting benthic plume as 
predicted by modeling commissioned by IM (DHI, 2024) could be 
sufficient to create a coating of the seabed and a cloud of suspended 
sediment. Even small sediment loads are sufficient to interfere with 
the function of, reduce viability, and kill deep-sea organisms, 
including microorganisms (Mevenkamp et al., 2017).
    With these potentially significant risks to marine life, as well as 
substantial knowledge gaps (Amon et al., 2022), there is a critical 
need for more independent scientific data to inform decision making. 
This includes data on site-specific oceanographic and sediment studies 
to understand the sediment dispersion patterns of plumes in the 
changing oceanographic dynamics present in the Clarion-Clipperton Zone, 
and the impacts of various elements of the plume (sediment, wastewater, 
as well as particulate and dissolved metals) on marine animals and how 
this translates to impacts to biodiversity and the wide-ranging food-
web effects including for commercially important species.
    This will require site-specific in situ testing with the technology 
to be used in commercial mining, as well as laboratory experiments and 
appropriate modelling efforts.

    Question 3. Can you please expand on your comments about the role 
of polymetallic nodules in the deep-sea ecosystem and the consequences 
of removing them?

    Answer. It is important to note that considerable scientific 
uncertainties exist: we only learned that nodules were radioactive two 
years ago, and only last year that they may be involved in oxygen 
production (Sweetman et al., 2024).
    Polymetallic nodules form a critical part of the habitat in abyssal 
ecosystems by providing hard substrate in a soft-sediment environment. 
This hard substrate provides an anchor, attachment surface or shelter 
for a multitude of deep-sea animals (Vanreusel et al., 2016; Amon et 
al., 2016; Simon-Lledo, et al., 2019). In fact, more than 50% of deep-
sea megafaunal species, such as corals, anemones, and sponges, in the 
Clarion-Clipperton Zone depend on nodules as an attachment surface, 
anchor, or shelter (Vanreusel et al., 2016; Amon et al., 2016; Simon-
Lledo, et al., 2019; Uhlenkott et al., 2022). The nodules also harbour 
diverse microbial communities that are distinct from those on 
neighbouring sediment and in the surrounding water (Shulse et al., 
2017).
    Nodules also play a critical role in maintaining deep-sea food-web 
integrity and their removal, even at the rates proposed by Impossible 
Metals, will likely result in lower abundance and diversity of seafloor 
life, which could directly affect ecosystem function and even services 
(Stratmann et al., 2021). Just a few months ago, the nodules were also 
found to be creating oxygen in the Clarion-Clipperton Zone (Sweetman et 
al., 2024). This was the first time oxygen was observed being created 
in the absence of sunlight, which challenges the previously held 
scientific consensus that oxygen is produced solely from light through 
photosynthesis. While the biological relevance has not been confirmed 
yet, the oxygen that is being produced may contribute to sustenance of 
life in the deep sea or life on Earth more generally. This recent 
discovery is an example of how poor our understanding is of the 
functioning of the CCZ ecosystem, the deep sea generally, and the 
planet, and is a canary in the coal mine for irreversibly damaging 
ecosystems, losing these types of mechanisms, before we know about them 
or understand their significance.
    Without the presence of nodules, recolonisation of a significant 
portion of the inhabiting fauna will not be possible. For example, 
``Due to the slow growth rates of nodules (ca. 10 mm/My) and overall 
very low sedimentation rates, short-term recovery is unlikely; the 
nodules and nodule dependent fauna may take millions of years to 
recover, and even the partial recovery of the motile sediment-dwelling 
fauna may take hundreds to thousands of years'' (Kaiser et al., 2017). 
As such, there will be severe and likely irreversible effects on 
seafloor communities from any type of polymetallic-nodule mining 
(Simon-Lledo et al., 2019).
    It should also be noted that Impossible Metals intends to leave 60% 
of nodules by number and 30% by mass. So the 40% of the nodules taken 
will comprise 70% of the mass. This could only be achieved by 
selectively targeting large nodules and leaving small nodules: the 
relatively low surface area and mass of which will support less life 
through the provision of anchors, attachment surfaces or shelter. It 
appears that this proposal is not validated by peer-reviewed science. 
This proposed mining strategy is unlikely to maintain ecosystem 
viability and function--a consequence that would only be understood 
through long-term studies. Impossible Metals also proposes to use AI 
technology and video imagery to selectively choose nodules with less 
fauna. This has not yet been proven and further lacks independent 
scientific verification. It remains to be seen what species and size of 
species the technology will actually be able to identify, especially in 
a seascape where >88% of species have not yet been formally described 
or have not yet been discovered (Rabone et al., 2023).

    Question 4. In your evidence you raised the potential legal 
problems regarding companies operating on a U.S. license in 
international waters. Could you elaborate on what the impacts may be, 
specifically for The Metals Company given their application?

    Answer. The Metals Company themselves have said in a filing to the 
United States Securities and Exchange Commission dated May 12, 2025 
that:

        ``The announcement or implementation of this strategy may cause 
        additional regulatory and political tensions, delay ISA 
        decision-making, or impair our ability to secure or maintain 
        exploration contracts or an exploitation contract under the ISA 
        framework and may result in our need to engage in costly and 
        time-consuming litigation to enforce our rights. In addition, 
        UNCLOS parties and the ISA are under a legal obligation, under 
        UNCLOS, not to recognize any commercial recovery permit issued 
        to us under DSHMRA; many UNCLOS parties and the ISA are likely 
        to regard such a permit as a violation of international law, 
        including UNCLOS, which could affect international perceptions 
        of the project, and could have implications for logistics, 
        processing, and market access in UNCLOS parties for seabed 
        minerals extracted under a U.S. license and for downstream 
        products containing them, or for partnerships involving foreign 
        entities, and could also result in actions, pursuant to UNCLOS, 
        against TMC under the national laws of UNCLOS parties, any or 
        all of which could have a material adverse affect on our 
        business, financial condition, liquidity, results of operations 
        and prospects''. (emphasis added)

    Note that 169 countries, including the top U.S. trading partners, 
are parties to UNCLOS.
    Article 137 of the 1982 United Nations Convention on the Law of the 
Sea (the ``Convention'' or ``UNCLOS'') provides that:

    1. No State shall claim or exercise sovereignty or sovereign rights 
over any part of the Area or its resources, nor shall any State or 
natural or juridical person appropriate any part thereof. No such claim 
or exercise of sovereignty or sovereign rights nor such appropriation 
shall be recognized.

    2. All rights in the resources of the Area are vested in mankind as 
a whole on whose behalf the Authority shall act. These resources are 
not subject to alienation. The minerals recovered from the Area, 
however, may only be alienated in accordance with this Part and the 
rules, regulations and procedures of the Authority.

    3. No State or natural or juridical person shall claim, acquire or 
exercise rights with respect to the minerals recovered from the Area 
except in accordance with this Part. Otherwise, no such claim, 
acquisition or exercise of such rights shall be recognized.

    Joanna Dingwall examined article 137 obligations and concluded 
that, as a matter of treaty law (i.e. for parties to UNCLOS), ``there 
are sufficient grounds to argue that Article 137 binds corporate 
actors, including nationals of NSPs [non-State Parties, such as the 
United States], directly, as a matter of treaty law.'' (page 189) And 
as regards non-Parties, ``the customary prohibition on unilateral deep 
seabed mining activities constitutes an international law rule which is 
directly binding upon corporate actors . . . if corporate actor began 
mining the deep seabed unilaterally, that actor would violate the 
customary norm prohibiting this activity and, consequently, would be 
responsible, as a matter of international law, for this violation.'' 
(page 194)
    Paragraph 3 of article 137 is in my view particularly problematic 
for The Metals Company. No party to the Convention may recognize any 
claim with respect to minerals recovered from the Area otherwise in 
accordance with Part XI (refer The Metals Company in the extract 
above). In sum, no rights shall be acquired or exercised with respect 
to the minerals. This provision could make it very problematic to 
process the nodules, and even to sell any metal such as nickel, cobalt, 
copper or manganese recovered from the metals to any party to UNCLOS. 
At this stage it cannot be said how far down the supply chain this 
would apply. Would products including such metals also be unable to be 
bought by any party to UNCLOS or their nationals?
    In addition, to the downstream supply chain difficulties, suppliers 
will also be constrained. Firstly, UNCLOS Parties are obliged to both 
comply with Part XI, which addresses deep-sea mining (Arts. 139, 154, 
etc) to act in accordance with Part XI (Article 138) and are obliged 
not to aid or assist another State in the commission of an 
internationally wrongful act (Articles on Responsibility of States for 
Internationally Wrongful Acts adopted by the International Law 
Commission, Article 16). These, and potentially other measures, could 
hinder The Metals Company in its reliance on its suppliers of 
technology and expertise, for instance.
    The terms of The Metals Company's subsidiary NORI's contract with 
the International Seabed Authority and with its sponsoring States Nauru 
and Tonga Offshore Mining Ltd (TOML), particularly in relation to 
NORI's obligations with respect to the International Seabed Authority, 
also need to be raised in this context. The ostensible unlawfulness of 
any DSHMRA permit exposes the operation to risk of litigation that 
could be costly to the company, the Government, and the taxpayer.

    Question 5. Would deep sea mining eliminate extractive mining on 
land?

    Answer. No. Any deep-sea mining would be in addition to terrestrial 
mining and mines would not close. There are no academic studies that 
prove that DSM will reduce terrestrial mining of metals in rainforests. 
Terrestrial mining would continue even if deep-sea mining increases the 
impact of mining on the globe.
    The World Economic Forum found that DSM ``will not necessarily lead 
to mine closures or to planned new mines being abandoned. Nor would it 
selectively eliminate land-mining operations with the lowest 
environmental or social performance since pressure on land-based mines 
would correlate to their production costs rather than their 
sustainability attributes.'' (World Economic Forum (2022)). A study 
commissioned by the ISA found that DSM will not cause overproduction of 
minerals globally (Lapteva et al., 2020). Rather, mining both the deep 
sea and on land could drive down mineral prices, reducing neither's 
destructive practices and lowering prices (Lapteva et al., 2020). To 
use nickel as an example, TMC's maximum production rate year, according 
to its March 2021 forecast, will be 119,000 tons (TMC 2021). World 
production in 2030 is projected to be 5,090,000 tons (and, thus, in 
2031 will be at least that number). Therefore, TMC would produce only 
2.34% of world's production in 2031. To use nickel as an example, TMC's 
maximum production rate year, according to its March 2021 forecast, 
will be 119,000 tons (TMC 2021). World production in 2030 is projected 
to be 5,090,000 tons (and, thus, in 2031 will be at least that number). 
Therefore, TMC would produce only 2.34% of world's production in 2031.
    Damage to biodiversity on land cannot be compared to damage to 
biodiversity from deep-sea mining, which is currently unknown. TMC's 
own reports \2\ acknowledge that a biodiversity comparison of the 
impacts on species and biodiversity from deep-sea mining versus 
terrestrial mining can't be done. A December 2023 report found that 
``the results of the three current studies comparing the cradle-to-gate 
(nodule-to-commodity) climate impact of deep sea and terrestrial mining 
vary hugely, estimating that polymetallic nodules could have a higher 
or lower climate impact than land ores.'' (Amadi 2023). The report 
noted that two of the three studies were funded and supported by DSM 
companies (Amadi 2023). The European Academies Sciences Advisory 
Council evaluated claims that DSM is the ``lesser of two evils when 
compared with terrestrial mining'' and found those claims misleading: 
``We discuss the validity of such claims and find them misleading, and 
note also that deep-sea mining lacks the mitigation and remedial 
measures available to terrestrial mining.'' (EASAC 2023).
---------------------------------------------------------------------------
    \2\ The Metals Company: Life Cycle Analysis: Where Should Metals 
for the Green Transition Come From? Comparing Environmental, Social, 
and Economic Impacts of Supplying 
Base Metals from Land Ores and Seafloor Polymetallic Nodules. At
https://metals.co/wp-content/uploads/2023/03/TMC_NORI-
D_LCA_Final_Report_March2023.pdf.
    ``An effort was made through endpoint analysis to assess the impact 
on ecosystems and some level of biodiversity analysis. However, this 
method is still very limited as it does not account for the ocean 
fauna, neither the type of vegetation and terrestrial land type.''
    And see Daina Paulikas, Dr. Steven Katona, Erika Ilves, Dr. Greg 
Stone, Anthony O'Sullivan.
    Where should metals for the green transition come from? 2020.
    https://www.fullertreacymoney.com/system/data/files/PDFs/2020/May/
22nd/LCA-White-Paper_Where-Should-Metals-for-the-Green-Transition-Come-
From.pdf
    ``Biodiversity is acknowledged in the paper as the most significant 
impact of nodule collection and is treated qualitatively in the paper. 
Because biodiversity impacts are treated qualitatively, it is difficult 
to say with certainty that biodiversity and species impacts from deep-
sea nodule collection would be less significant than those observed and 
measured on land.''
    TMC's own financial filings repeat this: `` `it may also not be 
possible to definitively say whether the impact of nodule collection on 
global biodiversity will be less significant than those estimated for 
land-based mining.'' Annual Report for 2021 Form 10-K, p 41-2.
---------------------------------------------------------------------------
    Deep-sea mining currently lacks the mitigation and remedial 
measures available to terrestrial mining. In terrestrial mining, a 
four-tier mitigation hierarchy is used to protect biodiversity: (i) 
loss avoidance; (ii) minimisation; (iii) remediation; and, as a last 
resort, biodiversity offsets (Van Dover et al., 2017). When comparing 
this to DSM, avoidance of biodiversity loss is not possible as the 
habitat will be destroyed and biodiversity may also be lost in the 
water column and areas affected by sediment plumes. With a lack of 
physical boundaries in the marine environment, impact minimisation is 
constrained, in contrast to terrestrial mining, where engineering 
design can limit impacts to the mining site. Similarly, remediation of 
deep-sea ecosystems is likely to be ineffective owing to the slowness 
of deep-sea recolonisation of disturbed habitats, the large areas 
affected, and the irreversibility of some habitat loss (see results 
from DSM on the Blake Plateau 50 years on) (Planet Tracker, 2023). 
Lastly, offsets to compensate for biodiversity loss over hundreds of 
thousands of kilometres of seabed is next to impossible.
    DSM will undermine the shift toward a circular economy (EJF, 2024). 
Recycling would help to increase resilience and supply chain security, 
while reducing primary extraction of raw materials and its associated 
environmental and social impacts. High recovery rates of above 90% are 
feasible for all four DSM Metals (Dominish et al., 2021).
    Recoverable minerals from polymetallic nodules, the source which is 
the current focus of deep-sea mining, are cobalt, nickel, manganese and 
copper. The first three are a small proportion of the 50 minerals on 
the U.S. Critical Minerals List, which does not feature copper (which 
is available only as an effective by-product in polymetallic nodules. 
(U.S. Congress, 2025). Note that rare earth elements (RREs) are not 
being targeted as a saleable product from the nodules.
Nickel
    USGS in 2024 estimated global reserves of over 130 million tons 
(with seabed resources not counted in the figures), with 26 million 
tonnes being in the friendly jurisdictions of Australia and Canada 
(USGS, 2025)
    An extensive global assessment of nickel mines shows that, given 
current data, land-based reserves and resources are sufficient to meet 
demand for over 100 years (at 2018 mining rates) (Mudd, 2022). 
Diversity of supply is provided by six countries holding 80% of global 
terrestrial nickel, and recent overproduction has led to a recent drop 
in historical five year prices (USGS, 2025). Action is needed, 
including improved management and biodiversity protection, to prevent 
ecological degradation and habitat loss accelerating (Tunnicliffe et 
al., 2025). In 2022, recycled nickel in all forms accounted for 
approximately 54% of apparent consumption (USGS, 2025).
Cobalt
    USGS estimates there are over 11 million tonnes of cobalt in 
reserves, and the International Energy Agency (2021) estimated that 
supply can meet projected demand through 2040 with current reserves and 
moderate investment (USGS, 2025).
    Most cobalt is sourced from the Democratic Republic of Congo (DRC) 
and is mostly a by-product of copper mining. Social conditions and 
environmental degradation need to be addressed (Earle, 2022; 
Tunnicliffe et al., 2025) but recycling could cut primary demand for 
cobalt by 35% by 2040 (Dominish et al., 2021). While other terrestrial 
sources expand, cobalt supply will remain tied to copper and nickel 
mining from which most cobalt is produced as a by-product. Solutions to 
address cobalt supply include increased efficiency and sustainability 
in metal extraction from mines, re-mining of tailings, new technologies 
in battery chemistry, and recycling and urban mining (Tunnicliffe et 
al., 2025).
Manganese
    Manganese reserve estimates are 1.7 million tonnes, with 
significant reserves in friendly jurisdictions, including 500,000 
tonnes in Australia (USGS, 2025). There are significant reserves in 
non-Russian occupied Ukraine, alongside two shuttered mines which as 
part of any U.S.-Ukraine deal would significantly add to global and 
U.S. production. (USGS, 2021). TMC themselves have noted ``We will be 
producing a novel manganese silicate product which does not yet have 
recognition in the marketplace with customers . . . manganese silicate 
is not a conventional mineral product and may require additional 
approvals for export and import from our processing facilities to our 
future customers.'' (The Metals Company, 2025).
Copper
    Global copper reserves in 2024 were estimated to be 980 million 
tons of copper--over 3.5 times those in 1970, despite the depletion by 
mining since then (USGC, 2025).
    In conclusion:

     Terrestrial reserves of the metals and minerals that are 
currently targeted for seabed mining--notably cobalt, copper, nickel 
and manganese--are already extensive.

     There is no evidence to suggest that deep-sea mining will 
be cost-competitive with terrestrial mining given such deep-water 
environments.

     Deep-sea mining will add a new, environmentally 
destructive, mining industry where there is no evidence it can be 
managed sustainably, particularly given current lack of knowledge, and 
copious evidence of the damage that we know it will cause.

     Better governance of terrestrial mining, a circular 
economy, including more reuse, recycling and repurposing, and 
technological advances are all well-known routes to meet the needs of 
the foreseeable future.

     Deep-sea mining is not a substitute for terrestrial 
mining; it will simply add to the biodiversity loss and challenges 
faced by the globe.

     For the most part, the large terrestrial mining industry 
is not involved in deep-sea mining. Instead, the industry is led by 
untested start-up companies, and has faced considerable economic 
challenges. Nautilus entered into liquidation in 2019 and Lockheed 
Martin sold its interests in nodules 2023 to Loke Minerals, which 
entered into bankruptcy this year.

    Question 6. Would mining minerals from the seafloor provide 
critical minerals supply chain security to the United States?

    Answer. No. Deep-sea mining is too speculative and unproven, too 
slow and too expensive, to alter mineral supply chain economics. 
Instead of a new, speculative and damaging industry, stockpiling metals 
from existing sources would provide some security of supply, as is 
recognized in the Strategic and Critical Minerals Stock Piling Act of 
1939.
    A recent article published in Nature (Alger et al., 2025) shows 
that:

        1. We already have sufficient terrestrial deposits of the 
        metals and mineral required for energy transitions and we do 
        not to augment supplies through deep-sea mining.

        2. The argument that deep-sea mining will avoid negative social 
        effects of terrestrial mining is false because deep-sea mining 
        will not replace terrestrial mining, and

        3. Deep-sea mining is a risky and unprofitable investment.

    Going further, the European Academies Science Advisory Council 
concluded in 2023 that ``The argument that deep-sea mining is essential 
to meet the demands for critical materials is thus contested and does 
not support the urgency with which exploitation of deep-sea minerals is 
being pursued. There remains much potential for policy to prioritise a 
circular economy, support innovation, and minimise continued dependence 
on the linear economy's focus on extracting virgin materials from 
nature.''
    Note that current deep-sea mining will not provide rare earth 
metals, which is the key critical mineral resource most frequently 
cited. (IEA, 2022)
    The main battleground in the global competition for critical 
minerals is not so much raw materials as midstream processing, an area 
where China dominates. (Zhou & Manberger, 2024). If security of supply 
is the key concern then the focus should be on ensuring the on-shoring 
or friend-shoring of processing capabilities.
    The Metals Company has claimed that NORI-D has a measured resource 
of 4 Mt of 1.4% nickel and 0.13% cobalt. If that translates to 56,000 
tonnes of nickel and 5,200 tonnes of cobalt, that pales into the 
comparison of 8 million tonnes of cobalt and 100 million tonnes of 
nickel in terrestrial sources. Deep-seabed mining at full scale is an 
untested technology. Deep sea explorer and entrepreneur Victor Vescovo 
has expressed skepticism about the prospects of deep-sea mining from a 
practical perspective: ``It is an act of God to do anything at 4,000 
meters. Everything breaks. Everything is difficult . . . You're talking 
about sustained heavy mining operations in depths that exceed the depth 
of the Titanic.'' He has observed that ``There are major technical 
risks mining 5,000 meters down with massive, rotating machinery under 
5,000 psi in freezing cold, corrosive saltwater. The technical 
difficulties of 24/7 commercial mining of the seafloor are massively 
underestimated. Deep-sea mining is also based on wildly over-optimistic 
financial assumptions made five years ago which no longer reflect 
current cost levels, interest rates, or likely . . . Even at full 
production rates, The Metals Company, for example, will only produce 
less than three percent of worldwide nickel production. Deep-sea mining 
will not materially affect terrestrial mining at all, as they would 
have their backers believe.''
    Question 7. Would mining minerals from the seafloor provide us with 
the minerals we need for national security?

    Answer. No: please see the response to question 6. The United 
States Executive Order of July 2025 \3\ defined critical minerals to 
mean minerals included in the ``Critical Minerals List'' published by 
the United States Geological Survey (USGS) pursuant to section 7002(c) 
of the Energy Act of 2020 (30 U.S.C. 1606) at 87 FR 10381, or any 
subsequent such list. Of the 2022 list of 50 minerals, \4\ only cobalt, 
nickel and manganese will be obtained from polymetallic nodules. Copper 
and manganese being relatively low value, deep-sea mining of 
polymetallic nodules largely is directed at obtaining cobalt and 
nickel.
---------------------------------------------------------------------------
    \3\ The White House. Ensuring National Security and Economic 
Resilience Through Section 232 Actions on Processed Critical Minerals 
and Derivative Products July 15, 2025. https://www.whitehouse.gov/
presidential-actions/2025/04/ensuring-national-security-and-economic-
resilience-through-section-232-actions-on-processed-critical-minerals-
and-derivative-products/
    \4\ Includes the following 50 minerals: Aluminum, antimony, 
arsenic, barite, beryllium, bismuth, cerium, cesium, chromium, cobalt, 
dysprosium, erbium, europium, fluorspar, gadolinium, gallium, 
germanium, graphite, hafnium, holmium, indium, iridium, lanthanum, 
lithium, lutetium, magnesium, manganese, neodymium, nickel, niobium, 
palladium, platinum, praseodymium, rhodium, rubidium, ruthenium, 
samarium, scandium, tantalum, tellurium, terbium, thulium, tin, 
titanium, tungsten, vanadium, ytterbium, yttrium, zinc, and zirconium.
---------------------------------------------------------------------------
    Rare earth minerals are not present in significant amounts in 
polymetallic nodules. For security and defence purposes the minerals in 
nodules would not be the most critical, where rare earth elements are 
prioritised, and are far less accessible by recycling (DoD, 2022; 
Vivoda et al., 2025).
    No country or company has successfully conducted large-scale 
commercial deep-sea mining. While deep-sea mining will have a `huge 
impact' in the marine environment, technologies like seafloor nodule 
collectors and riser systems are still experimental and unproven at 
scale (Zhang et al., 2024).
    It is naive to believe that even if successful, The Metals Company 
and similar companies would only provide minerals mined from the sea 
floor to the United States. They have already in 2021 announced that 
they concluded an offtake agreement with Glencore, a multinational 
commodity trading company headquartered in Switzerland for half of 
their nickel and copper production.
    There is no guarantee that minerals collected will be processed in 
the United States. For example, regarding minerals collected under 
DSHMRA, as The Metals Company is proposing, The Metals Company stated 
on their May 14, 2025 investor call that they will not be processing in 
the United States, nor do they have a timeline to do so. TMC's CFO 
Craig Shesky stated that both TMC and NOAA understand the ``reality 
that processing will occur outside the U.S. for some time.''
    The answers above and to Question 6 explain why deep-sea mining is 
not an economic or reliable source of deep-sea minerals, far less one 
on which the United States can rely for its national security.

                                 ______
                                 

    Dr. Gosar. I thank you, Mr. Currie. Now we recognize Dr. 
Peacock for his 5 minutes.

     STATEMENT OF THOMAS PEACOCK, PROFESSOR OF MECHANICAL 
 ENGINEERING, DIRECTOR, MASSACHUSETTS INSTITUTE OF TECHNOLOGY, 
                    CAMBRIDGE, MASSACHUSETTS

    Dr. Peacock. Chairman Gosar, Ranking Member Dexter, and 
members of the Subcommittee, thank you for the opportunity to 
talk today.
    I am a professor of mechanical engineering at MIT, where I 
lead the Environmental Dynamics Lab. For the past decade one of 
our focuses has been on the environmental impacts of deep-sea 
nodule mining. We do not take a position on deep-sea mining. 
Our mission is to perform objective research to inform 
discussions such as we are having today.
    Our research has looked closely at the behavior of sediment 
plumes, clouds of fine material stirred up from the seabed 
during mining operations. These plumes are critical to 
understand because they can create impacts beyond the immediate 
mining area. My research group at MIT and researchers around 
the world have made significant advances in understanding the 
potential impacts of deep-sea nodule mining activities. That 
research indicates that some of the proposed impacts of nodule 
mining may not be as severe as speculated. Some key findings 
are as follows.
    Test mining activities suspend roughly the top two inches 
of seabed sediment, not the 6 to 12 inches some had 
anticipated. Most of the disturbed material, between 92 and 98 
percent, either resettled within roughly 300 feet of the mining 
tracks or remained suspended close to the seabed, typically 
within 2 feet.
    Only a small fraction of sediment, about 2 to 8 percent, 
was lofted higher into the water column, reaching up to 15 feet 
in height, not hundreds of feet. These plumes traveled away in 
concentrations of a few milligrams per liter, roughly the 
equivalent of a grain of sand in a fishbowl.
    Tracks from experimental mining in the 1970s are still 
visible today, but there is minimal evidence of the sediment 
plume to the side of the tracks. While persistent biological 
effects have been observed, the populations of several 
organisms, including animals in and on the sediment and ranging 
from small to large sizes, have begun to reestablish themselves 
despite the physical changes to the sea floor.
    Across the Clarion-Clipperton Zone, recent estimates 
suggest between 6,000 and 8,000 species inhabit the region, of 
which fewer than 500 have been formally described.
    Broadly speaking, the region has at least two major zones 
to the east and west, but within the CCZ there is variability 
that affects the seafloor life. Specific areas would need to be 
protected, an approach the International Seabed Authority has 
been developing following the advice of scientific experts.
    Short-term pilot-scale trials have advanced our 
understanding, providing a starting point from which to 
research and assess the long-term impacts of proposed 
commercial-scale operations. To proceed responsibly, deep-sea 
mining would have to advance step by step. This would support 
reliable predictions of the environmental impacts of 
commercial-scale deep-sea mining, addressing critical concerns 
such as biodiversity loss and ecosystem function, and 
environmental monitoring would inform any necessary decisions 
to stop or amend operations.
    Achieving this will require technical innovation. While 
current sensors are capable of measuring key environmental 
parameters, they can be expensive and not yet suited for the 
large spatial scales and long-time scales involved. This will 
require two things: affordable sensors and platforms such as 
autonomous vehicles to deploy them, energy sources and subsea 
communication technologies to extend their reach.
    Even with these advances, monitoring will inevitably be 
challenged by the vast scales of the ocean. Emerging 
computational systems, especially those enhanced by GPU-based 
processing and AI, can dramatically improve our ability to 
improve our performance simulations, analyze data, and make 
informed decisions.
    The U.S. should play an active role in the development and 
use of technology, sensors, and computational systems to inform 
deep-sea mining, but currently it is not. During the 1970s and 
early 1980s, the U.S. was a global leader in deep-sea mining 
research and activities, exemplified by the NOAA Deep Ocean 
Mining Environmental Study, or DOMES Project. Over the past 30 
years, U.S. Government funding for deep-sea mining research has 
been absent.
    Meanwhile, China is surpassing the efforts of every other 
Nation in conducting technology trials, the European Union has 
invested over $50 million in three deep-sea mining research 
programs, Japan has launched a $100 million initiative focused 
on nodule mining within its Exclusive Economic Zone, and the 
full extent of investment by countries like China and India is 
not publicly known but likely exceeds these figures many times 
over. Without strategic investment, the U.S. risks falling 
behind.
    Fortunately, the U.S. retains tremendous strength in deep 
ocean science and engineering. NOAA, with its experience and 
capabilities, is well positioned to lead U.S.-based efforts. 
But the U.S. will need to invest significantly and soon, or we 
will be left to rely on the learnings and technological 
advancements made by other countries. That will make it harder 
for the U.S. to engage in this nascent arena, and to ensure 
that any future deep-sea mining activities are informed by the 
best science, the best monitoring capabilities, and the 
strongest protections.
    Thank you for your time, and I look forward to your 
questions.

    [The prepared statement of Dr. Peacock follows:]
Prepared Statement of Professor Thomas Peacock Professor of Mechanical 
   Engineering Fellow of the American Physical Society Massachusetts 
                        Institute of Technology

    Good morning, Chairman Gosar, Ranking Member Dexter, and Members of 
the Subcommittee. Thank you for the opportunity to speak to you today.
    I am a Professor of Mechanical Engineering at MIT. Ten years ago, I 
directed my research group's activities to study human activities in 
the ocean, with one focus being deep sea mining and its potential 
impacts. We do not take a position on deep-sea mining; our mission is 
to perform objective research to inform discussions such as we are 
having today.
    My group, the Environmental Dynamics Lab, or ENDLab, has been the 
only U.S.-based team working on sediment plume disturbances created by 
deep-sea mining. A sediment plume is like the dust cloud that is 
stirred up behind a vehicle driving down a dusty road. Deep sea mining 
activities similarly stir up sediment from the ocean floor, and that 
sediment can be carried away from the mining area by ocean currents. 
This is important because of a sediment plume's potential to create 
impacts away from, and on a larger scale than, the direct mining site.
    We are the only team to have participated in both of the deep-sea 
nodule mining trials in 2021 and 2022 in the Clarion-Clipperton Zone of 
the Pacific Ocean. We have published 11 papers in peer-reviewed 
journals on the topic. I am a member of the International Seabed 
Authority (ISA) Expert Working Group on Thresholds, and an advisory 
board member for the EU's TRIDENT project to research monitoring and 
modeling systems for deep-sea mining.
    In recent years, my research group at MIT and researchers around 
the world have made significant advances in understanding the potential 
impacts of nodule mining activities. The key findings indicate that 
some of the impacts of nodule mining may not be as speculated. Some key 
findings are as follows:

     For the technologies tested in 2021 and 2022, roughly the 
            first 2 inches of ocean floor sediment was suspended into 
            the water column, which is less than the 6-to-12 inches 
            that has been hypothesized.

     Rather than all the suspended sediment forming a plume, 
            92-98% of the sediment was either deposited on the seabed 
            within around 300 feet of the mining tracks or remained 
            suspended in the water column less than 2 feet above the 
            seabed.

     The remaining 2-8% of sediment was suspended up to around 
            15 feet above the seabed, which is less than the hundreds 
            of feet above the seabed that had been conjectured. It is 
            carried away from the mining site by ocean currents in 
            concentrations of a few milligrams per liter, which is 
            roughly equivalent to a grain of sand in a fishbowl.

     Tracks in the seabed from mining trials in the 1970's are 
            still evident today, but there is minimal evidence of the 
            sediment plume to the side of the tracks. While persistent 
            biological effects have been observed, the populations of 
            several organisms, including animals in and on the 
            sediment, and ranging from small to large sizes, have begun 
            to re--establish themselves despite the physical changes to 
            the seafloor.

     Across the Clarion-Clipperton Zone, recent estimates put 
            the total number of biological species between 6,000 and 
            8,000, only 438 of which have scientific names. Broadly 
            speaking the region has at least two major zones to the 
            east and west, but there is finer scale variability that 
            affects the seafloor life. Therefore, a patchwork of 
            protected areas is needed for effective environmental 
            management. This will entail both putting some large areas 
            off-limits to mining, and protecting some smaller sections 
            within areas that are otherwise open to mining. Such a 
            multiscale approach has been developed by leading 
            scientists for the ISA.

    Recent field trials conducted by contractors in 2021 and 2022, 
which were short-term and pilot-scale, rank among the largest deep-sea 
monitoring efforts to date, providing a foundation for assessing the 
long-term impacts of commercial-scale operations. These efforts aim to 
reduce uncertainty and support informed regulatory decision-making for 
proposed deep-sea mining operations. While research to date has been 
valuable and resolved misconceptions, as I described previously, much 
still remains to be learned about the consequences of scaling up to 
commercial operations.
    Deep-sea mining should only be permitted to move ahead to 
commercial scales in a step-by-step fashion as the tools and methods 
required to assess its impacts are further developed and deployed, and 
learnings obtained. This would allow for essential studies related to 
biodiversity loss and ecosystem function, to understand at what scale 
mining in particular areas could be ecologically viable. Furthermore, 
this would support reliable predictions of the impacts of commercial 
scale deep-sea mining; guide the creation and enforcement of a strong, 
effective regulatory framework; and inform any necessary adjustments or 
critical decisions.
    To accomplish this, further advances in sensor technologies and 
computational modeling are needed. Existing sensors are generally 
capable, but can also be expensive. Dedicated programs are needed to 
develop the next generation of cost-effective sensors, platforms such 
as autonomous vehicles that can host the sensors, energy sources to 
power the sensors and platforms, and subsea communication tools. This 
will make monitoring more capable of operating at the scales required, 
across hundreds of miles and over multiple years.
    Even with these advances, monitoring will inevitably be challenged 
by the vast scales and extreme depths of the ocean. Advanced modeling 
systems will be needed to analyze the data and to enable prediction, 
situational awareness, adaptive management, and effective permitting 
and governance. Emerging computational models, based around GPU 
processers and enhanced by AI-assisted algorithms, can outperform 
legacy systems and help derive learnings from sensor data, producing 
significant gains in insight, confidence, transparency, and trust.
    The U.S. should play an active role in the development and 
operation of technologies, sensors and computational systems for deep-
sea mining, but currently it is not. In the 1970's through the mid 
1980's, the U.S. was the global leader--a pioneering example being the 
NOAA Deep Ocean Mining Environmental Study (DOMES) project. Over the 
past 30 years, however, research funding from the U.S. government has 
been absent. Meanwhile, China is conducting technology trials at a rate 
matching every other nation combined. The European Union has funded 
three projects to the tune of $50 million to develop resource 
assessment and monitoring technologies. And in Japan, a $100-million 
initiative is taking place to test nodule technology in its Exclusive 
Economic Zone. Data is not readily available on funding for programs in 
countries such as China and India, but over recent years the amounts 
invested are likely much greater than what is being spent by Europe and 
Japan.
    Without strategic investment, the U.S. risks falling behind. With 
its immense talent pool in deep ocean operations, however, the U.S. 
could play a leading role in advancing this critical work.
    NOAA, with its experience and capabilities, as well as its access 
to Federally Funded Research and Development Centers across federal 
agencies, is well positioned to lead U.S.-based efforts. But the U.S. 
will need to invest significantly and soon, or rely on the learnings 
and technological advancements made by other countries. That will make 
it harder for the U.S. to engage in the nascent arena of deep-sea 
mining, and more challenging to ensure that any future deep-sea mining 
activities are informed by the best science, the best monitoring 
capabilities, and the strongest protections.
    Thank you again for the opportunity to provide the Committee with 
information on this topic. I am happy to answer any questions.

                                 ______
                                 

 Questions Submitted for the Record to Prof. Thomas Peacock, Professor 
    of Mechanical Engineering and Director, Environmental Dynamics 
           Laboratory, Massachusetts Institute of Technology

              Questions Submitted by Representative Dexter

    Question 1. In your testimony, you mentioned there are only 6,000-
8,000 species in the Clarion-Clipperton Zone. Other studies specify 
that this figure is specific to the benthic metazoan species, not the 
entirety of species in the CCZ. What do you believe to be the full 
measure of biodiversity in the CCZ?

    Answer. The estimates cited in my testimony for benthic metazoan 
species, which make up the bulk of the biomass found in the CCZ, come 
from the following publication [1]. For additional questions about 
biodiversity, I recommend reaching out to experts such as Prof. Daniel 
Jones (National Oceanography Center, UK; [email protected]), Dr. Adrian 
Glover (Natural History Museum, UK; [email protected]), and Dr. Bryan 
O'Malley (USA; [email protected]).

    Question 2. TMC maintains that the Digital Twin will be a core 
component of the company's Adaptive Management System which will aim 
``to ensure operations remain within environmental impact thresholds.'' 
Given the dearth of data on deep-sea organisms and processes, as well 
as data on plumes and their impacts, how can the Digital Twin reliably 
protect deep sea organisms and ocean ecological functions?

    Answer. The role of a digital twin is not to identify what the 
thresholds should be, but to produce the information needed to evaluate 
whether a threshold would be crossed under certain mining conditions.
    An example of a digital twin capability is to perform physical 
modeling of the sediment plumes--a topic for which there have been 
significant advances in understanding over the past 5 years--and 
identify when and where mining activity would exceed environmental 
impact thresholds, of which no agreed standard currently exists.
    An effective digital twin should integrate the latest developments 
in modeling and thresholds in order to capture the extent of impact of 
a mining operation. It is recommended that any digital twins used for 
monitoring deep sea mining impacts utilize modern computing approaches 
such as graphical processing units (GPUs) and artificial intelligence 
(AI), as these will outperform legacy modeling systems. Ultimately, a 
digital twin should have the capability to be queried and answer 
whatever environmental impact question is posed to it.
    Without environmental impact thresholds, the starting point for a 
digital twin is to identify where environmental metrics (e.g., 
suspended sediment concentration) approach natural levels. This 
furthermore requires parcels of the sea floor to be set aside and 
undisturbed in order to protect deep sea organisms and ocean ecological 
functions.
    A number of new scientific studies of the technology trials carried 
out in the CCZ by Global Sea Mineral Resources (GSR) in 2021 and The 
Metals Company (TMC) in 2022 are increasing our knowledge, particularly 
of the impacts in regions directly mined and those impacted by sediment 
plumes. Results from these studies have been presented in public 
scientific conferences but many of the papers are not yet published.
    Overall, a precautionary approach to adaptive management is 
recommended.

    Question 3. Is it accurate to say that little is known about the 
fate of the fine particle or dissolved components of the benthic 
sediment plume that could rise some distance in the water column in a 
DSM scenario? What do we know about how far these components will 
travel and the ecotoxicology associated with it?

    Answer. A great deal has been learned from the two recent mining 
trials in the CCZ. In our peer reviewed publications, we provide 
estimates for horizontal and vertical extents of sediment plumes based 
on operational parameters and background conditions. We also provide 
estimates of how far these sediment plumes travel at specific impact 
thresholds. Some insight into the fate of dissolved components can be 
gleaned from the results for very fine particles. Three of our relevant 
publications are [2, 3, 4].
    My research group does not study the ecotoxicology of sediment 
plumes, but relevant researchers who have either led or been involved 
in recent expeditions include Prof. Daniel Jones (National Oceanography 
Center, UK; [email protected]) and Dr. Katja Schmidt (BGR, 
[email protected]). The CCZ is already among the most well-studied 
areas of the deep seabed, but increased U.S. investment in research to 
characterize sediment plumes and their impacts would further improve 
our understanding.

    Question 4. Independent oceanographic modelling predicts the mid 
water discharge plume may travel from the TMC Tonga license to the 
waters of Kiribati and Hawaii over a 3-month period. This prediction is 
based on accredited oceanographic models using the best publicly 
available data. What specific aspects of the modelling as described in 
the technical notes supporting the Blue Peril visual investigation do 
you disagree with?

    Answer. To properly evaluate any modeling approach and its results, 
the authors of a scientific study should submit a manuscript to a 
respected scientific journal to undergo peer-review, as consistent with 
established scientific practice. To my knowledge, the modeling approach 
used by the Blue Peril visual investigation has not undergone peer 
review.
    It is widely understood that a slowly settling particle can travel 
a distance of 1000 km in the ocean; we state this in our 2021 study of 
midwater plumes [2]: ``Extent of impact of deep-sea nodule mining 
midwater plumes is influenced by sediment loading, turbulence and 
thresholds''. The same paper also makes the point--in the title, 
abstract and conclusions--that for a plume to cause environmental 
impact, there has to be a sufficient concentration of sediment; the 
existence of a single particle somewhere does not constitute a plume. 
By analogy, when an air freshener is sprayed, someone standing 10 feet 
away may clearly sense it, but someone standing 100 feet away won't 
detect it at all, even though some of the air freshener molecules 
technically traveled that distance.
    The Blue Peril video and accompanying paper, for which the modeling 
was undertaken by Austides Consulting, state that a given area of the 
ocean could be expected to be ``impacted'' by sediment plumes. But 
neither the Blue Peril video nor the accompanying paper disclose the 
values of any impact thresholds they use, such as suspended sediment 
particle concentrations or sediment deposition rates. Without 
disclosing the impact thresholds that are being used, the Blue Peril 
simulation does not provide enough information to be useful for 
evaluating the environmental impact of a sediment plume.
    Two of our publications [3,4], both cited by the Blue Peril paper, 
predict the distances at which different thresholds of sediment plume 
concentrations can be detected coming from collector plumes on the 
seabed and from midwater plumes. Our studies assume that the normal, 
background level of suspended sediment without any kind of disturbance 
is 10 micrograms (mg) of sediment per liter (L) of water, which is 
roughly equivalent to a pinch of sand in an Olympic sized swimming 
pool.
    For seabed collector sites, our studies indicate that sediment 
plumes can be detected in concentrations of 1,000 mg/L (100 times the 
normal concentration and roughly equivalent to \1/4\ cup of sand in an 
Olympic swimming pool) at a distance of 1 km from the collector site, 
100 mg/L (10 times the normal concentration and roughly equivalent to a 
teaspoon of sand in an Olympic swimming pool) at a distance of 5 km 
from the collector site, and the concentration of suspended sediment 
returns to the background level of 10 mg/L at a distance of 17 km from 
the collector site.
    For midwater plumes, our studies indicate that the sediment plumes 
can be detected in concentrations of 1,000 mg/L at a distance of 4 km 
from the plume origination site, 100 mg/L at a distance of 20 km from 
the plume origination site, and the concentration of suspended sediment 
returns to the normal, background level of 10 mg/L at a distance of 97 
km from the plume origination site. These midwater plume predictions 
are consistent with additional simulations conducted using an 
independent modeling system, as described in [2]. Note that not all 
deep-sea mining companies are proposing to create a midwater plume.
    Our results do not support the claim that a midwater plume or 
collector plume at the TMC Tonga license site would produce a 
measurable impact in the waters of Kiribati or Hawaii.

    Question 5. The ISA set up an international expert group that has 
been tasked with providing inputs in three main areas of environmental 
concern: (a) toxicity, (b) turbidity and settling of resuspended 
sediments, and ( c) underwater noise and light pollution. Your 
expertise is in sediments, which is one component of the environmental 
thresholds being set by the ISA How does your testimony differ from the 
consensus opinion of the IEG with respect to sediments and why are your 
predictions better?

    Answer. The ISA's Intersessional Expert Group (IEG) and its 
subgroup on turbidity have yet to release any consensus findings, and 
thus I have no basis to compare my testimony. The contributions of my 
research group are part of the evidence base being created by the 
international scientific community and are being incorporated into the 
IEG's findings.

    Question 6. You are listed as a co-author on a long-term study 
published in Nature in March of this year. The paper concludes: ``our 
results show that mining impacts in the abyssal ocean will be 
persistent over at least decadal timeframes and communities will remain 
altered in directly disturbed areas, despite some recolonisation.'' How 
do you reconcile that finding with your testimony that seemed to 
downplay the impact caused by seabed mining?

    Answer. The findings in the study published in Nature in March of 
this year [5] are consistent with my testimony, in which I stated 
persistent biological effects have been observed from mining 
experiments conducted in the 1970s. One goal of my testimony was to 
enumerate some of the impacts caused by deep seabed mining, 
specifically to characterize the current state of scientific 
understanding around sediment plumes and to contrast that with claims 
made about sediment plumes that are not based on sound scientific 
evidence. My testimony was reviewed by several lead authors of the 
Nature paper and was approved by them.

    Question 7. Is it possible to remediate environmental damage in the 
deep sea? If so, what kind of damage and over what time frame? Is there 
damage that cannot be remediated? Please be specific about damage to 
species, sediments, water columns, noise, light, carbon cycle, and 
other ocean processes.

    Answer. These are areas of ongoing scientific research. My 
expertise and ongoing research projects are focused on characterizing 
sediment plumes. We make our findings available to policymakers for 
incorporation into the complex decisions surrounding the governance of 
deep seabed mining.
    Other research groups are better positioned to provide 
authoritative inputs on the other topics in question. For example, 
there are ongoing studies by the JPI-Oceans Mining Impact 2 project 
investigating the ecosystem impacts of deploying artificial, inert 
nodules to recreate the physical conditions that preceded the 
collection of polymetallic nodules [6]. For further information on 
this, I recommend reaching out to Dr. Sabine Gollner (NIOZ, 
[email protected]).
    Expert assessment suggests that other forms of mitigation, such as 
set-aside areas and impact minimization through engineering design, may 
be more efficient management strategies than remediation [7,8]. In 
fact, the approach of deliberately setting aside parcels in the CCZ is 
already the norm. Approximately 2 million sq. km. (about 30% of the 
area of the CCZ) has already been set aside for protection under the 
ISA's CCZ Environmental Management Plan as a network of 13 ``areas of 
particular environmental interest'' (APEIs). The design and designation 
of the APEI network started over 20 years ago based on a series of 
scientific workshops (led initially by U.S. scientists) and has been 
refined on several occasions. To date, all entities granted exploration 
contracts by the ISA have followed ISA guidelines on the protection of 
these regions.
    For matters related to carbon sequestration, the following 
publication provides an assessment of the risks [9], determining them 
to be `trivial'. For further details, I recommend reaching out to Prof. 
Beth Orcutt (Bigelow Laboratory for Ocean Sciences; 
[email protected]) and Dr. Bryan O'Malley (USA; [email protected]).
    As I stated in my testimony and my remarks, federally-funded 
research programs that invest in our understanding of the impacts of 
deep seabed mining on biodiversity and other ocean processes are 
important and necessary.
References
    1. Rabone, Muriel, et al. ``How many metazoan species live in the 
world's largest mineral exploration region?'' Current biology 33.12 
(2023): 2383-2396.
    2. Munoz-Royo, Carlos, et al. ``Extent of impact of deep-sea nodule 
mining midwater plumes is influenced by sediment loading, turbulence 
and thresholds.'' Communications Earth & Environment 2.1 (2021): 148.
    3. Ouillon, Raphael, et al. ``Advection-diffusion-settling of deep-
sea mining sediment plumes. Part 1: Midwater plumes.'' Flow 2 (2022): 
E22.
    4. Ouillon, Raphael, et al. ``Advection--diffusion settling of 
deep-sea mining sediment plumes. Part 2. Collector plumes.'' Flow 2 
(2022): E23.
    5. Jones, Daniel OB, et al. ``Long-term impact and biological 
recovery in a deep-sea mining track.'' Nature (2025): 1-3.
    6. Gollner, Sabine, et al. ``Restoration experiments in 
polymetallic nodule areas.'' Integrated Environmental Assessment and 
Management 18.3 (2021): 682-696.
    7. Niner, Holly J., et al. ``Deep-sea mining with no net loss of 
biodiversity--an impossible aim.'' Frontiers in Marine Science 5 
(2018): 53.
    8. Cuvelier, Daphne, et al. ``Potential mitigation and restoration 
actions in ecosystems impacted by seabed mining.'' Frontiers in Marine 
Science 5 (2018): 467.
    9. Orcutt, Beth N., et al. ``Impacts of deep-sea mining on 
microbial ecosystem services.'' Limnology and Oceanography 65.7(2020): 
1489-1510.
                                 ______
                                 

    Dr. Gosar. I thank you, Dr. Peacock.
    The gentleman from Arkansas, the Chairman for the Full 
Committee, is now recognized for 5 minutes.

  STATEMENT OF THE HON. BRUCE WESTERMAN, A REPRESENTATIVE IN 
              CONGRESS FROM THE STATE OF ARKANSAS

    Mr. Westerman. Thank you, Chairman Gosar, and thank you to 
the witnesses for being here today.
    You know, by now our country's reliance on critical and 
other hardrock minerals is widely known. These minerals are 
essential to America's national security, to our economy, to 
our energy infrastructure, and to many other things. This 
Committee has repeatedly emphasized the importance of these 
minerals and of securing American mineral supply chains.
    Although the United States is blessed with some of the most 
abundant mineral deposits, our abilities to discover, extract, 
and process critical and other hardrock minerals has declined 
for decades. Not only have we closed refineries and processing 
facilities, but we have also choked mineral mining operations 
with red tape. At the same time, we have failed to effectively 
combat the lawfare waged by radical non-profit groups who are 
determined to delay and terminate critical and crucial mineral 
projects within our borders.
    Fortunately, we have championed an all-of-the-above 
approach to mineral exploration and extraction policy. This 
approach includes streamlining permitting for terrestrial 
mining projects and encouraging American companies to continue 
investing in emerging technologies which even includes space 
mining. And today we are here to better understand the 
possibilities of how the minerals readily available on the sea 
floor can be extracted in a manner that is both efficient and 
environmentally friendly.
    In fact, just last week President Trump signed an executive 
order streamlining the process through which American companies 
can work to identify and extract minerals like cobalt, copper, 
manganese, and nickel from both American and international 
waters. These seabed minerals are most often found in rocks or 
polymetallic nodules that line the ocean's floor. These nodules 
are estimated to exist worldwide in numbers as great as 200 
trillion tons, and have the ability to produce the raw 
materials necessary for batteries, electronics, and steel.
    While venturing to the cold, dark depths of the sea floor 
to collect critical minerals sounds like something from a 
science fiction movie, the United States has possessed the 
technology and knowledge necessary for seabed mining since at 
least the 1970s. Today American companies are leading the 
charge to not only utilize these capabilities, but also develop 
new and exciting technologies and methods to harvest 
polymetallic nodules from the sea floor in a manner that is 
both more efficient and friendly to the marine environment than 
was ever imagined.
    Frankly, other adversarial nations like China have eyed 
seabed mining without serious competition from the United 
States for far too long. We cannot continue to rely on China 
for the minerals we currently use, and we certainly cannot 
allow China to capture the market for offshore resources. This 
path would only continue to impose a never-ending threat of 
mineral supply chain collapse. Only by unleashing American 
offshore critical minerals and natural resources can we secure 
our own critical mineral supply chains. We can revolutionize 
energy production. We can strengthen our national security, and 
at the same time we can grow our economy.
    I look forward to a robust discussion on how we can ensure 
efficient development of seabed mineral resources. I appreciate 
your expertise and for being here today to discuss this 
important issue.
    And I will say there is a lot going on in Congress this 
week. Hopefully, more members will come in because this is such 
a critical discussion that we need to have. But I can assure 
you that people are very busy with other committee markups and 
hearings taking place, but that doesn't minimize the importance 
of what we are here to discuss today.
    Thank you, Mr. Chairman, I yield back.

    Dr. Gosar. I thank the gentleman. We are now going to move 
into the questions from the members. I will recognize the 
members as we go down the road. Now we are going to recognize 
Mr. Case from Hawaii for his 5 minutes.
    Mr. Case. Thank you very much, Mr. Chair and Ranking 
Member, and I truly appreciate your courtesy in allowing me to 
rejoin the Natural Resources Committee for this critical 
hearing.
    And it should come as no surprise that my concern is for 
our marine environment. I have introduced two pieces of 
legislation that would affirmatively place a moratorium on any 
domestic or international deep-sea mining until we know exactly 
what is going on in our oceans. So no surprises where I am 
coming from on this.
    Mr. Barron, back a couple of years ago, when you were 
questioned about concerns with environmental impacts of deep-
sea mining, you stated in the press that where you wanted to 
mine is a ``marine desert.'' ``If you measure the amount of 
life there, it is measured in grams per square meter. There are 
no trees, no plants at all.'' You also said that your mechanism 
for deep-sea mining is blasting a jet of water to the nodule to 
lift it up. ``In this part of the ocean floor there isn't much 
to impact to begin with.'' Do you stand by those statements?
    Mr. Barron. Thank you for the question. Yes, I do.
    Mr. Case. OK. And what is the basis, the scientific 
environmental basis for your statements that basically there 
won't be any particular impacts from--can you point to a 
specific study? Like, you held up a bunch of paper there. Is 
that from the original Act back in 1980, or is that more 
recent? Or what is the basis for that statement?
    Mr. Barron. Well, I think it begins with the fact that if 
we think about all of the landscapes on our planet, and if we 
were to draw a bar chart and on the right hand side you would 
have an environment that has the most life that could be 
impacted, that would be called our tropical forests.
    Mr. Case. Yes. What I am asking for is, do you cite a 
specific scientific study?
    Mr. Barron. Yes.
    Mr. Case. And where is that study for the basis for your 
statement? That is what I am getting at.
    Mr. Barron. Yes, and I will get to that in a moment.
    Mr. Case. But I have a limited amount of time, so what I am 
doing is I am asking a very specific question. What is the 
scientific basis for your statement?
    Mr. Barron. Well, I will draw you to my testimonial, where 
we cite many of the studies that have been carried out. And in 
fact, just recently, of course, I heard people refer to the 
DOMES study that was carried out from the trials that were done 
in the 1970s.
    Mr. Case. OK.
    Mr. Barron. Our own studies, we revisited the area where we 
had collected nodules from in 2022. And when we went back a 
year later, we found that the tracks had recovered 30 percent 
to pre-disturbance levels, and that is one----
    Mr. Case. OK, so are those your studies, Mr. Barron?
    Mr. Barron. Well, they are studies we fund----
    Mr. Case. Your company's studies?
    Mr. Barron. They are studies we fund.
    Mr. Case. OK. They are studies you fund. And as far as the 
underlying environmental impact statement that you referenced, 
that was back to the 1970s, which was related to the passage of 
the law in 1980 that we are relying upon today for our 
environmental protections. Is that correct? Under the executive 
order.
    Mr. Barron. The trials were done in 1979. And of course, 
the study that went back last year was a broad range of 
funders, all independent, who went back on a study that was 
published only 2 weeks ago, I believe.
    Mr. Case. OK. All right.
    So I have read that executive order. And first of all, I 
see absolutely no reference to environmental protection 
whatsoever in the President's executive order. The word 
``environment'' is mentioned once, and it is kind of a 
throwaway. It is a reference to a 1980 law which we propose to 
proceed under. Obviously, a lot has changed, I believe, since 
1980. So Mr. Currie, let me just focus a couple of questions on 
you because, fundamentally, I don't think that we have those 
studies in hand right now.
    First of all, it strikes me that we are only studying one 
kind of extraction. So, for example, a--plucking a module--a 
nodule off of the sea floor. The videos I have seen show a big, 
old clamshell dredge coming down, impacting--going down deeper 
than two inches, by the way--and sucking up a bunch of the 
ocean floor. We also have the technique which is fundamentally 
strip-mining the ocean floor and dragging stuff across it. Is 
there any limitation on what kind of mining we would be able to 
do under this executive order that you know of, or are we just 
focusing our studies only on one particular type of least 
intrusive impact?
    Mr. Currie. Yes. I would not call it least intrusive 
impact. I think what--the kind of damage that you talk about is 
clear. In my opening remarks I talked about the damage to the 
nodules. We know the nodules themselves have life on them. We 
know between 50 and 70 percent of deep-sea life are dependent 
on the nodules. We know that the deep-sea plume will smother 
the life that is down there.
    And it really is very deeply concerning to hear Mr. Barron 
make such clearly scientifically incorrect statements, when 
this is the company that proposes to do the seabed mining in 
the deep sea 5,000 meters deep, far away from any regulatory 
authorities, far away from any----
    Mr. Case. OK.
    Mr. Currie [continuing]. Any controls.
    Mr. Case. I am not going to overstep my welcome in this 
Committee, and my time is up.
    Dr. Gosar. We will do a second round, if you would like to 
stay around.
    Mr. Case. Thank you so much, and I would ask for a consent 
to be able to submit written records--sorry, written questions.
    Dr. Gosar. Without objection.
    Mr. Case. Thank you so much.
    Dr. Gosar. So ordered. I appreciate it.
    Mr. Case. OK.
    Dr. Gosar. The gentlewoman from Oregon is recognized for 
her 5 minutes.
    Dr. Dexter. Thank you, Mr. Chair.
    Mr. Barron, Lockheed Martin, a U.S. company with a market 
cap of about $100 billion and extensive experience in material 
needs for the defense industry, recently quit their investment 
in seabed mining and sold their seabed resources subsidiary. 
The shipping giant Maersk also recently dropped its investment 
in your company, and leading tech and EV companies--there is 
several of them--have joined calls for a moratorium. What do 
you know that these major companies didn't about the 
profitability of this industry or the necessity of extracting 
critical minerals from the sea floor for civilian and defense 
enterprises?
    Mr. Barron. Thank you. Well, Lockheed Martin still have 
exploration licenses under NOAA regulations. They did sell 
their licenses that they had been granted through the 
International Seabed Authority because of the uncertainty of 
that regulator being able to put in place the mining code.
    In answer to your question about what do I know that those 
car companies know: a lot, because my company, The Metals 
Company, has spent hundreds of millions of dollars funding 
independent scientific organizations to carry out those 
environmental studies. And not one single name of those 
companies that you read out, those car companies, have ever 
contacted us to ask, ``What is your evidence?'' They claim to 
care a lot about the environment, and I am sure if they really 
did, they would want to hear both sides.
    What I can tell you is that the American car industry has 
not done that virtue signaling by saying, ``We will join that 
moratorium.''
    Dr. Dexter. Understood. However, if it was a good 
investment, they don't need to necessarily know the science. 
They will know that somebody is showing a profit.
    So given that The Metals Company has yet to demonstrate a 
commercially viable deep-sea mining operation, how can you 
assure U.S. regulators and taxpayers that sponsoring your 
permit is not simply subsidizing a high-risk foreign startup 
with little to no guaranteed return?
    Mr. Barron. America has an urgent need for critical 
minerals. America has a need to re-industrialize. It needs to 
secure these metals.
    The beauty of these nodules, of course, is that they are 
much more metal-rich compared to land-based alternatives, and 
that has a massive impact on the economics. The people that 
speculate about economic viability tend to be the activists who 
oppose the industry.
    Dr. Dexter. It is interesting that China has moved away 
from cobalt, which, obviously, is rich in here, and they have 
every reason to double down on that with their rich resources 
that they have available. So I would consider that when we are 
making those investments.
    Mr. Currie, thank you for coming. There is a lot of focus 
on resource exploration in the development of extraction 
technology on the sea floor. But recent studies suggest that 
the infrastructure needed to process polymetallic nodules is 
still uncertain and untested, and that no companies have 
developed plans for processing. Is the seabed mining industry 
prepared to process all the nodules they claim they will bring 
to the surface?
    Mr. Currie. That is a very good question, Member, because 
the crucial issue here is, frankly, processing. China dominates 
the market with these metals, particularly cobalt and nickel, 
because they dominate the processing.
    Processing is a very labor-intensive activity, very 
environmentally harmful activity, very difficult to do it. 
China has been doing it for many decades. And really, that is 
the answer to your question of, you know, what does the U.S. do 
about access to minerals. It is not as if China is digging up 
the minerals from its own land and dominating the market in 
that way. It is doing it firstly because of the processing, 
secondly because of the access to minerals it has through 
contracts and foreign direct investment. And there is no reason 
to believe it wouldn't do the same thing with deep-sea mining.
    And I also note, with respect to your question to Mr. 
Barron, that Loke Minerals, who did purchase the shares in UK 
Seabed Resources, has gone bankrupt recently, just to add one 
more list of companies that have gone bankrupt during the 
attempts to seabed mine. Thank you.
    Dr. Dexter. Thank you. We are running short on time, but I 
did want to ask, The Metals Company has initiated a process to 
acquire licenses and permits to extract minerals from the ocean 
floor through the United States. These permits, and this is to 
you, Mr. Currie, these permits, which are supported by a recent 
executive order made by President Trump, risk violating 
international agreements governing ocean activities. Based on 
your experience with permitting at the International Seabed 
Authority, will major cuts to staff at BOEM and NOAA make it 
easier or harder for them to issue these permits?
    Mr. Currie. Issuing these permits will be an 
extraordinarily difficult issue. We are dealing with an area 
5,000 meters deep, in the area beyond national jurisdiction. 
This is why the International Seabed Authority has had such 
difficulty in finalizing the regulations. It is a difficult 
thing to do. There are international legal complexities, there 
is questions about the actual title to the area that Mr. Barron 
would want to mine. There is questions about the access title 
to the minerals because the law of the Sea Convention is very, 
very clear no one country may expropriate minerals from the 
deep sea bed.
    And so--and there is a host of questions. The mining 
company that would undertake the physical mining for The Metals 
Company, Allseas, is a Swiss company. Switzerland is not going 
to allow their company to breach international law. Nauru must 
be deeply unhappy with what is happening there. You know, Nauru 
faces the twin horns of a dilemma. Either get paid nothing for 
the minerals that are brought up by The Metals Company, or does 
get paid something and it participates in the breach of 
international law.
    And there also is a question about the Jones Act. There is 
a host of very, very difficult questions, which, frankly, I 
don't envy the few remaining staffers at NOAA to have to deal 
with.
    Dr. Dexter. Thank you.
    Thank you, Mr. Chair.
    Dr. Gosar. Well, thank you. You are welcome. The 
gentleman--the full Committee Chair, Mr. Westerman, is 
recognized for his 5 minutes.
    Mr. Westerman. Thank you, Chairman Gosar.
    Mr. Gunasekara, I hope I got that right. Thank you for 
being here. I am excited to learn more about the work that you 
and your company are doing.
    And you recently submitted a formal request to the Bureau 
of Ocean Energy Management to begin the process of leasing 
harvesting rights within the U.S. Exclusive Economic Zone off 
the coast of American Samoa. Why did you choose to initiate the 
process with BOEM at this time?
    Mr. Gunasekara. Well, the U.S. critically needs these 
metals. I think it is very clear that China controls the vast 
majority of critical minerals. And yet, in our own Federal 
waters, we have huge quantities. And fortunately, Congress 
passed a law that allows U.S. entities like ourselves to 
request the starting of this process. So we very much would 
like the Administration to use the authority that Congress has 
given it to start the process so that we can actually 
ultimately get to the point where we can extract these minerals 
from the deep ocean around the territory of American Samoa.
    I want to be clear, though. We want to do this in an 
environmentally sensitive manner. We don't expect to be able to 
do it without an environmental impact statement and being very 
clear what is the impact. But in our view, we critically need 
an independent source of these minerals. These minerals are in 
our own waters. We can extract them with much less cost and 
much less time and much less environmental impact.
    Mr. Westerman. Your company focuses only on picking up the 
nodules. You are not like some of the early technology, where 
you are picking up a lot of material off of the floor, is that 
correct?
    Mr. Gunasekara. Yes, it is a completely new type of 
collector. So our collector doesn't actually land. We are 
exclusively focused on the polymetallic nodules, the potato-
sized rocks. So like all people going after this resource, 
there is no cutting or blasting. Literally, these are like golf 
balls on a driving range that we have to pick up.
    And now, our vehicle hovers, it doesn't actually land. And 
it uses AI with its cameras, to look for life. We know very 
occasionally, every few hundred nodules there is a deep sea 
coral or a sponge. We will detect that using the AI on the 
vehicle, and then we will quarantine that area and fly over the 
top, leaving it completely undisturbed.
    In addition, we will always leave around 60 percent of the 
nodules left undisturbed. And because the vehicle is hovering, 
there is minimum sediment impact. We don't have a discharge 
plume. We minimize noise. We basically took as an input the 
environmental concerns, and designed a 21st century technology 
solution to mitigate those concerns.
    We are also significantly less expensive. And I do want to 
be clear, our economic model, version 6, which is on our 
website, including the spreadsheet, is showing how we are 10 
times less expensive than the average nickel mine in 2024, 10x. 
That is for the mining and the processing. This allows us to 
avoid Chinese dumping.
    The problem with China is that they are very, very good at 
manipulating the price and driving Western companies out of 
business. Because our cost base is going to be so low, we are 
somewhat isolated from that strategy.
    Mr. Westerman. It sounds like your technology has moved 
along at a faster pace than regulatory reforms. I know that, in 
addition to BOEM, NOAA also plays a role in the process for 
seabed mining in the U.S., now depending on which area is 
involved. Can you talk about the weaknesses and strengths of 
the different agencies involved in the permitting process?
    Mr. Gunasekara. The good news is that there is legislation. 
The bad news is that it is quite old, and we feel could be 
improved.
    Specifically in the BOEM case, which is where we are 
focused, there are four public consultation periods. There is 
no defined timetable. Again, given the President's 
determination of an emergency, we would like to see a more 
dedicated time frame for when this process can start.
    I want to be clear. We want environmental review. We want 
to do an environmental impact. We are very strong in protecting 
the environment. But we don't want it to take decades. It is 
too important.
    Mr. Westerman. I agree with that, and that applies to many 
things.
    But Mr. Chair, I am going to go ahead and ask this 
question.
    Dr. Gosar. Go ahead, please.
    Mr. Westerman. A concern that I have, and you mentioned it 
in your testimony, is that the processing of all these critical 
minerals basically happens in China. You did mention that there 
are some other countries, I think, Japan and Australia, that 
have some processing capabilities. But when we look at this 
issue from a national security standpoint, if we are simply 
mining the material and shipping it to China, we are not really 
helping ourselves on the national security. Talk about how much 
capacity is out there with more friendly countries, and the 
need to co-develop processing facilities here in the U.S. or in 
Canada or somewhere close if we are going to be mining this 
material.
    Mr. Gunasekara. It is essential that we develop domestic 
capabilities, and I think the President's previous executive 
orders talk about that.
    But I think in the short term, stockpiling is a great 
option. It will stimulate the industry. And if we build the 
stockpiles in strategic locations in the U.S., where there is 
the infrastructure and the power, it will encourage industry to 
invest in building those.
    In the intermediate, we can do processing in friendly 
nations. The Metals Company actually has proven that Japan has 
the capability. They have worked with a partner there, and 
actually proven that nodules can be processed in an existing 
nickel refinery. And our belief is that could also be 
duplicated in Australia and potentially in Canada, as well.
    So we see three stages: first stage is stockpile; second 
stage is reuse friendly nations; third stage is build our own 
bespoke optimized processing here in the U.S.
    Mr. Westerman. I am way out of time, Mr. Chair.
    Dr. Gosar. Oh, I thank the gentleman. We are going to have 
a second round here.
    You know, I am a touchy-feely guy. I actually have a nodule 
right here from the Mojave Desert. It is filled with rubidium. 
I know you guys have some. Could you send those around to 
everybody, please?
    I got to tell you, when I went through TSA with that, 
everybody was talking about that, that nodule right there. So 
you will see they are very interesting. Did you get a chance to 
see this?
    Mr. Barron. Mr. Chairman, I am happy to say a nodule just 
like this one was presented to the President last week, and now 
sits on the Resolute Desk.
    Dr. Gosar. Well, I guess my point is I found this on a 
desert, and it is surrounded by sand. So you think there would 
be some commonalities there, OK?
    Dr. Peacock, that is why I want to come back to you. It 
seems like you have been doing the studies that have shown 
there is really no impact. Can you give us a little bit more 
background on that?
    Dr. Peacock. Certainly, yes. So we monitored the collect 
trials that took place in the Clarion-Clipperton Zone in 2021. 
We established very clearly what the physics and what the 
scales of the plumes were.
    So as I stated in my testimony, 92 to 98 percent of the 
sediment deposited within about 300 feet of the mining 
activity, the remaining 2 to 8 percent of the sediment was 
about no higher than about 10 to 15 feet above the seabed, and 
happy to answer any more questions or further details on that--
--
    Dr. Gosar. Yes. Is there anything else that could disturb 
those sands and bedrock down below?
    Dr. Peacock. Natural processes are you talking about?
    Dr. Gosar. Yes, like volcanoes, seismic activity.
    Dr. Peacock. That has not been determined right now. In the 
Atlantic Ocean there are some data sets that talk about what 
are called benthic storms that naturally suspend sediment. 
There is no data yet on that in the Pacific Ocean. And of 
course, those storms wouldn't remove nodules from the seabed.
    Dr. Gosar. Right, but I am talking about more of the sand.
    Dr. Peacock. So at present there is not data in the Pacific 
Ocean whether there is these benthic storms that would do that. 
There is some data in the Atlantic Ocean.
    Dr. Gosar. Now, are you familiar, Dr. Peacock, with 
microprocessors?
    Dr. Peacock. A little.
    Dr. Gosar. OK. So the new technology is getting everything 
out of this ore. So it is pulverized. My understanding, there 
is a number of sequences. There is pulverized, there is 
electrolysis. They use surfactants to take it all off, and they 
are basically getting everything out of the ore. Is your 
opinion the same way?
    Dr. Peacock. I apologize, could you repeat the question? I 
don't quite understand----
    Dr. Gosar. Yes, these microprocessors, they are doing ore 
very differently. They are pulverizing the ore, they are using 
different surfactants and whatever, weights of the things to 
pull off the everything that is in these ores. Are you familiar 
with those?
    Dr. Peacock. No, I am not familiar with the processing 
technology there.
    Dr. Gosar. OK. Are you familiar with Schlumberger?
    Dr. Peacock. I know the company Schlumberger, yes.
    Dr. Gosar. Are you familiar with how they actually 
concentrate lithium?
    Dr. Peacock. No, I don't work on the processing side.
    Dr. Gosar. This comes back to the technology. It is 
advancing very, very fast. And Schlumberger can actually go 
into--like, say we have a subterranean big lake west of me in 
Phoenix. It is actually in Buckeye. They can't use water 
because it is very heavy metal and very briny. And they are 
hooking up these machines that actually will use the water, 
because when you are using lithium you have to use a lot of 
water. And they are actually producing cleaner water than 
actually what they are finding there. So I think there is a lot 
of upside on a lot of this.
    Mr. Barron, I think part of your problem is that on land we 
can't find a mine that the other side would like and would go 
along with. And they are no longer--29 years, over 3 decades. 
The Resolution Copper over here in eastern Arizona, in the 
copper corridor was mined for over 100 years, and still we have 
gotten nowhere with it. So they haven't produced one piece of 
copper. So that is our frustration here.
    The other thing is misuse of some of the language in the 
law. A president has no jurisdiction beyond 2 years and less 
than 5,000 acres to withdraw in any way, shape, or form. So we 
have got to get back to the rule of law on that aspect.
    So I am going to cut my question short and go to the next 
round. So Mr. Case, you so diligently stayed behind, we would 
love to give you your next 5 minutes.
    Mr. Case. Thank you very much.
    Dr. Peacock, I am going back to your testimony. Basically 
what your testimony offers is a view of minimal environmental 
impact, based on your monitoring of tests conducted in 2021 and 
2022. Were those Mr. Barron's company's tests?
    Dr. Peacock. No. The second test was The Metals Company 
test. We did a small component of that. We provided a new 
sediment sensor that we designed for monitoring. The first test 
was for a company called Global Sea Mineral Resources, also 
independently monitored by a European consortium called the 
Mining Impacts Consortium.
    Mr. Case. OK, so these were private companies wanting to 
conduct deep-sea mining. You are monitoring their tests, 
correct?
    Dr. Peacock. Correct.
    Mr. Case. OK. And according to your testimony, these were--
I am trying to find your quote--they were ``small-scale, short-
term pilot tests,'' is that right?
    Dr. Peacock. That is correct.
    Mr. Case. OK. So these were not large-scale, longitudinal, 
real deep-sea mining tests. They were not tests of that. They 
were kind of like, hey, get in there, do a small pick, find out 
what the sediment is, et cetera.
    Dr. Peacock. I would agree with that with one exception, 
which is the scale of the vehicles themselves was not 
dissimilar from what a commercial scale would be. They were 
about a third the size of a commercial scale vehicle.
    Mr. Case. OK. And were there a variety of approaches to 
deep-sea mining tested, or were they focused on the pluck that 
has been, you know, testified to, one of the measures?
    So, in other words, did they, for example, do the large-
scale clamshell drop from the top of the ocean to the bottom, 
impacting the bottom, digging up deeper than a couple of 
inches? Did they do a dredge across the bottom? Did they do any 
of that stuff, or was it just like one approach?
    Dr. Peacock. So both companies used the same technology, 
which is this hydrodynamic suction technique.
    I am not really aware of any commercial companies using 
that sort of dredging type approach----
    Mr. Case. OK.
    Dr. Peacock [continuing]. From the top of the ocean.
    Mr. Case. All right. So you just did the suck thing, the 
hydrodynamic--go down there with a suction thing and suck it 
up.
    Dr. Peacock. Yes, that is one of the main technologies that 
people are looking at.
    Mr. Case. All right, but it is possible that there is other 
ways of getting stuff from the ocean floor. Correct?
    Dr. Peacock. Yes----
    Mr. Case. You didn't test for that.
    Dr. Peacock. A----
    Mr. Case. OK. And similarly, you only tested for sediment. 
You didn't test for other marine impacts, correct?
    Dr. Peacock. My group led the sediment studies, but there 
was an entire European consortium of 23 institutions that did 
all the biological studies.
    Mr. Case. OK, and I want to get to that, because I am 
reading your testimony further. And you have a couple of 
specific recommendations in here.
    First of all, you say that you need to be very careful 
about where you conduct these extraction activities. You 
recommend a patchwork of protected areas. You suggest large 
areas off limits to mining, protecting some smaller areas. You 
definitely recommend a regulatory framework. You recommend 
dedicated programs to determine sensors to detect impacts, 
monitoring. You talk a lot about the International Seabed 
Authority. In fact, you are a consultant, or you are actually a 
member of the International Seabed Authority indirectly, right?
    Dr. Peacock. I am on the Expert Committee for Thresholds--
--
    Mr. Case. OK.
    Dr. Peacock [continuing]. For the ISA.
    Mr. Case. All right. So you are not sitting here as an 
expert recommending that we do whatever we want on the seabed. 
You are recommending a specific regulatory framework for 
protecting the environment which is similar to what the ISA is 
doing. Right?
    Dr. Peacock. Yes. I advocate for a step-by-step approach at 
increasing scales of operation and with robust guidelines of 
regulations to oversee that process.
    Mr. Case. OK. And do you have a view about whether the 
executive order offers such a regulatory framework?
    Dr. Peacock. I don't have a view on that. I don't have----
    Mr. Case. OK.
    Dr. Peacock [continuing]. Familiarity with it.
    Mr. Case. Mr. Currie--and I am going to do this 
rhetorically, and you can answer within 30 seconds--
fundamentally, the executive order ignores the International 
Seabed Authority, throws it out, that we are going to go this 
alone, right?
    China is a member of the International Seabed Authority, 
and China is obviously trying to manipulate it to its ends, but 
it is at least doing it within a framework of the International 
Seabed Authority Law of the Sea. We have decided not to do 
that. Is it correct that the actions by this President would 
incentivize China to go it alone, with no environmental 
regulation whatsoever?
    Mr. Currie. That is one possible outcome. The other 
possible outcome is that China positions itself as the leader 
of multi-lateralism and goes it that way. China is very smart 
about the way that thinks forward. They are clearly very, very 
invested in pursuing deep-sea mining, but not in any particular 
rush.
    Mr. Case. OK.
    Mr. Currie. So I think you would find China coming back 
with a very measured response.
    Mr. Case. OK. Thank you very much.
    Dr. Gosar. I thank the gentleman from Hawaii. The gentleman 
from Arkansas is recognized for 5 minutes.
    Mr. Westerman. Thank you, Mr. Chairman, for doing two 
rounds.
    Dr. Peacock, I wanted to discuss your research related to 
seabed mining. We often hear from folks who are opposed to 
seabed mining that we don't actually know what exists on the 
sea floor. Is that an accurate assertion?
    Dr. Peacock. I often find these general statements not very 
enlightening.
    In terms of the global sea floor, the entire global sea 
floor is mapped to a resolution of 1.5 kilometers. About 25 
percent of the ocean is mapped to resolution of 100 meters. 
There are areas of the Clarion-Clipperton Zone that are mapped 
to within one centimeter.
    On the biological side, indeed, across the Clarion-
Clipperton Zone, as I mentioned in my testimony, there are 
several thousand anticipated species, but only 500 have been 
named. But at particular nodule sites that have been studied 
for 10 to 20 years, there is far greater knowledge of what 
lives at those sites.
    Mr. Westerman. Thank you. In your written testimony you 
talked about the need for improvement to technologies related 
to deep-sea mining. And I know we have had a little bit of 
discussion about that already, but can you elaborate on what 
technologies need to be improved and how the government can 
ensure that entrepreneurs have the space to address these 
technological needs?
    Dr. Peacock. Yes. There are capable sensor systems that 
exist now that are being used throughout current trials. But as 
efforts would scale up, there is a need--for example, improved 
energy supplies to operate in the deep ocean for long periods 
of time. Battery technologies are challenged for their 
duration. Low-cost vehicles that could travel over these large 
distances of tens to hundreds of kilometers that the mining 
sites are assigned over 30-year timescales. So these kind of 
advances would be needed.
    And also on the computation side, the ocean is big, deep, 
and vast. We can gather as much data as we can, but there will 
always be a need for computer modeling to help make the best 
use of that data. So advances in AI and GPU-based computing 
technology can really enhance our ability to understand where 
critical knowledge gaps are and where we should invest in and 
put sensors.
    Mr. Westerman. And the last question I want to ask you is, 
what areas do you think the United States surpasses China with 
technology and resources for deep-sea mining and vice versa?
    Dr. Peacock. The U.S. has a leading history, of course, 
from the 1970s in operating in the deep ocean. And NOAA is a 
world-leading institution in terms of ocean research. In 
regards to deep-sea mining, there has been very little 
investment from the U.S., of course, in the last few decades. 
So at this point entities like China, Japan have advanced 
capabilities compared to the U.S.
    Mr. Westerman. Now, Mr. Barron and Mr. Gunasekara, I want 
to ask that same question to you. Where do you see U.S. 
technology leading over China, or where does China have better 
technology than us in deep seabed mining?
    Mr. Barron. Well, I have had the benefit of traveling to 
China a year ago and visiting Sanya on Hainan Island, where 
there is a community of 27,000 people all dedicated to building 
the technology stack.
    The good news is America did lead the space, as I 
articulated, in the 1970s. And American companies and 
universities have played an important part in our own 
operation. We have four universities who are contributing to 
our environmental research. We fund them, but they are free to 
go and do the work and publish their results. We conducted our 
own boat out of San Diego, where we ran 22 campaigns from the 
Port of San Diego carrying out research. Those campaigns run 
for between six and 8 weeks.
    And I think the innovation available in America is 
tremendous, and I think that you need to have something--a 
starting gun, and I think that starting gun was triggered last 
week by the President's executive order.
    Mr. Gunasekara. I would add and say that our technology is 
leading. I have spent 20 years living and working in Silicon 
Valley, and we have been able to pull together the most 
advanced technology, a completely new way to harvest these 
metals with the least impact and the least cost. Of course, 
China will copy us, you know, although we have U.S. patents. 
Right now we are in the driving position of having, I would 
say, the most advanced technology for this. But if we don't 
move quickly, China will overtake us. They are doing two----
    Mr. Westerman. So you think China has had the same focus on 
the environmental sensitivity of harvesting these nodules that 
the U.S. has had?
    Mr. Gunasekara. No, not at all. You know, they are actually 
doing two collector tests this year in the Clarion-Clipperton 
Zone under the ISA. And so we can see these are traditional-
style collector vehicles that don't have as good an 
environmental impact as what we are attempting to deliver.
    Mr. Westerman. Thank you.
    Dr. Gosar. I thank the gentleman. The gentlewoman, the 
Ranking Member, Dr. Dexter, is now recognized for her 5 
minutes.
    Dr. Dexter. Thank you, Mr. Chair.
    Mr. Gunasekara, last year your company applied for mining 
exploration in U.S. waters near American Samoa, which BOEM 
denied after consultation with American Samoa. Shortly after, 
American Samoa announced a deep-sea mining moratorium in their 
territorial waters, citing threats to marine life, cultural 
heritage, and the territory's tuna fishery which is a 
profoundly important one.
    But just this month your company announced that it is 
applying for a lease to explore and potentially mine in Federal 
waters near American Samoa. Why are you pursuing this venture 
when it is clear the most impacted community is opposed to the 
industry and the impacts it will cause to their environment and 
its economy?
    Mr. Gunasekara. So we have had extensive dialog with the 
new Administration. There has been an election since the 
moratorium was signed by the previous governor. There is a new 
governor. And in our discussions we see that they are quite 
supportive, especially for the economic and jobs opportunity 
that deep-sea mining would unlock for them.
    It also--as I would say, the proposed area is hundreds of 
miles away from any land population, so significant distance. 
And with our technology there is no mid-water plume. There will 
be zero impacts to fishing. Of course, we will confirm that 
with an environmental impact assessment.
    The final thing I would say is that the Cook Islands, which 
is adjacent to American Samoa, recently signed an MOU with 
China for deep-sea mining. This is an opportunity to pull the 
Cook Islands back into the U.S. camp, because American Samoa is 
the nearest port with infrastructure that ultimately would be 
required for any deep-sea mining operation in the Cook Islands.
    Dr. Dexter. OK. My guess is that the chance that there will 
be impacts on the fishing industries and on those cultural and 
community interest has not been verified that there will be no 
impact. We are making an immense assumption there, I would 
guess. Do you agree that that is accurate?
    Mr. Gunasekara. That is accurate, but that is the whole 
purpose of an environmental impact assessment.
    You know, we are asking for this process to start. In the 
current legislation there are four public consultation periods. 
So there would be a lot of opportunity to have all stakeholders 
contribute and provide input.
    I want to be clear. Our request is not to go mining 
tomorrow. It is to formally start the process, which is going 
to take many years.
    Dr. Dexter. And Mr. Currie, I saw you nodding there. I 
would love your sort of assessment of the risks to the 
community and the fisheries from your assessments.
    Mr. Currie. What struck me, frankly, is the dissonance of 
the answer Mr. Gunasekara gave you and your question, if I may 
say so, about the cultural impacts.
    What we have learned in the International Seabed Authority 
in the last few years is that Pacific Islanders have very 
strong cultural ties to the Pacific Ocean, to the deep sea. It 
is not just about the physical impacts, it is about the 
cultural impacts, and these need to be taken into account. In 
my own country in New Zealand, the law requires that the Maori, 
the local people there, have an input into their cultural 
heritage, into their cultural perspective. And this is 
absolutely crucially important. That is the first thing.
    And the second thing is, yes, the Impossible Metals 
activities there, with their partnerships with local industry 
seem to be, you know, really flying in the face of the local 
concerns and the moratorium that still is in place.
    Dr. Dexter. Thank you. I am going to try to be quick, Mr. 
Chair.
    But Mr. Barron--sorry, I am trying to make this quick--
commercially valuable tuna and their food source support a 
multi-billion-dollar tuna industry in the Pacific. But these 
are fish that are high on the food chain. And some toxics, like 
manganese metals, concentrate as they move up the food chain. 
Tuna in particular are one of the unfortunate repositories for 
mercury, for example, which is toxic to people. And now the 
tuna in the fisheries would be exposed to toxic metals found in 
sediment or discharge plumes generated through seabed mining.
    What guarantee can you provide that deep-sea mining will 
not harm the Pacific tuna fisheries that American fleets and 
American consumers of seafood depend on?
    Mr. Barron. Well, the good news is tuna are very heavily 
studied, and we have studied them when it comes to polymetallic 
nodules. And the food web that tuna depend on will not be 
impacted by any of our return sediment or any of the activities 
we carry.
    Firstly, we are not in the migration path, but also we 
return the water at 2000 meters below sea level. And as part of 
the studies we carried out in 2022 from a production 
environment, we monitored and measured the benthic and pelagic 
plume. We had 50 assets in the water measuring while we were in 
the production phase. So we have an enormous amount of data 
around this. And NOAA, who obviously, have a regulatory 
environment to oversee this, will be furnished with all of that 
information.
    New Zealand, of course, have done extensive studies on this 
topic through their Federal agency. Mr. Currie would no doubt 
be aware of them. And so it is well understood that tuna will 
not be impacted by our activity in the CCZ.
    Dr. Dexter. So just to verify, there have not been 
commercial-level mining yet done, so I find it hard to make 
that sort of statement based on small-level production at this 
point.
    Mr. Barron. Well, I think the fact is the commercial trials 
we ran provide us the model to be able to then go and expand 
that model into a multi-year operation.
    But the key to think about is where tuna operate. They 
operate in the top hundreds of meters of the surface. And of 
course, they often feed on plankton that will go down to 1,000 
or sometimes 1,200 meters. And that is why, with the feedback 
of environmental scientists, we return the water to a depth of 
2,000 meters.
    There are some people that think we should tip the return 
water over the back of the boat because it would create an 
algae, and it would be an amazing sequester of carbon. And 
maybe 1 day in the future that is what the regulator will ask 
us to do because of the environmental benefits that come with 
that. But for the moment our proposal is to return that water 
at 2,000 meters below sea level, out of every harm's way.
    There, of course, have been studies around bioavailability, 
as well, and it appears that these metals in water are not 
bioavailable to species that digest them anyway.
    Dr. Dexter. So I just want to make the statement that, as a 
physician we have made many hypotheses on the complex 
biological ecosystems of the body, and our assumptions that we 
make based on small studies oftentimes are proven wrong over 
time. So I just want to caution this Committee using small-
degree data over short periods of time in an incredibly complex 
ecosystem to make assumptions about.
    Thank you, Mr. Chair.
    Dr. Gosar. I thank the gentlewoman. Thank you, because you 
led into my questions.
    But the gentleman from Florida, Mr. Webster, is recognized 
for his 5 minutes.
    Mr. Webster. Thank you so much, Mr. Chairman, and thank you 
for kind of getting me into this Committee, I appreciate it. I 
have a question for Mr. Gunasekara.
    I sent a letter to then-Defense Secretary Lloyd Austin, I 
think it was in 2023, urging him to develop a plan to counter 
the Chinese Communist Party's dominance and continued 
investment in critical minerals. Additionally, the United 
States holds only the observer status in the International 
Seabed Authority, the entity regulating deep-sea mining.
    Since the sending of that letter in 2023, have you 
witnessed a difference on how the United States counters the 
CCP presence in seabed mining?
    And in what ways does still holding the observer status 
with the ISA affect your presence in the industry?
    Mr. Gunasekara. So China has, over the last few years, made 
massive investments in deep-sea mining. They actually hold four 
concessions through the ISA, more than any other country. And 
what we know is that they have to submit an environmental 
impact statement for any collector testing, as has been done 
with other companies. And two of their companies are actually 
doing collector testing this year. So they are moving very, 
very rapidly, heavily invested.
    Now you are correct, the U.S. has not ratified the UN Law 
of the Sea, and so it only holds observer status, which means 
that it cannot take its full-time position on the council. The 
U.S. is the only country that is guaranteed a permanent seat on 
the council, which is part of the executive branch of the 
International Seabed Authority. But fortunately, there is a law 
that was passed that allows the U.S. to regulate, even though 
they have not ratified the sea.
    So, you know, I think it would be ideal that the U.S. 
influence could accelerate the timelines at the International 
Seabed Authority. As Mr. Barron pointed out, it has been 14 
years since work started on the mining code, it is still not 
finished, and it is effectively being filibustered by a small 
number of countries that want to protect their domestic mining 
or have extreme environmental concerns. And so we would love to 
see that work actually conclude, and I think U.S. leadership, 
if it was a member, could help.
    Mr. Webster. OK, I have another question then. During the 
Biden administration you submitted a request to initiate the 
leasing process for critical minerals exploration in the U.S. 
economic zone, and that request was subsequently denied. You 
have now resubmitted the request to the Bureau of Ocean Energy 
Management. How will America lead critical mineral exploration 
in this portion of the globe and contribute to the ability to 
challenge China's growing dominance in deep-sea mining?
    Mr. Gunasekara. Well, one of the advantages that we have 
over China is that we do have these minerals in our Exclusive 
Economic Zone. That is something that China actually does not 
have. And so this gives us the ability to effectively mine our 
own waters. So the Federal waters, the Exclusive Economic Zone 
around American Samoa, are our Federal waters. They are exactly 
the same as if they were on Federal land. And the ability to 
mine them ourselves, I think, is a great mitigation against 
China's control.
    Obviously, those laws have already been passed but they are 
quite old and quite comprehensive in the fact that they need 
multiple public consultations. We would love to see a 
streamlining so that we could actually do all the environmental 
work and actually be mining in the next few years, not in the 
next 30 years, which is the average of a mine in the U.S.
    Mr. Webster. Thank you very much.
    I yield back.
    Dr. Gosar. I thank the gentleman. I will now take my 5 
minutes.
    This young lady talked about studies and, you know, the 
scientific methodology that goes with it. So, you know, Dr. 
Peacock, coming back to you again. Once again you have a 
hypothesis, then you try to develop whether it is true or not, 
and you go beyond that, right? And you start with small pilot 
studies and you build and build and build them.
    Now, you are on that verge right now, it sounds to me like, 
because you had that one study that was a real big one and a 
bunch of smaller ones, right?
    Dr. Peacock. There have been two pilot-scale trials in 2021 
and 2022 that brought a great deal of information. That is the 
latest.
    Dr. Gosar. OK. Now, this collection of these nodules is 
nothing new, right, Mr. Gunasekara?
    Why I say that is I was in Norway 6 years ago, and they 
were showing us that the Chinese, with their icebreakers, were 
actually up in the Arctic Ocean doing this already, right?
    Mr. Gunasekara. Absolutely, yes. I mean, China is investing 
in marine technology in all areas. They are building massive 
amounts of ships, underwater vehicles. Their navy is growing 
really rapidly, and deep-sea mining can be seen as a proxy for 
dual-use technology, especially the type of technology that we 
are building, which is autonomous underwater robots. These 
absolutely can have dual use and military applications.
    Dr. Gosar. Oh, I certainly agree with you, because we had 
autonomous vehicles being built for Resolution Copper because 
they are extracting copper at 7,000 feet and below. That is 
where the majority of that is coming from.
    So China follows all the rules, Mr. Gunasekara. They follow 
all the rules, right?
    Mr. Gunasekara. Not directly. They--yes, I mean, they----
    Dr. Gosar. So they only fish in their waters, right?
    Mr. Gunasekara. Yes, they----
    Dr. Gosar. Yes, that is not what I hear. That is not what 
happens. You know, so from that standpoint I think we got some 
problems here.
    Mr. Currie, Indigenous people--OK, I have lived my whole 
life with Native American Tribes. A lot of their concepts are 
based upon what they have gone through the ages with, but these 
are teaching moments. Would you say that is true or not?
    Mr. Currie. I am sorry. What moment, sir?
    Dr. Gosar. So these are teaching moments when we have 
something that is different or may be construed as different as 
far as an Indigenous Tribe.
    Mr. Currie. They certainly have a different perspective, if 
that is what you are saying, sir, absolutely.
    Dr. Gosar. Yes. So these could be teaching moments, you 
know, for example, let's say that we are talking about the 
collection of uranium, OK? And when we look at the breccia 
pipes in northern Arizona, OK, there are collapsed bed.
    Now, I am not a geologist, my dad was, but he taught us 
that these are collapsed or more concentrated in that area, and 
they are also the lowest point. And so when you are getting 
radiation, every time it rains, every time it blows you get 
that radiation. But if you sit down and say, listen, but if you 
take this out, you are going to have less of that contact. So 
you have to weigh those prospects--going back to the scientific 
methodology.
    But these are teaching moments because we are explaining 
why they are getting that exposure, how they are getting that 
exposure, and how much they are getting that exposure. So that 
plays a big deal with it, does it not?
    Mr. Currie. Yes. I think what I was trying to say to the 
other member is that the cultural perspectives are important on 
their own, quite separate from the scientific issues. I mean, 
traditional knowledge is certainly becoming a very big topic of 
discussion in international law. I have just come from a 
meeting in the United Nations last week where it was very much 
in evidence.
    But I think the point is not just the Indigenous viewpoint 
of what is happening. That is important. It is also their 
cultural connection to the deep sea that is what I was really 
referring to.
    Dr. Gosar. Well, I guess my point is they are not mutually 
exclusive.
    Mr. Currie. No.
    Dr. Gosar. I think--there you go. That is what my whole 
point was, is that----
    Mr. Currie. Thank you, sir.
    Dr. Gosar [continuing]. You have this hypothesis, and you 
have to disprove it, and you include people when you are doing 
that. And I think that is what--how medicine has gotten so 
good--or bad, however you want to look at it, depending upon 
how you approach it, the disease or whatever.
    So now I am going to ask you a question for each one of 
you. I will start with you, Mr. Barron, and it is the same 
question for all four of you. I already warned you about this. 
What was the question you wanted asked today? What is the 
question that wasn't asked, and what is its answer?
    Mr. Barron, you are first.
    Mr. Barron. Well, that is a challenging one. My question 
would be, what if the environmental impacts are indeed exactly 
as we predict they will be?
    And what if recycling won't meet the needs that are 
sometimes speculated? What is the alternative?
    And I can provide you the answer, as well. There isn't a 
good one. We need to find a supply of critical minerals with 
the lightest environmental and human impacts. And seafloor 
nodules are that answer.
    Dr. Gosar. Thank you, Mr. Barron.
    Mr. Gunasekara?
    Mr. Gunasekara. My comment would be on let's consider how 
we get the metals we use today. Let's take nickel. Seventy-five 
percent of it comes from rainforests in Indonesia. The majority 
is used in stainless steel, a little bit in batteries.
    Those rainforests are being completely destroyed because 
the nickel laterite ore is directly below the rainforest. The 
biodiversity, the carbon storage is immense. Let's talk about 
the social impact. There are Indigenous people that live--often 
they are being forced off their land at gunpoint. The water is 
being polluted. The fish are dying. It is an absolutely 
terrible situation. And guess who controls all of it? China. 
This is the current situation.
    We can deliver minerals from our own waters at lower cost. 
Lower cost will mean that those mines will close in Indonesia, 
just as today Indonesia has caused many mines in Australia to 
close because the prices come down. And to be clear, I am 
comfortable with the price coming down. We have plenty of 
margin available with our 10x lower cost, and it will enable 
everyone to afford newer technologies like electric vehicles 
and other infrastructure. So we can do a huge benefit for the 
planet environmentally, socially, and we can isolate ourselves 
from China control.
    Dr. Gosar. Thank you.
    Mr. Currie?
    Mr. Currie. Thank you, Mr. Chair. That is a fascinating 
question.
    I would like to ask what would happen if the U.S. goes it 
alone. And what I postulate, firstly, I think it would be a 
tragedy for the United States in stepping outside the 
multilateral framework and all the many effects it may have, 
including the freedom of navigation, marine scientific 
research, the U.S. standing in the world.
    I think it has the potential for initiating a free-for-all 
such as Mr. Case talked about. Whether it is China, whether it 
is another country, if one country is doing it, if one operator 
is doing it, you may well get many operators doing it, causing 
massive destruction on an unprecedented scale. You would have a 
great deal of legal litigation in the United States, possibly 
international. I think it will be a tragedy for the 
environment, a tragedy for the United States, and most 
importantly, a tragedy for multilateralism that has been in 
place for over 40, 50 years, recognizing that this area is a 
common heritage of humankind, needs to be looked after, needs 
to be for all generations and all peoples to look after.
    And it is difficult. It is frustrating. It is difficult, no 
doubt about that. But it has worked for 50 years, and we think 
that is the way to go. Thank you.
    Dr. Gosar. I thank you.
    Dr. Peacock?
    Dr. Peacock. Thank you very much.
    I think the question I would like to be asked is, are the 
latest scientific findings being used to drive decisions and 
discussions about deep-sea mining?
    And my answer to that is, I think, unfortunately, it is not 
the case. For example, we hear the topic of will deep-sea 
mining disturb carbon sequestration in the deep ocean. I think 
that was established in about 2020 that this is not an issue. I 
have studied sediment plumes for 10 years, but I read articles 
that a mining operation two-and-a-half miles down in the 
Pacific Ocean 1,000 miles away will reach Hawaii, which is 
simply not the case.
    The latest topic, of course, is dark oxygen. That has been 
a very high-profile scientific study. And the scientific 
community is looking into it. The consensus emerging is that 
this does not seem to be an issue. There is a paper from 2006 
that finds the opposite findings from the latest paper that 
came out.
    So I just really encourage the whole debate to take on 
board the latest science and data. Of course, I am going to do 
that. I am a faculty member at MIT. That is my role and that is 
my job. But I really think it is important to take on board 
learnings when we get them, whether they are good or bad. There 
is still a lot of questions about biodiversity, ecosystem 
function. We need to pay attention to those. But when something 
is determined and scientifically shown to be the case, we need 
to accept that and move on. Thank you.
    Dr. Gosar. Wow, what a discussion. You know, I wish more 
people were here watching and seeing this. I know that the 
Committee will have a bunch of more questions, and they will 
have to submit them in a certain way. Let's see, and we will 
ask our witnesses to respond with those questions in writing. 
Under Committee rule 3, members of the Committee may submit 
these questions to the Subcommittee clerk by 5 p.m. on Friday, 
May 2. The hearing record will be held open for 10 business 
days for these responses.
    If there is no further business----
    Dr. Dexter. Mr. Chair, I just wanted to request that I be 
allowed to submit into the record several reports and 
documents.
    Dr. Gosar. Without objection, so ordered.
    Dr. Dexter. Thank you very much.
    Dr. Gosar. I will tell you I am fascinated by this, and I 
will tell you, we need to keep our eyes open. I am not so leery 
of America. I want America to dream again. I want her to build 
again. I want her to lead again. And I think that is very 
important.
    You know, so Mr. Currie, I know that you are in New 
Zealand. We share a common bond there. And I thank you very 
much for your travels.
    And with that, the Subcommittee stands adjourned.

    [Whereupon, at 11:54 a.m., the Subcommittee was adjourned.]

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