Comment from Anonymous

I do not believe it is appropriate at this time for American Deep Sea Minerals (“ADSM”) or any other U.S. entity to be granted a license to mine in international waters near the areas over which French Polynesia, the Cook Islands, and Kiribati have exclusive rights. I strongly feel that it would be misguided, in bad faith, and a case of very poor judgment to not await international permission, and to allow the industry to operate in the high seas under the Deep Seabed Hard Mineral Resources Act. As NOAA is no doubt aware, that Act, passed during the Carter administration, was meant to be an interim measure until the world agreed to the U.N. Convention on the Law of the Sea. But when the treaty was adopted, Congress never ratified it. Acting alone, without international consensus, may be a hallmark of the Trump administration, but it is poor policy and poor international politics. The Trump administration’s pursuit of the industry has already caused global backlash. Other nations recognize that high seas are deemed the “common heritage of humankind.” One could also argue that ocean environments don’t belong to humans at all. There is far too much at stake for NOAA to greenlight ADSM’s application. What about the consequences of mining near regional fisheries? What about the rights of Pacific nations and indigenous peoples to have a say in how their neighboring waters are used, and to prevent ecological harm to those waters? It’s worth noting that Pacific peoples who never achieved U.N. membership were excluded from the creation of the Law of the Sea delineating international waters. Further, ADSM has is not a going concern; it has no institutional experience or expertise. According to its application, it doesn’t own the equipment or technology needed to work in marine environments. ADSM is just a thought bubble. Also worth noting is a potential business risk to ADSM (or any other U.S. company in its stead). Through a U.N.-established procedure, countries can claim sovereign rights over additional seabed if they can prove their continental shelf extends beyond the standard 200-mile exclusive economic zone established by international law. If one of the surrounding countries in question successfully extended its claim to the seabed, any claim the company might hold to it would be overridden. In evaluating ADSM’s application, the most important factor is one that is both moral and aesthetic. The part of the world that ADMS seeks to mine is one of the most beautiful, sublime places on earth. I have been there. We humans would be fools to desecrate it. And the ocean environment is far too important for us to damage. As the president of French Polynesia said last year, mining the seabed is “playing gods with the cradle of life — and that’s way too dangerous.” Who are we Americans to barge into this precious, vital, delicate place and start ripping it up? (Have we forgotten what the U.S. did to Bikini Atoll after World War II, and the physical devastation and political outrage that that caused?) For all these reasons, NOAA should wait on granting any licenses to conduct seabed mining or mining exploration activities until there is international consensus about whether, and if so, under what conditions, any seabed mining or exploration is permissible. The Trump administration should, for once, step back and let considerations other than greed and competitiveness hold sway.