Comment from Grandy, Emily

I am submitting this comment in opposition to American Deep Sea Minerals, Inc.'s application for a deep seabed mineral exploration license under the Deep Seabed Hard Mineral Resources Act. The deep ocean is one of the least understood ecosystems on Earth. Scientists continue to discover new species, ecological relationships, and ecosystem functions in deep-sea habitats, yet our understanding remains incomplete. Authorizing exploration that could facilitate future commercial mining risks causing irreversible damage before we have sufficient knowledge to understand, measure, or mitigate those impacts. Deep seabed mining threatens fragile ecosystems that have evolved over millions of years. Disturbance of the seafloor can destroy unique habitats, generate sediment plumes that extend far beyond mining sites, introduce noise and light pollution into otherwise undisturbed environments, and disrupt species whose recovery may take centuries—or may never occur. Because many deep-sea organisms grow slowly and exist only in limited geographic ranges, the loss of biodiversity could be permanent. The environmental risks are compounded by scientific uncertainty. There is currently no demonstrated ability to restore mined deep-sea ecosystems or reliably predict the long-term cumulative effects of industrial-scale seabed disturbance. In the face of such uncertainty, the precautionary approach should guide federal decision-making. Once these ecosystems are damaged, there is no practical way to reverse the harm. The economic justification for deep seabed mining is also unconvincing. While proponents argue that seabed minerals are needed for emerging technologies, this overlooks the rapidly expanding opportunities to meet demand through improved recycling, material recovery, substitution, and more efficient use of existing mineral resources. Investing in a circular economy reduces pressure on both terrestrial and marine ecosystems while creating domestic jobs in recycling, manufacturing, and materials innovation. Moreover, the ecological services provided by healthy oceans—including carbon storage, nutrient cycling, fisheries support, and biodiversity—have immense long-term economic value. Damaging deep-ocean ecosystems for uncertain mineral returns risks imposing environmental costs that far exceed any short-term commercial benefits. The financial risks of investing in an industry facing significant regulatory uncertainty, growing international opposition, and unresolved environmental liabilities further weaken the case for expanding deep seabed mining. The United States has an opportunity to demonstrate global leadership by protecting one of the planet's last relatively undisturbed ecosystems rather than opening it to industrial extraction before its consequences are understood. Responsible ocean stewardship requires that exploration not outpace science. For these reasons, I respectfully urge NOAA to deny this application and prioritize the conservation of deep-sea ecosystems until independent science demonstrates that exploration and any future mining activities can occur without causing significant and irreversible environmental harm. Given the current state of scientific knowledge, that standard has not been met.