Comment from Anonymous

NOAA has received an application from American Deep Sea Minerals Inc. for a deep seabed mining exploration license covering 101,064 km2 of the South Penrhyn Basin. The most damaging gap in the application's own reasoning is financial: ADSM's Statement of Financial Resources shows the company holds only $150,000 in cash, with $100,000 committed to the license fee itself and just $50,000 left for pre-mobilization, compliance, and administrative costs, yet the same application asserts the company has the financial capacity to complete a four-year, multi-cruise exploration program involving chartered vessels, AUVs, ROVs, and dedicated environmental cruises (Section 1.1). Several other internal contradictions undercut the application's conclusions. Section 2.1 claims ADSM has 'full technological capability' to execute the program, but Section 2.3.1 admits no agreements exist yet with any vessel owner or equipment supplier. Section 4.6.9 concedes that no site-specific benthic biology surveys have ever been done in the actual license area, even though the environmental baseline conclusions throughout Section 4.6 and the 'no significant impact' determination in Section 4.7.1 rely on the 1981 Programmatic EIS and on data from neighboring, already-licensed areas rather than the license area itself. And Section 4.7.2.2 promises Biodiversity Preservation Areas as mitigation for potential undocumented or endemic species without specifying any locations, sizes, or criteria. If this goes through, as an individual whom in her own community had a shell game played upon with a company who had no financial track record to run a transportation system and continually needed to be bailed out by my local government. This seems to be the same thing. No financial track record of this company will apparently also need the same kind of government bail out for the four year multi cruise exploration program. NOAA should not issue this exploration license until ADSM provides verifiable financial documentation (audited statements or equivalent) demonstrating capacity to fund the full four-year program; executed agreements with vessel and equipment providers rather than preliminary discussions; site-specific baseline environmental data for the actual license area rather than analogues from neighboring EEZ blocks; and concrete, defined Biodiversity Preservation Area boundaries and criteria. NOAA should also require disclosure of aggregate, non-confidential cost figures so the public can meaningfully evaluate financial capability, and should explain why the 44-year-old 1981 PEIS remains an adequate basis for a no-significant-impact finding given the scale of sampling and survey activity described in this application.