Deep Seabed Hard Mineral Resources Act Proposed Rule Comments

NOAA-NOS-2025-0108-1569
5 September 2025

Signatories (in alphabetical order): The signatories are faculty and senior staff at major American research universities and institutes, and the views expressed are their own.

Amy Baco-Taylor, Florida State University
Erik Cordes, Temple University
Katy Croff Bell, Ocean Discovery League
Jeffrey C. Drazen, University of Hawai`i at Mānoa
Val Finlayson, University of Maryland College Park
Christopher R. German, Woods Hole Oceanographic Institution
Annette Govindarajan, Woods Hole Oceanographic Institution
Julie A. Huber, Woods Hole Oceanographic Institution
Brian RC Kennedy, Tufts University and the Ocean Discovery League
Lisa A. Levin, Scripps Institution of Oceanography, UC San Diego
Beth O. Orcutt, Bigelow Laboratory for Ocean Sciences
Jason B. Sylvan, Texas A&M University

Among tens of thousands of comments, a group of US deep-sea scientists informed about deep seabed mining, including COBRA members and partners, responded to the US National Oceanic and Atmospheric Administration request for comments on revisions to regulations for deep seabed mining exploration license and commercial recovery permit applications. Under the Proposed Rule, the exploration license and commercial recovery permit would fall under a single application. This consolidated approach removes a critical separation of two processes, which introduces the problems and issues that limit the ability of the agency to ensure effective protection of the marine environment.

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