COBRA’s mission is to accelerate the understanding of the deep sea to inform decision making. In service to that mission, COBRA convenes subject matter experts to synthesize and translate information and knowledge gaps to policy makers and the general public, such as requested through public comment. Below are examples of some of these knowledge translation efforts.
Docket: NOAA-NOS-2026-1751, August 19, 2026
Comment: NOAA-NOS-2026-1751-1594, October 19, 2026
Signatories (in alphabetical order): Peter J. Auster, Katy Croff Bell, Erik Cordes, Andrew Fisher, Zach Gordon, Julie A. Huber, Lisa Levin, Neil Nathan, Adela Roa-Varon, Andrew Thaler, Travis W. Washburn. The signatories are at major American research universities and institutes, and the views expressed are their own.
A group of US-based subject matter experts in deep-sea science, including COBRA members and partners, provided comments on the Consolidated Application for marine minerals exploration and exploitation from TMC for the USA-A area in the Clarion Clipperton Zone. This comment does not express an opinion for or against deep sea mining. As subject matter experts, we aimed to objectively evaluate if the consolidated application is compliant with the applicable information requirements of DSHMRA and its implementing regulations described in the Code of Federal Regulations Part 971. We asked if the application provides sufficient information to reasonably expect that there will be no significant adverse environmental effect. Or, if there is insufficient information to make that determination, that no irreparable harm will result during a period when monitoring of commercial recovery is undertaken to gather sufficient information in order to determine the potential for or occurrence of any significant adverse environmental effect. Our review resulted in a number of important findings regarding this data sufficiency question. See PDF for details.
Docket: BOEM-2025-0318, January 29, 2026
Comment: BOEM-2025-0318-1902, March 24, 2026
Signatories (in alphabetical order): Steven Auscavitch, Peter J. Auster, Amy Baco-Taylor, Julie A Huber, Brian Kennedy, Lisa A. Levin, Beth Orcutt, Randi Rotjan, Andrew D Thaler, Travis W Washburn. The signatories are primarily faculty and senior staff at major American research universities and institutes, and the views expressed are their own.
A group of US-based Subject Matter Experts on deep-sea scientific exploration and research, including COBRA members and partners, provided information that BOEM may use in reviewing leasing requests for prospecting for “deep-sea mining” in the Outer Continental Shelf Minerals Offshore Alaska pursuant to EO 14285 and 30 CFR 581.11 and this Request For Information. The purpose of this letter is to provide a reference of publicly available information that might inform your work, particularly biological and environmental information as requested in the RFI Section 6 (d), as well as information on OCS minerals of interest (a), and environmental sensitivity (f). We reviewed existing publicly-available information and found that there is limited environmental baseline data from the specific region being considered for OCS mineral leasing, including physico-chemical data, biological and ecological data, and mineralogical data. See PDF for details.
Docket: NOAA-NOS-2025-0702, NOAA-NOS-2025-1330, December 23, 2025
Comment: NOAA-NOS-2025-0702-0167, NOAA-NOS-2025-1330-0192, February 23, 2026
Signatory: Julie A. Huber, Woods Hole Oceanographic Institution. My signature represents my view as an individual and not the institution I work for.
Julie Huber (Woods Hole Oceanographic Institution) provided comments on the TMC Applications A and B for nodule exploration licenses in the Clarion Clipperton Zone. I am a US-based subject matter expert in deep-sea science. My comment concerns the scientific robustness of the baseline information and monitoring plans described in the applications and their compliance with the requirements of DSHMRA and the Code of Federal Regulations. I did not find the applications compliant with the requirements of DSHMRA exploration regulations. See PDF for details.
Docket: BOEM-2025-0351, December 12, 2025
Comment: BOEM-2025-0351-0694, December 22, 2025
Signatories (in alphabetical order): Diva Amon, Steven Auscavitch, Katy Croff Bell, Amy Baco-Taylor, Jeffrey W. Beeson, William W. Chadwick, Erik E. Cordes, Jeffrey C. Drazen, Ann G. Dunlea, Valerie Finlayson, Marina Garwood, Zachary Gordon, Julie A Huber, Kristen Johannes, Brian RC Kennedy, Lisa A. Levin, Sheryl Murdock, Neil Nathan, Beth Orcutt, Randi D. Rotjan, Patrick T. Schwing, Andrew D Thaler, Jacob Tomer, Travis W Washburn. The signatories are faculty and senior staff at major American research universities and institutes, and the views expressed are their own.
A group of US-based Subject Matter Experts on deep-sea scientific exploration and research, including COBRA members and partners, responded to the US Bureau of Ocean Energy Management request for information in reviewing leasing requests for prospecting for “deep-sea mining” in the U.S. Exclusive Economic Zone / Outer Continental Shelf (OCS) offshore the Commonwealth of the Northern Mariana Islands. The purpose of this letter is to provide a reference of publicly available information that might inform your work, particularly biological and environmental information, as well as information on OCS minerals of interest, and environmental sensitivity. We reviewed existing publicly-available information and found that there are almost no environmental baseline data from the specific region being considered for OCS mineral leasing, including physico-chemical data, biological and ecological data, and mineralogical data. See PDF for details.
Docket: NOAA-NOS-2025-0108, July 7, 2025
Comment: NOAA-NOS-2025-0108-1569, September 5, 2025
Signatories (in alphabetical order): Amy Baco-Taylor, Erik Cordes, Katy Croff Bell, Jeffrey C. Drazen, Val Finlayson, Christopher R. German, Annette Govindarajan, Julie A. Huber, Brian RC Kennedy, Lisa A. Levin, Beth O. Orcutt, Jason B. Sylvan. The signatories are faculty and senior staff at major American research universities and institutes, and the views expressed are their own.
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. See PDF for details.
Docket: BOEM-2025-0035, July 16, 2025
Comment: BOEM-2025-0035-8135, August 13, 2025
Signatories (in alphabetical order): Diva Amon, Steven Auscavitch, Katy Croff Bell, Amy Baco-Taylor, Erik E. Cordes, Jeffrey C. Drazen, Valerie Finlayson, Christopher R German, Annette Govindarajan, Santiago Herrera, Julie A Huber, Brian RC Kennedy, Lisa A. Levin, Beth Orcutt, Randi D. Rotjan, S. Adam Soule, Jason B Sylvan. The signatories are faculty and senior staff at major American research universities and institutes, and the views expressed are their own.
Among tens of thousands of comments, a group of US-based Subject Matter Experts on deep-sea scientific exploration and research, including COBRA members and partners, responded to the US Bureau of Ocean Energy Management request for information in reviewing leasing requests for prospecting for “deep-sea mining” in the U.S. Exclusive Economic Zone / Outer Continental Shelf (OCS) of American Samoa. This letter provides a reference of publicly available information to inform the work, particularly biological and environmental information, as well information on OCS minerals of interest, and environmental sensitivity. Although there has been a strong push in past decades to explore and characterize deep-sea ecosystems, including in American Samoa, we reviewed existing publicly-available information and found that there are almost no environmental baseline data from the specific region being considered for OCS mineral leasing, including bathymetric mapping data, physico-chemical data, biological and ecological data, and mineralogical data. See PDF for details.
