The United States sits atop an estimated billion-ton reserve of polymetallic nodules that can underwrite a century of industrial leadership; yet, today those resources lie fallow while China races to secure a global supply. We therefore write both to affirm our commercial interest in a lease in this area, and to urge the Bureau of Ocean Energy Management (BOEM) to advance expeditiously from this RFI to a proposed notice of sale.

Impossible Metals is a U.S.‑headquartered, Delaware‑incorporated company founded to solve America’s critical mineral dependency through home‑grown innovation. Our autonomous underwater vehicle (AUV) fleet employs selective, “pick‑and‑place” robotics that hover above the seabed, lift individual nodules, and leave at least sixty percent in situ to sustain benthic biodiversity while maintaining profitability. Unlike dredge‑and‑riser systems, our AUVs generate no sediment plume, avoid all visually detected megafauna, and operate from standard commercial vessels without dynamic positioning. This technology has been tested in the ocean at a depth of over a mile, and we expect to be technologically ready for full-scale production in 2027. Any environmental impacts will be quantified with a comprehensive environmental impact assessment (EIA) before mining is permitted. Impossible Metals commits that we will only mine if we are satisfied that our Environmental Impact Statements (EIS) show there will be no material, long-lasting impacts on the marine habitat or other uses of the ocean. (fishing, transportation, recreation, submarine cables, etc.)

Impossible Metals see the following benefits to leasing:

  • Mitigates the national security risks and vulnerability to geopolitical and supply chain disruptions due to the U.S. being highly dependent on foreign sources of critical metals.
    • Provide large quantities of critical metals (Ni, Cu, Co, Mn, and possibly REE).
  • Revenue for the US Treasury from lease, royalties, and taxes.
  • Incentivizes investments in mineral processing facilities in the U.S., including potentially in American Samoa.
  • Pulls the Cook Islands away from China’s support by providing available infrastructure.

And additional benefits to the communities of American Samoa:

  • 1% profit share to be paid by Impossible Metals to the American Samoa community.
  • Employment, training, and capacity-building opportunities, including high-skilled new jobs in this new industry.
  • Potential U.S. Federal government investment in critical infrastructure (e.g., port upgrades & permanent Coast Guard presence).
  • Securing more knowledge of the American Samoan EEZ seabed and environmental conditions, even just from the exploration stage.
  • Potential sharing of the federal revenue from the lease, as is typical with offshore oil and gas and offshore renewable energy.

Impossible Metals’ approach aims to address all major concerns with seabed mining.

  • Environment: Taking a precautionary approach that protects the environment, including generating no sediment plume, avoiding all visually detected megafauna, operating from standard commercial vessels without dynamic positioning, and leaving the majority of nodules to preserve the ecosystem.
  • Economic: Generating revenue and jobs from seabed mining, attracting new potential federal and mineral processing investment, and profit sharing with the local community.
  • Local Culture, Leadership, and History: Engaging with leaders, organizations, and residents in American Samoa as a vital part of responsible resource development, and ensuring that Pacific history does not repeat by focusing on sustainable resource development.

The full PDF of our comments is here.