Frequently Asked Questions (FAQs)
Please contact our team if you have any questions that aren’t covered here or would like to discuss your questions or feedback with Impossible Metals.
Deep Sea Mining Regulations
The exploration phase of collecting deep-sea minerals has begun. So far, no commercial collection has taken place in the deep sea. To date, approximately 40 exploration licenses have been awarded: 31 by the International Seabed Authority (ISA) and the remainder by different governments within their exclusive economic zones (EEZ). There are 22 exploration resource areas for nodules: 19 from the ISA and 3 from the Cook Islands.
Individual countries govern the deep sea minerals within their EEZs. In international waters, deep sea minerals are governed by the United Nations (UN) through the “United Nations Convention Law Of the Sea (UNCLOS).” 169 countries, including the European Union, are signatories of UNCLOS. UNCLOS is controlled and enforced by the International Seabed Authority (ISA), an autonomous organization within the United Nations common system. For more details, please see the blog post “Current Status of Deep Sea Mining Regulations.”
Exploration regulations have been in force for many years. Exploration includes analyzing deposits, testing systems and equipment, and completing environmental baseline, scientific, technical, and economic studies; no commercial activity is permitted under exploration.
Exploitation (commercial mining) regulations have been under development for many years. The ISA has stated that the exploitation regulations will be adopted in 2025. Multiple countries, including the Cook Islands, have awarded exploration licenses within their exclusive economic zones. For more details, please see the blog post “Current Status of Deep Sea Mining Regulations.”
No. No single baseline for any development project can hope to solve ocean science and answer every question. A baseline project is not an unbounded ocean research exercise. The scope of a baseline project is defined by an EIA Scoping Study that identifies the parameters essential to assessing impacts and that directly connect to monitoring key indicators. However, there is an interface between a baseline project and regional and global ocean science objectives. By aggregating results across several individual baseline projects using consistent methods, regional assessments are made, and by integrating across information sources, the knowledge of global ocean science is improved. Publishing the objective findings of baseline studies is a key global knowledge enhancement process.
Nodule-rich areas are mapped and identified as part of the mining prospecting and exploration phase (not our focus). A traditional AUV with wideband sonar and box core samples performs the mapping. The essential data is nodule abundance measured in kg per square meter and metal grade. The metal grade is by collecting multiple box core samples and sending the nodules to the lab to measure the ore grade. Multiple NI-43-101 resource estimations have been completed for deep-sea minerals. The resource estimations are much more complex on land as the resource is three-dimensional compared to two-dimensional on the seabed. Holes are drilled, and an estimate of the three-dimensional resources is calculated.
Collecting and analyzing the data and writing the Environmental Impact Statement (EIS) report typically take three to five years. This is the primary purpose of the exploration license, which typically costs around $30–80M.
Yes. Stakeholders are engaged throughout the EIA process. EIS submission typically involves a public consultation period during which any parties can provide comments registered by the regulator and proponent and require assessment.
Additional elements of an EIS include stakeholder consultation outcomes, Environmental Management and Monitoring Plans, closure plans, and adaptive management measures. An EIS typically assesses project alternatives and states the no-development case. A level of Cumulative Impact Assessment (CIA) is typically required.
For more details on the EIA, see this blog post.
Yes. Environmental Impact Assessment (EIA) is a branch of environmental science performed by objective professionals with the necessary qualifications and experience. Given the oversight in modern EIA practice, project approvals do not benefit from poor-quality EIAs or overt client advocacy. EIA specialists do not engage in client advocacy. Furthermore, independent reviews, panels, committees, and hearings are standard practices in EIA.
No. The award of an environmental permit is contingent on a variety of factors. These include the comments from the public consultation period, independent reviews, and regulators’ internal assessment processes.
No. The permitting process involves setting a range of conditions. Permit conditions can include a range of measures, including additional studies, revised modeling, additional monitoring requirements, etc. Regular reporting and independent monitoring are also part of the checks and balances applied.
No. EIS does not seek consensus among all parties, and the award of an environmental permit does not require a response to every public comment on every topic.
Exploitation regulations are in the final stages of being adopted by multiple regulators. It is anticipated that the earliest date an exploitation contract could be awarded and production mining started is 2027.
169 countries, plus the European Union, have ratified UNCLOS. This represents 7.5 billion people (93%) of the world’s population. In the United States, there has been a vigorous debate over the treaty’s ratification, with criticism primarily coming from political conservatives who raised concerns about the Convention’s impact on U.S. sovereignty. See more details in the 60 minutes TV program from March 2024.
Yes. All mining typically has a royalty, paid for access to the resource. The ISA Finance Committee is working on equitable finance sharing from deep seabed mining. This is likely to result in a royalty. See the blog post “For All Mankind: How Deep Sea Minerals Could Pay Children in Africa to Go to School Instead of Mining” for more information.
- US Outer Continental Shelf (OCS) Lands Act, 1953
- US Deep Seabed Hard Mineral Resources Act (DSHMRA), 1980
- International UNCLOS, 1982
- India Offshore (Development and Regulation) Areas Mineral Act, 2002
- Cook Islands, Seabed Minerals Act, 2019
Deep Sea Mining & Other Industry Glossary
Abyssal plains = underwater plain on the deep ocean floor, usually found at depths between 3,000 and 6,000 meters.
Areas Beyond National Jurisdiction (ABNJ) = The formal term for the international seabed, beyond any country’s borders otherwise known as the ‘Area’ or the high seas.
AUV (Autonomous underwater vehicle) = self-guided underwater robots used for exploration, mapping, and, in the case of Impossible Metals, the selective harvesting of polymetallic nodules. These vehicles are battery-operated and operate without tethers, utilizing onboard sensors and AI to navigate and make collection decisions in real-time. They are central to minimizing environmental impact by avoiding direct contact with sediment or marine life.
BBNJ (Biodiversity Beyond National Jurisdiction) Treaty = also known as the High Seas Treaty or the Global Ocean Treaty, is a landmark international, legally binding instrument adopted by the United Nations on June 19, 2023. It aims to ensure the conservation and sustainable use of marine biodiversity in areas beyond national jurisdiction.
Biodiversity = biological diversity among and within plant and animal species in an environment.
Bulk carrier or bulker vessel = merchant ship specially designed to transport unpackaged bulk cargo such as nodules.
Bureau of Ocean Energy Management (BOEM) = a U.S. federal agency under the Department of the Interior that oversees the leasing and development of offshore energy and mineral resources on the Outer Continental Shelf. BOEM ensures that activities such as offshore oil, gas, wind, and mineral extraction are conducted responsibly, balancing energy needs with environmental protection.
CAGR (compound annual growth rate) = business, economics and investing term representing the mean annualized growth rate for compounding values over a given time period.
CCZ (Clarion-Clipperton Zone) = large area in the Pacific Ocean from Hawaii to Mexico.
Container ship or box ship = cargo ship that carries all of its load in truck-size intermodal containers.
Contractor = is a company, consortium, or state entity that has been officially licensed to explore or exploit mineral resources on the deep ocean floor, particularly in areas regulated by the International Seabed Authority (ISA) or within a country’s Exclusive Economic Zone (EEZ).
CFC (Cobalt-rich Ferromanganese Crusts) = ‘Crusts’ which form on sediment-free rock surfaces around oceanic seamounts, ocean plateaus, and other elevated features.
Critical Minerals or Metals (CM) = Copper, nickel, and cobalt which are essential components in many of today’s rapidly growing clean energy applications. Many governments maintain a list of critical minerals.
Deep Seabed Hard Mineral Resources Act (DSHMRA) = is a U.S. federal law passed in 1980 that establishes an legal framework for U.S. entities to explore for and recover hard mineral resources—specifically polymetallic nodules enriched in manganese, nickel, copper, and cobalt—from areas beyond national jurisdiction (the “Area”)
Department of the Interior (DOI) = a U.S. federal executive department responsible for managing the nation’s natural resources, public lands, and cultural heritage. It oversees agencies such as the National Park Service, Bureau of Land Management, and Bureau of Ocean Energy Management, playing a key role in conservation, energy development, and stewardship of federal lands and waters.
Dredging = bulk collection method involves machines that drag, vacuum, or scrape the seabed to collect polymetallic nodules and other mineral resources. This process typically involves disturbing large areas of sediment, which can create plumes, displace marine life, and damage sensitive ecosystems.
DP (Dynamic Positioning) = computer-controlled system to automatically maintain a vessel’s position and heading by using its own propellers and thrusters.
DSM (Deep Sea Mining) = process of extracting minerals from the deep sea..
ECS (Extended Continental Shelf) = area of the ocean which is part of a continental shelf that extends more than 200 nautical miles from the coast.
EEZ (Exclusive Economic Zone) = area of the ocean, generally extending 200 nautical miles beyond a nation’s territorial sea, within which a coastal nation has jurisdiction over both living and nonliving resources.
EIA (Environmental Impact Assessment) = series of baseline and technical studies, modeling, and analysis that aims to understand the receiving environment, the nature, and scale of impacts, identify mitigations, consult and liaise with regulators and stakeholders, interface engineering design and mine planning with environmental risks, assess optionality and weigh various alternatives. An EIA provides a formalized and transparent impact assessment that outlines how project pressures cause effects, how those effects work individually or in concert to cause impacts, and predicts the consequences of impacts in terms of their expected magnitude and duration.
EIS (Environmental Impact Statement) = tool for decision-making. It describes the positive and negative environmental effects of a proposed action.
EMMP (Environmental Management and Monitoring Plan) = is a comprehensive plan that outlines how a mining contractor will protect the marine environment before, during, and after deep sea mining operations. It is mandatory for any contractor applying for an exploitation license from the International Seabed Authority (ISA) or from a national government.
Eureka I, II, III. IV = Underwater robots (more formally called autonomous underwater vehicles, or AUVs) designed by Impossible metals for selective harvesting of polymetallic nodules from the ocean floor.
Eureka Collection System = The complete system for commercial mining of polymetallic nodules designed by Impossible Metals. This consists of the Eureka AUVs, SLARS, Vessel based media handling, Charing and battery swapping, Mainetance.
EV (electric vehicle) = vehicle that uses one or more electric motors for propulsion.
Exploitation license = a formal legal authorization that allows an entity to begin commercial extraction of mineral resources from the deep seabed. It follows an exploration license and is issued only when the contractor meets strict technical, financial, and environmental criteria. Also known as a ‘recovery permit’
Exploration License: a formal legal authorization that grants a company or government entity to
- Conduct geological, biological, and environmental surveys
- Collect small quantities of mineral samples
- Evaluate commercial mining potential & define the resource size & economic potential
- Develop an environmental baseline
- Design an Environmental Management and Monitoring Plan (EMMP)
It does not allow commercial-scale mining. That requires a separate exploitation license or recovery permit.
ISA (International Seabed Authority) = autonomous international organization that organizes and controls all mineral-resources-related activities in the Area for the benefit of humankind.
LARS (launch and recovery system) = a device that helps safely launch and recover autonomous underwater vehicles (AUVs) and remotely operated vehicles (ROVs) from a ship.
L(M)FP (Iron, manganese, phosphorus) = battery chemistry cathode
Megafauna = animals of a given area that can be seen with the unaided eye.
NCA (nickel, cobalt, aluminum) = battery chemistry cathode
NMC (nickel, manganese, cobalt) = battery chemistry cathode
National Oceanic and Atmospheric Administration (NOAA) = a U.S. federal agency within the Department of Commerce focused on understanding and managing the nation’s oceans, weather, climate, and coastal resources. NOAA conducts research, provides forecasts, monitors environmental conditions, and supports marine conservation to protect ecosystems and public safety.
Outer Continental Shelf Lands Act (OCSLA) = a U.S. law enacted in 1953 that governs the exploration and development of offshore mineral and energy resources, including oil, gas, and renewable energy, on the Outer Continental Shelf (OCS). It authorizes the federal government, primarily through the Department of the Interior, to lease areas of the OCS, regulate activities, and ensure environmental protection and resource conservation during offshore operations.
PMN (Polymetallic Nodules) = ‘nodules’ also known as manganese nodules, are mineral concretions on the ocean floor that contain valuable metals. See Wikipedia.
Prospecting = in mining is the first stage of the mineral resource discovery process. It involves searching for evidence of valuable minerals or metals in a specific area, usually through preliminary surveys and testing, before any drilling, excavation, or large-scale operations begin.
PSV (Production Support Vessel) = large surface ship that serves as the central facility for deep sea mining operations. PSVs are typically modified from dynamically positioned drillships used in the oil and gas industry. Their primary functions are to:
- Collect, gather, lift, and temporarily store polymetallic nodules
- Store, maintain and control the dredging tractor and riser system
- Dewater the nodules
- Provide power, control, and guidance to the subsea collector
- House the crew that monitors and runs the operations
The temporary storage of nodules only has capacity for a few days of storage. When full, a Shuttle Transport And Resupply Ship (STARS) is required to transfer the nodules to port.
Note: Impossible Metals does need PSV.
Regulator = a governmental or intergovernmental authority responsible for creating and enforcing the rules that govern mineral activities in the ocean, especially in areas beyond national jurisdiction. These regulators ensure that mining is done responsibly, sustainably, and legally, balancing economic interests with environmental protection. E.g. ISA, BOEM, NOAA, SBMA.
REEM (Rare Earth Element Muds) = ‘Muds’ mainly contain rare earth elements in the seabed sediment.
ROV (Remotely Operated Vehicle) = free-swimming submersible craft used to perform underwater observation, inspection and physical tasks. The vehicle is tethered to the vessel.
SBMA (Seabed Minerals Authority) = is the national regulatory agency of the Cook Islands responsible for managing, regulating, and monitoring activities related to the exploration and potential exploitation of seabed minerals in the country’s Exclusive Economic Zone (EEZ)—one of the largest in the world.
Selective Harvesting = Rather than scooping or vacuuming everything in sight, Eureka underwater robots identify and pick up individual nodules while avoiding sensitive habitats, visible organisms, or sediment. This approach minimizes disruption and improves sustainability.
Sediment Disturbance = This occurs when mining activities disturb the ocean floor, creating small sediment disturbance.
Sediment Plume = Large cloud of disturbed seabed sediment from deep sea mining operations. Impossible Metals’ AUVs hover above the seafloor, avoiding direct contact and significantly reducing this impact compared to traditional dredging and do not create enough sediment disturbance to form a plume.
SLARS (Smart Launching and Recovery System) = Impossible Metals technology which allows full autonomous operations of the LARS with a vessel without DP and in a wide range of sea states.
SMS (Seafloor Massive Sulfides) = ‘Vents’ appear on and within the seafloor when mineralized water discharges from a hydrothermal vent.
STARS (Shuttle Transport And Resupply Ship) = specialized ships with DP used to supply the mining Production Support Vessel (PSV). Key tasks performed are:
- Transfer of nodules from the PSV
- Transport of those nodules to the processing facility
- Transport of equipment, fuel and provisions to the PSV
- Transfer of personnel to and from the PSV per crew rotas
Note Impossible Metals does not need STARS.
TAM (Total addressable market) = metric that estimates the maximum revenue potential for a product or service if it were to capture 100% of a market.
Tailings: Waste materials from mineral processing, sometimes discharged into the ocean.
UNCLOS (United Nations Convention on the Law of the Sea) = established a comprehensive international legal framework to govern activities related to the global oceans.
USBL (ultra-short baseline) = method of underwater acoustic positioning and wireless communication as GPS and WiFi do not work underwater.
