That is the purpose of the Environmental Impact Assessment (EIA), which must be conducted before any mining is approved. This work typically takes 3-5 years and is performed under an exploration license that does not allow commercial mining. The cost is typically around $30–80M USD and requires many baseline studies with hundreds of scientists. All this data is made public. A regulator will decide if deep sea mining can start commercial operations only after the impacts are known.

For more details on the EIA, see this blog post.

There are 22 exploration-licensed areas for nodules. Let’s assume all areas go into production and no new areas are added. The average size of each licensed area is 75,000 sq km. Only 50% of that area is mined due to sea slopes, leaving marine protected areas. So the impacted area is approximately 22 * 75,000 * 50%  =  825,500 sq km over 30 years. The total surface area of the world’s oceans is approximately 361 million square kilometers. So deep sea mining for nodules will likely be just 0.23% of the world’s oceans after 30 years. 

In the case of Impossible Metals, we have committed to leave 30% of the nodules undisturbed by weight which is 60% by numbers, so the number would reduce to 577,850 sq km. or 0.16% of the world’s oceans.

Every year, 1.4% of the ocean is impacted by trawling fishing, according to a paper published in nature.

No. Although the ocean is the largest carbon reservoir on Earth, holding significantly more carbon than the atmosphere or terrestrial biosphere, sequestering about 25% of the annual anthropogenic CO2 emissions released into the atmosphere.

Less than 1% of the CO2 sequestered in the ocean’s upper layers reaches the deep sea floor annually. As the carbon-based organic matter sinks to the bottom of the ocean, much of it is processed before reaching the ocean floor. ​​Due to lower productivity and reduced input of organic matter, deep-sea sediments have an overall low organic carbon content of approximately 0.05% of the dry weight of the sediment. Nodules do not sequester CO2 and do not contain a meaningful amount of carbon. Sediment disturbed by the collector vehicle has no pathway to the atmosphere. Local sediment disturbance has shown not to rise more than a few meters, many meters away from phytoplankton, which need light for photosynthesis. Impossible Metals has no riser system with a discharge plume, so this will not impact phytoplankton photosynthesis.

Impossible Metals has committed to Net Zero, so we will either offset any emissions from the ships, charging of the underwater robotics and metal refining, or use new technology to remove these emissions.

See more details in the ISA Fact-check 2024/1 – The carbon cycle in the Area.

No. 90% of global fishing activities are carried out within Exclusive Economic Zones (EEZ) and Extended Continental Shelf (ECS). Most deep sea mining exploration is in areas beyond national jurisdiction (‘area’), although the Cook Islands and India will have deep sea mining within their EEZ. Local sediment disturbance has been shown not to rise more than a few meters, many meters away from phytoplankton (food for fish), which needs light for photosynthesis. Impossible Metals has no riser system with a mid-water discharge plume, so this will not impact phytoplankton photosynthesis. 

See more details in the ISA Fact-check 2024/2 – Status of fishing activities in the Area.

There are a few categories of concerns about the potential impacts of deep sea mining. Impossible Metals’ approach from our founding has focused on removing or minimizing these concerns to create the most environmentally responsible form of mining.

1. Loss of Biodiversity: Identifying new species during deep sea exploration is common. These creatures may hold unknown discoveries for science or medicine, and there is concern that deep sea mining could result in their loss before we know they exist. Although “protected areas” (the ISA calls them “areas of particular environmental interest” [APEIs]) are left as non-mining areas, these protected areas are significantly distant from the mining areas, so the biodiversity in these areas differs from the mining areas.
2. Sediment Disturbance & Pollution: Deep sea mining may disturb sediment, which can have various impacts, such as:
   1. Disturbance of animals that live in the sediment. These are typically small (or very small) creatures that spend all or part of their lifecycle under the upper layers of the very fine deep sea sediments.
   2. When sediment is disturbed, it sinks to the seafloor, which can smother animals that cannot move out of the way, like deep sea corals.
   3. Increasing toxicity in the water can harm marine organisms and bioaccumulate/magnify. This could impact fish food sources.
   4. Potential for release of stored carbon in sediment.
3. Noise & Vibration Disturbance: Equipment used in the ocean may have sounds or vibrations associated with them, from the motors running dynamic positioning (DP) systems to keep ships in place to electromagnetic waves from various monitoring or communication systems. Plenty of sea creatures use particular wavelengths to communicate, like whales. Noise and vibration from deep sea mining have the potential to impact this communication, which could result in changing behaviors or migratory pathways.
4. Light Disturbance: The abyssal plains where nodules form are very deep (4-6 km) and, therefore, very dark. There is concern that the introduction of light sources could impact sea creatures.
5. Loss of Hard Surface: Polymetallic nodules often represent the only hard surface in these abyssal ecosystems, where the rest of the seafloor is composed of very fine sediment. Some animals attach to the nodules, like deep-sea corals and sponges. Other animals use the nodules to move around, similar to how it takes less energy for a person to walk on a sidewalk than on soft sand.
6. Emission of Greenhouse Gasses: Management of emissions will be a key task for the deep sea mining industry. Ship fuel will account for a significant proportion of emissions, providing energy for ship movement and the variety of tasks the ship will perform. This includes ship dynamic positioning (DP) and the riser system in a traditional architecture.

Impossible Metals was explicitly founded to address the environmental concerns surrounding deep sea mining of polymetallic nodules, so here’s how we address each of the five concerns listed in the previous answer:

1. Loss of Biodiversity: By avoiding picking up visible life (megafauna) and leaving behind a percentage of nodules, our system minimizes the potential for destruction of animals for their own sake, for the ecosystem, and for any potential human uses.
2. Sediment Disturbance & Pollution: Our underwater robots—formally known as Autonomous Underwater Vehicles (AUVs)—have a variety of features that minimize sediment disturbance:
   1. Our AUVs hover over the seafloor so they do not disturb sediment from landing or driving over the seafloor.
   2. The buoyancy engine makes the robot positively buoyant while it hovers over the seafloor, meaning thrusters push upward, not downward into the sediment.
   3. Robotic arms/claws pick up nodules individually, minimizing sediment pickup.
   4. The AUVs move up and down the water column, avoiding the need for a riser pump system and its discharge plume.
3. Noise & Vibration Disturbance: Our sound emissions are relatively low. Most sound subsea will come from the acoustic communication system, subsea thrusters, and buoyancy pumps. The surface sound will be from the ship and the launch and recovery operations of the underwater robot. As part of our equipment’s environmental design basis, we have aimed to generate minimal sound. In particular, we have aimed for minimal sound compared to dredge-based equipment. Substantial sound comes from DP {Dynamic Positioning) ships and the riser system. We do not require DP or risers. Our sound profile is small compared to other technologies.
4. Light Disturbance:  Today, we use visible white light. We are working with marine scientists to determine the best wavelength (color) to have the least impact. In production, we may reduce the light power by using more sensitive sensors in our cameras. We will work with scientists to measure the effect on the marine ecosystem.
5. Loss of Hard Surface: Selective harvesting allows us to leave behind a percentage and/or pattern of nodules that maintain the ecosystem’s hard surface and avoid nodules with attached visible life (megafauna). Our current economic models assume we will leave 20% of nodules behind, but this estimate will be refined through study and discussion with scientists.
6. Emission of greenhouse gasses: Our plan for producing responsible metals includes a commitment to net zero. This means we will minimize emissions as much as possible, and use carbon offsets for any remaining impacts. We report annually on our environmental impact. Our selective harvesting system design minimizes emissions in the following ways:
   1. AUVs are electric, and we are investigating renewable energy sources for battery charging
   2. No riser pump, ship-to-ship transfer, or onboard separation of nodules from sediment and water
   3. We are working on a launch and recovery system that does not require our ships to have dynamic positioning.

The only way we can prove our impact level is to collect nodules from the seafloor, so that is what we will do. We will carry out a test where our robot picks up nodules, typically called “component testing” or “test mining,” depending on scope. During this test, there will be a wide range of environmental monitoring to characterize the environmental impact, including sediment monitoring and a photomosaic with detailed imagery before and after the test. Before the test, sediment modeling will be carried out to estimate the sediment disturbance. Impossible Metals is committed to transparency about all modeling and monitoring results.

Impossible Metals is collaborating with BGR to test our hovering selective harvesting robot for collecting critical metals from the seabed. See the press release.

Impossible Metals started engaging with marine scientists early in our company’s history, with initial discussions about selective harvesting in April and May 2022. Since then, we have continued to engage scientists to discuss vehicle testing and monitoring and will continue to carry out this engagement as we develop our technology. Additionally, we will leverage the expertise of marine scientists to monitor the environmental impacts of selective harvesting during testing.

See the roundtable summaries.

• Protects safety and human rights.
• Are carbon neutral.
• Maximizes the potential for recycling and circularity.
• Eliminates toxic waste.
• Avoids widespread habitat destruction.
• Avoids water scarcity.
• Avoids loss of biodiversity.
• Avoids displacing Indigenous people or communities.

Impossible Metals has published the following data to its public data folder:

• ESG Annual Reports
• Eureka I Demo Days May 17-18, 2023
• Eureka II Demo Days Nov 12-13 2024
• Eureka III BGR test in CCZ
• MediaKit
• Ocean Deployment – Public Data
• Public Presentations
• Scientific Engagement Round Table Reports
• Techno Economic Analysis (TEA)

SDG Goal 5 – Achieve Gender Equality and Empower All Women and Girls

SDG Goal 6 – Clean Water and Sanitation

SDG Goal 7 – Affordable and Clean Energy

SDG Goal 9 – Innovation, Industry and Infrastructure

SDG Goal 12 – Responsible Consumption & Production

SDG Goal 13 – Climate Action

SDG Goal 14 – Life Below Water

SDG Goal 15 – Life on Land

If you were to point to a random point in the deep ocean, we likely would need more information to start mining there. However, the areas proposed for deep sea mining are some of the best-explored areas of abyssal plains in the world. In international waters, at least three years of environmental baseline information must be collected, characterizing biodiversity and the ecosystem, the physical and chemical characteristics of the water and sediment, and their interactions. Some exploration permit holders have been doing baseline studies for over 20 years! For more on this topic, check out our blog, “Data from the Deep Seabed – What Do We Know?”

Currently, deep sea mining is not occurring. Existing industries that impact ocean life are fishing (particularly bottom trawling), oil and gas, offshore wind, and shipping. Bottom trawling is of particular concern as it scrapes the ocean floor, destroying and disrupting habitats and ecosystems. Bottom trawlers catch 26 percent of the total global marine fisheries catch. Additionally, many industries contribute to the global issue of climate change, which impacts the ocean through warming, deoxygenation, and ocean acidification.

Land-based nickel mining has significant environmental impacts, with the severity varying based on the regulatory frameworks in different jurisdictions. Indonesia and the Philippines produced 58.2% of the world’s nickel in 2022, largely from deposits located beneath rainforest ecosystems. In addition to environmental destruction, poor social protections put local communities at risk, including Indigenous communities, which have the right to free, prior, informed consent under the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP).

Watch a video about Indonesian nickel mining (BBC News)

Watch a video about Philippines nickel mining (FRANCE 24)

The Democratic Republic of the Congo (DRC) supplies an overwhelming 68% of the world’s cobalt and has half of global land reserves, so the significant impacts in the DRC are especially notable. Amnesty International reports that cobalt (and copper) mining in the DRC has led to “the forced eviction of entire communities and grievous human rights abuses including sexual assault, arson, and beatings.” Additionally, it is well-documented that DRC mines use child labour. The US Department of Labor states that, “While mining is on the DRC’s list of hazardous activities for which children’s work is forbidden, the majority of cobalt mining in the DRC is done informally, where monitoring and enforcement are poor.” These social issues in the DRC are compounded by environmental hazards, such as deforestation, toxic tailings, and soil erosion/degradation that further threaten human health and wellness.

To learn more, check out “Cobalt Red”, a book by Siddharth Kara.

We want the environmental bar to be set high and for the industry to innovate to reach it.  A ban would stop innovation and remove significant funding for scientific research. It is well established that we will need a lot of critical minerals for the energy transition away from fossil fuels (e.g. IEA, World Bank Group). Deep sea mining represents an opportunity for environmentally and socially responsible access to these resources. Consumer demand for responsibly sourced materials is rising, so we should define what that looks like and empower the innovators to do their work. We also feel that a holistic approach to critical minerals is required. A deep sea mining moratorium, pause, or ban would only result in more land-based mining impacts and will make it impossible to achieve Net-Zero by 2050.

A number of countries are listed as having signed up for a moratorium, pause, or ban. Although these countries may have made public statements, the vast majority have not passed legislation. In fact, these countries have signed UNCLOS, which legally commits them to deep sea mining regulated by the ISA. Some of these countries have sponsored exploration applications. If they legally supported a moratorium, pause, or ban, they would be in violation of their legal obligations and could lose their exploration areas.

A number of companies are listed as having signed up for a moratorium, pause, or ban. The wording says, “Before any potential deep seabed mining occurs, it needs to be clearly demonstrated that such activities can be managed in a way that ensures the effective protection of the marine environment.” This is the purpose of the Environmental Impact Assessment (EIA), which must be approved by the regulator before any mining can start. After a regulator approves an exploitation application, the EIA will provide for protecting the marine environment. So, any companies that have signed the moratorium will be free to purchase deep sea minerals.

See this blog post for more information.