Response to Franklin & Marshall Professor’s Deep Sea Mining Op-ed

We recently came across an opinion piece published by an associate environmental policy professor at Franklin and Marshall College entitled, “Reducing carbon emissions can’t come at the expense of our oceans.”  The article appeared on The Hill website on 10/15/23, and it argues against extracting polymetallic nodules – mostly on environmental grounds. 

We have written previously about the lack of critical thinking that characterizes most if not all of the opposition to the extraction of deep-sea polymetallic nodules.   

“Critical thinking is a vital and fundamental skill we’re all taught in high school. It means analyzing all of the available facts, evidence, observations and arguments to form a judgment that is based on rational, skeptical, and unbiased analysis. Employing critical thinking skills is a must when it comes to making decisions on complicated issues.”

COMRC.org

Unfortunately, this opinion piece showed the same deficiencies that have come to define the anti-deep sea extraction activist movement.  It was highly biased and riddled with inaccuracies, unsupportable facts, and pertinent omissions.  All the same, we wanted to highlight the article because it was authored by someone who is supposed to be teaching students how to think (as opposed to what to think).  Our hope is that an administrator, a faculty member, a student, or even a parent of a student would take note of our critique and remind this professor of the paramount importance that critical thinking should play – particularly in the classroom.        

The paper’s lack of robust analysis is evident from the start.  The author’s title point, that we don’t want to sacrifice our oceans in the name of reducing CO2 emissions, implies that by collecting nodules (the form of extraction that is being considered at the United Nations) to produce energy transition minerals, we will sacrifice our oceans. 

The professor writes:

“We face a consequential choice: Will we finally protect the unique and fragile organisms found in the largest and least disturbed ecosystem on Earth? Or, in an attempt to curb the damage already caused by fossil fuels, will we destroy these species and habitats they depend upon before we have even discovered them?” 

The Hill

Yet, the choice the author poses is a false one.  Let’s dig deeper and see if objective analysis reveals that there’s a reasonable risk that picking up polymetallic nodules from the floor of the ocean will sacrifice the ocean and the ecosystems upon which ocean organisms depend for survival. 

First, let’s try to put some context around this issue by understanding how much of the abyssal plains (the deep ocean floor at 4,000-6,000 meters depth, where nodules exist) may be at risk from nodule collecting.  Based on an operator’s estimate that a nodule harvester will cover approximately 2,000 to 2,500 km2 of ground over 20 years, we can get a feel for the area of abyssal plains at risk from the direct touch of a harvester.  Using estimates from the International Energy Agency, we calculate the requirements for electrifying the global EV fleet, and then we assume that all cathode materials for nickel-cobalt-manganese(“NCM”) lithium-ion batteries will be supplied by polymetallic nodules (1.567 ktons nickel, 257 ktons cobalt, and 246 ktons manganese annually per IEA estimates) (IEA, 2021). This is an unrealistic assumption because terrestrial mining will also supply these minerals, but we want to give the author the benefit of doubt and test a worst-case scenario to see if it will sacrifice the ocean. 

To create the volume of cathode metals required to electrify the entire global auto fleet over the next 20 years, until some circularity cuts the demand for primary metals, would require 120 harvesters.  Those 120 harvesters would cover an area of 0.1% of the abyssal plains over the 20-year period (300,000 km2 area of collection vs. abyssal plains of 300 million km2) (Britannica).

It is a stretch to imagine that picking up these small rocks from 0.1% of the abyssal plains would sacrifice the ocean.  The idea is akin to claiming that farming 0.1% of our land will destroy the earth’s terrestrial habitats and all of the world’s land-dwelling creatures.  Still, we need to understand whether indirect effects from the extraction operations could spread over much wider areas.  Those indirect impacts would be driven by plumes of sediment (noise and light are also a factor but are less consequential and we treat these threats on comrc.org).  As the harvesting vehicle works the ocean floor, it creates a plume, much like a farm harvester does as it works a field.  In addition, some collection systems use riser pipes, similar to the oil and gas industry, to lift nodules from the seafloor to the surface, and the sediment and bottom water that accompanies nodules must then be returned to the ocean creating the potential for a separate plume. 

Some contractors have, in the past, indicated that the sediment return discharge could happen at approximately 1,200 meters depth, below the pelagic layer (where most fish roam the seas), but that release depth would be subject to change based on a careful study of midwater sediment plumes.  While studies have indicated that midwater plumes can be managed effectively, subject to environmental constraints, a midwater plume is likely the most controversial aspect of nodule harvesting.  That plume might migrate to layers inhabited by pelagic species, and it could travel long distances, albeit at minute concentrations.  Yet, our understanding, based on presentations from operators, reveal that no midwater plume is necessary.  The most advanced operator, The Metals Company, indicated at a presentation in the fall of 2023 that it will return sediment to the bottom, avoiding the need for a midwater plume.  Meanwhile other operators use alternate lift system technologies and avoid sediment and bottom water transport to the surface entirely (Impossible Metals). 

Without midwater plumes, we are left with benthic plumes from the harvester, and while certain environmental groups assert that these plumes can travel hundreds of kilometers, this isn’t what the empirical data and research says (DSCC website).  In fact, The Metals Company (“TMC”) recently hosted an open discussion on the results from plume studies on their nodule collecting operation which completed in 2022.  Those studies demonstrated that bottom water plumes do not extend upward more than a couple meters and resettle within 1,000 meters of the harvester (TMC news).  In other words, our worst-case figure of 0.1% doesn’t need to be increased for plumes.  Thus, there is no mechanism by which harvesting could destroy the ocean as the author asserts, assuming no midwater plume (even with a midwater plume, the idea is outlandish based on empirical data on plume dispersal physics) (MIT study).   

Even if the author’s lead point about sacrificing the oceans to extract minerals is false, we should nonetheless try to understand the potential damage from the activity as part of our critical thought process.  Will collecting nodules really destroy the 0.1% of abyssal plains that are impacted?  That’s not what the data say.  In a recent study of collection impacts on foraminifera by marine scientist Bryan O’Malley and his team of researchers, we learned that a collector will cause a 20% reduction in biodiversity within the collection area, and a 0% decrease to biodiversity in the plume zone (O’Malley, 2023).  In fact, researchers have been studying benthic impacts from harvesting operations for around 45 years, and the data we’ve seen from those studies is similar to the more recent work, so there is a fairly robust set of long-term data supporting the case (Gausepohl, 2020).  More detailed information will nonetheless be gathered as operators progress extraction activities.   

We can go a step further and note that operators will also be required to “set aside” significant contiguous portions of their license areas to allow for speedier recolonization.  These set-aside areas could be as great as 30% of the licensed area or more (Pew, 2018).  In addition, contractors may be required to “leave behind” a certain percentage of nodules in the area that they cover to encourage recolonization (from discussion with an operator).  Each of these protective measures could further reduce the amount of biodiversity that is lost due to the activity.  In any case, the idea that the benthic environment would be completely destroyed by a harvester rolling over the plains, lifting up nodules as it proceeds, is not based in fact. 

We’ve established the kind of damage that can be expected from nodule collecting, but critical analysis demands that we put that information into context.  While a 20% or even a 35% reduction in biodiversity is not ideal, when it comes to mineral extraction very little is ideal.  Minerals are required to make goods for society, and those minerals must come from somewhere. If we don’t collect nodules, then we will have to mine from terrestrial sources. 

A typical terrestrial battery mineral mine requires clear cutting what is most often a tropical rainforest, and digging 10-100 meters into the earth, destroying approximately 100% of the biodiversity in the mine footprint and recovering ore with grades of around 1% vs. the 100% grades for nodules (Giljum, 2022).  In addition, the mines often create indirect impacts that extend much farther than the mine site (Siqueria-Gay, 2020).  Fresh water sources are lost, entire watersheds may be polluted with toxic chemicals, people are displaced, new infrastructure must be constructed in pristine habitats, people are exposed to air that is polluted with particulate matter and toxic emissions, tailings ponds are created that may overflow during typhoon season, and human lives are lost to disease and to dangerous working conditions. 

To be clear, we cannot recycle, reuse, or innovate away the need for these base minerals as many environmental NGOs suggest (WWF, 2022).  If we could, we would have done so many years ago.  In fact, the demand for primary metals is set to expand in unprecedented fashion over the next two decades to accommodate the energy transition, so the idea that we don’t need new stocks of minerals will only become more fanciful in the future.  Minerals must come from somewhere, and it is up to us to use our critical thinking skills to discern where we can source these minerals most efficiently – at the least cost to the environment and to society.  The evidence points to the fact that collecting nodules can be managed in a manner that causes far less damage than many of the alternatives. 

“While the recycling and reuse of minerals can play a key role in reducing emissions, mining will still be required to supply the critical minerals needed to produce these low-carbon technologies, even with large future increases in recycling rates.” …..“Technology and subtechnology choice, material substitution, and technological improvements will shift the demand for individual minerals under different low-carbon scenarios. Still, any lower-carbon pathway will increase the overall demand of minerals.” 

(World Bank, 2020)

It is also important to note what is at stake as we compare different forms of mineral extraction.  The level of biodiversity on the abyssal plains is relatively modest.  A recent study noted that an estimated 8,000 metazoan species may inhabit the massive Clarion Clipperton Zone abyssal plains, and that the majority of those species are invisible or barely visible to the human eye (Rabone, 2023).  By contrast, tropical rainforests are believed to be the most biodiverse habitats on the planet with some sources claiming that half of the world’s species (around 4.4 million species) are found in these habitats (Pillay, 2021) (Mora, 2011).  Most of the tropical rainforest organisms are visible to the human eye, and are far more complex than the microbes the author aims to protect on the seafloor, and a great number of them are endangered species (NIH, 1988). 

We don’t know enough about either ecosystem to make definitive proclamations, because 85-95% of species remain unknown in both of these habitats, but we do know that tropical rainforest ecosystems are far more threatened than are the abyssal plains (Mora, 2011).    

Objective readers will note that the alternative to nodule collecting is highly invasive strip mining in the world’s most sensitive habitats where humans are also at risk.  Humans have almost no risk from nodule collection operations (absent a midwater plume, as previously discussed).  Terrestrial battery mineral mines can cause significant damage to human populations – whether from displacement, from the pollution of fresh water supplies, from the reduction of native food availability, from dumping processing waste in the ocean, from the coal plants that generate power for processing, or from the toxic airborne emissions (Ilagan, 2021).  This is particularly true for mines run by Chinese outfits which often disregard regulations that protect workers and the environment (HRW, 2011).  It is important that activists who pursue an agenda against nodule collecting understand that their work is helping to perpetuate human suffering in some of the most vulnerable populations in the world (Pandapaw, 2023). 

Now that we have addressed the false choice embedded in the title of the article, we can dig into the body of the opinion piece.

The author writes:

“There are not only new and wondrous plants and creatures to be discovered in the deep sea, but also new drugs and treatments derived from this rich biodiversity, which are helping us combat cancer and HIV.” 

The Hill

The author is an environmental sciences professor so one would expect that she would know that there is no plant life on the abyssal plains (where nodules are collected) because the waters are so deep (around 5,000 meters or 3 miles in depth).  Sunlight can only penetrate to around 200 meters depth, so there’s no photosynthesis on the abyssal plains (Study.com).  While the point may seem trivial, it is nonetheless a clear indicator of the author’s surprising lack of subject-matter understanding.   

The author also provides misinformation with respect to the deep-sea originated treatments she cites.  We dug into the links she provided and found that those treatments don’t come from the deep sea at all.  They were found in organisms at 0-30 meters depth.  While this indicates sloppy and biased work, and a possible intent to manipulate the audience, we don’t dispute the author’s point that it is entirely possible that we may find valuable medical treatments from tiny creatures in the deep ocean on the abyssal plains.  If we do, however, it will be because of the large sums of money that contractors are investing in researching these environments, and not in spite of the work that these groups are doing.    

The point that we should study the biodiversity present on the abyssal plains is a good one.  It is one that marine operators take seriously given that they pay for the work being done to study marine life.  Relatively little work was being done on the abyssal plains prior to the efforts of operators.  The fact is that it is very expensive and time-consuming to do this work, and it is only because of the potential commercial interest in the abyssal plains that we are gaining access to much of this information.  This brings us to the next point in the note in which the author discusses a proposed moratorium. 

There are a number of bodies calling for a moratorium on nodule collecting until more work is done on the research and regulatory front.  What this author and the various institutions and enterprises that call for a moratorium do not seem to grasp is the fact that a moratorium would discourage progress on the research and regulations that they demand (more likely, they completely understand this and that’s the point!).  It is expensive to do the research and convene all of the experts that these parties demand, and a moratorium would starve the industry of the limited amount of capital available to it now.  After all, who would invest in a company whose only source of revenue is under a moratorium of indeterminate length and which is largely influenced by environmental NGOs who wish the industry would simply go away?  There are much easier ways to make a return. 

As we’ve written elsewhere, the moratorium is actually a device being used to shut down the industry.  The people who request the moratorium don’t want progress.  They don’t want research.  The more research that is published, the more their scare stories are debunked.  As if to prove our point, Greenpeace activists recently illegally commandeered a research vessel and physically forced a stop to ongoing environmental research on nodule collecting impacts (Maritime Executive, 2023). 

There is 45 years’ worth of research available on long-term impacts from nodule harvesting, and it all points in the same direction (Gausepohl, 2020).  Nodule collecting causes damage to the benthic environment, but the relative paucity of biomass and biodiversity, and the non-invasive nature of collection mechanisms, mean that these impacts are dramatically lower as compared to alternatives (Paulikas, 2022) (Benchmark Mineral Intelligence, 2023). We have plenty of information to begin careful and limited nodule collecting today, and the precautionary principle demands that we do so to avoid the serious consequences associated with strip mining in tropical rainforests. 

The author claims that “Vacuuming nodules off the sea floor will cause drifting plumes of sediment that smother filter feeding species such as deep-sea corals and sponges.”  No references are provided.  No studies are cited.  Yet, as discussed previously, the bottom plume from a collection vessel has been carefully studied.  It doesn’t travel very far (around 1,000 meters) and the damage caused by the plume is highly manageable based on the empirical data (Nori Update, 2023).  The O’Malley study on foraminifera cited a 0% decrease in biodiversity in the plume zone with a 0% decrease in biomass density (O’Malley, 2023).  The author makes no mention of the fact that plumes from terrestrial mining sites travel further than they do on the abyssal plains and are laden with toxic particles that end up in human food supplies and human lungs.     

The author claims that it is misleading to argue that nodule collecting is more sustainable than land-based mining.  While researchers present hundreds of pages of carefully accumulated data and analysis to support their life cycle analyses which point to astounding levels of improvement in terms of environmental and societal costs when we pick up nodules vs. mine on land, the author seems to make her assertion based on a hunch (Paulikas, 2022) (Benchmark Mineral Intelligence, 2023).  She provides zero support for her contention, yet she expects her readers to go along for the ride.  We provide a chart below from the Paulikas study showing the reduction in impacts from nodule collecting vs. the alternative along a number of pathways. 

The author goes on to suggest that there are other technologies which do away with the need for nickel and cobalt in batteries, and thus there is no longer a need to gather nodules.  There are two major problems with this rationale.  First, the minerals in nodules are in demand regardless of whether or not batteries are part of that demand.  We gain enormous benefits as a society if we can capture these minerals more efficiently (lower environmental, social, and economic costs) by collecting nodules rather than mining on land no matter the end market that the minerals serve. 

Second, almost all battery experts agree that ternary (nickel, cobalt, manganese) lithium-ion batteries are going to part of the solution for many years to come.  A variety of different battery chemistries and formats are emerging, and each will likely have success in different end markets depending on the unique demands of the end market. Yet, ternary lithium-ion batteries provide the market with the best energy density of current technologies, so where mobility and range are important, these chemistries are going to be a factor for a long time (Benchmark, 2022).  If we want to encourage an energy transition, the last thing we should do is constrain choices or constrain the availability of minerals, because doing so will lead to suboptimal solutions and higher prices which will only encourage a slower energy transition.    

The opinion piece then notes the fact that oceans provide a valuable buffer against climate change due to their absorption of heat and the large carbon sink which oceans represent.  All true enough, however, focusing on CO2 sinks contradicts the author’s objective of undermining the case for nodule extraction.  There is virtually zero release of sequestered carbon in a nodule collecting operation that doesn’t use riser pipes, and the amount of sequestered CO2 released when risers are used is infinitesimal relative to the release in terrestrial operations (TMC webinar). 

This point is reflected in the multiple life cycle analyses which we have already referenced and confirmed in operating data from The Metals Company.  The LCAs indicate a reduction in sequestered CO2 release associated with nodule collecting vs. terrestrial mining of over 90% (not to mention a 70% reduction in CO2 emissions).  At the depths of the abyssal plains, mobilized sediment containing previously sequestered CO2 does not migrate upward to the surface (IPCC, 2018).  The CO2 at these depths is denser than seawater and simply returns to the sediment after being mobilized.  At the other end of the spectrum, a terrestrial strip mine will destroy all of the vegetation in a footprint and then must unearth approximately 500 tons of rock to produce 1 ton of target mineral, initiating the release of vast stores of CO2 (based on a 4:1 strip ratio and 1% grade of ore).  Thus, if our principal goal is to reduce CO2 emissions and the release of sequestered CO2, then it is obvious that we should substitute as much terrestrial mineral production for nodule collection as is possible, as soon as is possible.   

The author concludes that we must find greener solutions to fuel a sustainable energy transition.  It’s an excellent point, and we think that few people would disagree.  We should always look for ways to improve efficiencies and to do less damage.  It was precisely that pursuit that has led us to nodule harvesting as an alternative.  Capturing these the nodules represents a giant step forward for humanity.  They offer a pathway to the transition that is far less costly to the environment, to human health, and to our pocketbooks than the alternatives.  We would suggest to the author that we cannot hope to find greener solutions when we close our eyes to the solutions that we discover.  Critical thinking opens our eyes.   

While some will dismiss the opinion piece on The Hill as just one more harmless rant by a fringe activist, we know better.  We have witnessed the ill-effects from the type of misinformation that this professor is peddling.  It has an impact on corporate and government decision making and thus is quite dangerous.  It is important that editors, activists, students, administrators, politicians, and everyone who cares about finding the best path forward understands the damage that misinformation can cause.   

If campaigns built on misinformation win, and we move forward with a moratorium, by default we will need to lean into the most invasive and destructive forms of extraction known, in environments that are far more sensitive and endangered than the abyssal plains, in geographies that depend on coal-fired generation to power industry,  in jurisdictions that are known for their weak governance of human rights and environmental protection.  These problems will compound quickly as the energy transition hits an inflection point, and mineral demand intensifies while ore grades decline, causing ever increasing levels of damage per unit of mineral extracted (Calvo, 2016). 

A moratorium will threaten the energy transition with higher economic costs due to the scarcity of many minerals and the high costs of terrestrial operations (Benchmark, 2023).  It will also threaten the credibility of the transition as we are forced to burn more and more fossil fuels to extract a unit of mineral and as we release massive quantities of sequestered CO2.  The moratorium will hand China a consequential victory as it will insure our continued reliance on that country for the critical minerals in question for a period of time that could run decades (Diplomat, 2023).  The Chinese have shown a willingness to leverage that reliance to gain political, economic, and military advantage (WSJ, 2023).  It will threaten our national security as we will remain beholden to China and other adversarial powers for minerals that are vital to our national defense and economic health.  Finally, it will mean losing more ground economically to nations who are better positioned with respect to terrestrial mineral sources.  The research and development that accompanies many consumer-oriented businesses will shift to countries that have guaranteed access to the minerals to build those products.  Hopefully readers will understand the seriousness of these matters and thus the need for solid critical analysis as we search for a solution.   

Finally, though we disagree with the author on most points in her opinion piece, we respect her right to voice her opinion, even if that opinion is filled with misinformation and misunderstanding.  Our belief is that a sensational headline and alarmist content may serve as good click bait, but in the end analysis the truth will make itself known.  Activists and editors alike should think about where that truth will leave them. As Warren Buffet is fond of saying, “It takes 20 years to build a reputation, and five minutes to ruin it.  If you think about that you’ll do things differently.”  Here’s hoping that these groups start to think about doing things differently.   

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