Deep Seabed Mining: Notice of receipt of application for deep seabed mining exploration license from American Metal Resources, LLC (AMR)

Mr. Kerry Kehoe Office for Coastal Management National Oceanic and Atmospheric Administration (NOAA) Dear Mr. Kehoe, I am writing in strong opposition to the American Metal Resources, LLC and SeaX's applications for two exploration licenses under the Deep Seabed Hard Mineral Resources Act — Docket NOAA-NOS-2026-0034; NOAA-NOS-2026-0035, Notice NOAA-NOS-2026-0034-0001; NOAA-NOS-2026-0035-0001. Deep sea mining is reckless, unnecessary, and prioritizes questionable short-term gain for a few over ocean health needed for all. Deep sea mining risks irreversible harm to ocean ecosystems and the people who rely on them. The exploration plans provided by these applicants are inadequate to collect data on the full impact of mining, or the ecosystems that would be threatened by it. I ask that NOAA ensure that seabed mining applicants meet their regulatory obligations and reject exploration applications that fall short. Deep sea mining technology is expensive, untested and unproven. There are no commercial deep sea mining operations anywhere in the world. Like all deep ocean operations, deep sea mining will have extraordinarily high up-front costs, and is unlikely to be competitive without government support. Deep sea mining should not be permitted without assurances that U.S. taxpayers will not be on the hook for environmental costs, as were the people of Papua New Guinea when the Nautilus Minerals project resulted in bankruptcy and over $100 million in alleged losses for their country. That history is a clear warning, yet the applicants point to their founding of Nautilus as among their most important and relevant experience, suggesting they are willing to put U.S. taxpayers at risk next. Until these risks can be understood and properly controlled, the U.S. should continue to explore more sustainable pathways available to meet its critical mineral demands. Deep sea mining is opposed by the people most likely to be affected. Nearly all Pacific U.S. States and U.S. territories, including California, Washington, Oregon, Hawai'i, American Samoa, and Guam have either prohibited, banned, or restricted deep sea mining within state and territorial waters. Pacific countries and non-U.S. territories have also called for a moratorium on deep sea mining, including Palau, Fiji, Samoa, Federated States of Micronesia, New Zealand, Vanuatu, Tuvalu, Marshall Islands, and the territorial governments of New Caledonia and French Polynesia. Furthermore, the cultural connections of Pacific Peoples are not limited by political boundaries. The international waters of interest to these applications include traditional seafaring routes and are central to core belief systems and cultural values. Unilateral deep sea mining in international waters is a grave geopolitical risk to the United States and threatens national security. The U.S. is one of the biggest beneficiaries of the U.N. Convention on the Law of the Sea, allowing it to claim a massive Exclusive Economic Zone, an Extended Continental Shelf claim in the Arctic, provides for maritime law enforcement in international waters, and ensures safe passage of our military and commercial fleets worldwide. Going against the will of the 172 parties that ratified the Treaty and enabled it to enter into force puts global governance at risk, and could escalate tensions in already tense times. For these reasons, I urge NOAA to uphold strong environmental review, be a good faith actor in global governance, and reject these inadequate applications. Sincerely, Joanie Steinhaus