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Posts Tagged ‘NOAA’

Rules of thumb for offshore spills:

  • The initial spill estimates are low; often by a lot
  • The estimates of oil recovered are high and unverified

Louisiana Offshore Oil Port (LOOP) spill:

  • product spilled: Venezuelan crude
  • first observed:  2/26 at approximately 0400
  • initial spill volume estimate: <100 barrels (bbls)
  • 3/3: spill volume update: 300 bbls
  • 3/5: final spill volume update: 750 bbls; volume reaffirmed on 3/17 and 2/26
  • reported cause: material failure in a section of the cargo transfer hose during a crude oil transfer between the offshore facility tanker
  • estimate of oil recovered: 655–664 bbls (>87%!)

Comments:

  • According to a Unified Command interview, the spill volume estimate was based on visual observations and estimates of the volume of oil recovered. Neither are reliable indicators of the volume actually spilled.
  • Was the volume transferred being metered at the vessel and LOOP, such that meter differentials could indicate the actual spill volume?
  • The spill was first observed at night. What procedures were in place for monitoring the transfer operation for potential leaks?
  • LOOP first reported a spill estimate of <100 bbls, subsequently increased to 300 bbls, and then 750 bbls.
  • The oil recovery estimate of 655-664 bbls is highly suspect unless the spill was much larger than reported. Recoveries >50% are unlikely for open water spills. (Typically <20% is recovered.)
  • How were the oil recovery estimates determined? Is data available on the total fluid recovered and water content?
  • NOAA reports that the spill response and repair were postponed due to hazardous offshore conditions. This makes the spill and recovery numbers even more suspect.
  • Ed Tennyson, a leading authority on oil spill response capabilities and a former colleague, was skeptical of oil recovery claims. When on-scene, he would ask to see the recovered oil and data on how the volumes were determined.
  • Hopefully, the investigation report will be timely and comprehensive.

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The wave data are from Georges Bank (buoy 44011, first chart) and Nantucket Shoals (buoy 44008, second chart).

Note that the significant wave height is the average height from trough to crest of the highest one-third of waves that occur in a given period.

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The Metals Company has filed the first consolidated application for an exploration license and commercial recovery permit under NOAA’s new regulations.

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Remotely operated vehicle traverses over an extensive field of ferromanganese nodules that form the bulk of the hard seafloor substrate. Credit: NOAA.

Links to final rule and post about the draft rule

“The objective of this rule is to provide the option for a consolidated application streamlining the process for qualified applicants.”

Reflecting on advances in environmental science, seafloor mapping, and offshore mineral-collection technologies, the revised rule allows qualified companies that gather the necessary site information to proceed to the collection phase. Deepsea mining is now more closely aligned with offshore oil and gas in that companies acquiring licenses are able to proceed to production after regulatory approvals.

The preamble nicely summarizes the opposition to the rule for environmental and jurisdictional reasons:

General opposition to deep seabed mining was expressed for a variety of stated reasons, including, but not limited to the following assertions: effects on the environment; effects on seabed habitat and to marine species including undiscovered species especially in the Clarion-Clipperton Fracture Zone; harm to cultural resources and Pacific Islander livelihoods and beliefs; inadequate scientific research and information; inadequate resource protection measures and regulations; uncertainties regarding environmental impacts and a nascent industry; significant technical challenges to deep seabed mining; opposition to deep seabed mining from many U.S. states, countries, and global companies; that deep seabed mining is contrary to international agreements and efforts; the need for moratoria; that deep seabed minerals are not needed to meet U.S. demand for critical minerals and domestic sources and recycling of such minerals should be used instead; the U.S. needs to focus on building domestic refineries; using renewable and alternative resources rather than deep-sea minerals; and jeopardizing vital carbon sinks.”

“Commenters stated that acting unilaterally on deep seabed mining undermines the ISA (International Seabed Authority) process, international norms, global stability, and the rule of law, and that it could result in harm to protected areas, such as Areas of Particular Environmental Interest designated by the ISA.”

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NOAA is touting marine aquaculture and has published Programmatic Environmental Impact Statements for Aquaculture Opportunity Areas (AOAs) in the Gulf of America and offshore Southern California. This is a positive step.

While the focus of these EIS documents is on distinct AOAs separated from oil and gas facilities, NOAA might also have discussed the potential for synergy with existing platforms. The reef effect of platforms can be sustained and new fishery ventures supported by converting older platforms to aquaculture facilities (Rigs-to-Roe/Redfish/Rockfish) rather than decommissioning them.

The ecological importance of offshore platforms has been well documented in both the Gulf and Santa Barbara Channel Channel area.

According to a paper published in 2014 by marine ecologist Dr. Jeremy Claisse of Cal Poly Pomona, the oil and gas platforms off the coast of California are the most productive marine habitats per unit area in the world. “Even the least productive platform was more productive than Chesapeake Bay or a coral reef in Moorea,” said Dr. Love. (Milt Love, UCSB biologist)

beneath Platform Gilda, Santa Barbara Channel

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pictured:TMC pilot trials

Highlights from TMC’s Q2 update:

  • On August 11, 2025, TMC USA received notice of full compliance from the National Oceanic and Atmospheric Administration (NOAA) on its exploration applications, and reconfirmation that TMC USA has priority right over both exploration areas
  • Both applications entered the certification stage in late July, which we expect to be approximately 100 days
  • In light of recent U.S. regulatory developments, TMC expects to commence commercial production from the NORI-D Area in the fourth quarter of 2027 if we receive a commercial permit before scaling to an average annual production rate of 10.8 million tonnes of wet nodules per annum (Mtpa) at steady state (2031 through 2043) production, with an expected 18-year life of mine (LOM);

Meanwhile, after missing deadlines in 2020 and 2023, the International Seabed Authority (ISA) again failed to deliver a Mining Code as communicated in their 2023 roadmap during the second part of their 30th session in July 2025. No new roadmap or new target date for adopting the final Mining Code has been agreed. The next ISA meeting is scheduled for March 2026. (Hence the importance of direct permitting through the US/NOAA.)

NORI area
polymetallic nodule

More posts about deep sea minerals

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The attached petition from Save the East Coast Inc. et al requests that NOAA revoke the Empire Wind Letter of Authorization using the emergency authority delineated at 50 C.F.R. § 216.106(f).

This is a strong filing, but revocation would be difficult given the extensive development activity to date and the Administration’s decision in May to allow the project to go forward.

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Remotely operated vehicle traverses over an extensive field of ferromanganese nodules that form the bulk of the hard seafloor substrate. Credit: NOAA.

The proposed rule is attached. Important points:

How can the US issue mining licenses in international waters (controversial)?

The International Seabed Authority (ISA) regulates deep seabed mining in areas beyond national jurisdiction for countries that are parties to the United Nations Convention on the Law of the Sea (UNCLOS). The United States is a non-party to UNCLOS. Under U.S. law, NOAA may issue licenses and permits to U.S. citizens in areas beyond national jurisdiction under the Deep Seabed Hard Mineral Resources Act (DSHMRA).

Main objective of the proposed rule (paraphrased):

The deepsea mining industry has gained experience from site specific exploration activities. As a result, later entrants may be able to capitalize on the information gained by previous explorers and lessen the need for further exploration of previously explored areas. In such cases there may be a need for a consolidated licensing process in which permit applicants could meet exploration license requirements to establish priority of right, and permit requirements, simultaneously.

Comment: The proposed rule seems reasonable in that qualified companies that gather the necessary site information would have the right (after NOAA review and approval) to collect the minerals. This would align deepsea mining more closely with offshore oil and gas in that companies acquiring licenses would be able to proceed to production after regulatory approvals.

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… and shared a mineral water toast! 😉 (Weak joke, but at least it’s original and topical!)

NOAA and TMC, a Canadian company, are working together to bypass the stifling UN deep sea minerals bureaucracy.

NOAA raises a glass: Yesterday, President Trump signed an Executive Order establishing a framework for American companies to identify and retrieve offshore critical minerals and resources. The Executive Order prioritizes U.S. leadership in seabed mapping and mineral exploration, ensuring reliable access to critical minerals like manganese, nickel, cobalt and rare earth elements.

In support of the Executive Order, NOAA is committed to an expeditious review of applications for exploration licenses and commercial recovery permits. The agency will provide the necessary resources for license and permit reviews to ensure that those reviews go forward without undue delays.

TMC applauds:

  • TMC is positioned to play a central role in supporting an American industrial ecosystem underpinned by deep-seabed minerals, and poised to mobilize tens of billions in private investment in the U.S. across shipbuilding, ports, mineral processing, and advanced manufacturing
  • The Company through its U.S. subsidiary expects to file license and permit applications under the U.S. Deep Seabed Hard Mineral Resources Act (DSHMRA) in the second quarter of 2025

China boos: “The US authorization… violates international law and harms the overall interests of the international community,” Chinese foreign ministry spokesman Guo Jiakun said on Friday.

TMC and other companies like Impossible Metals (see below) have had enough of the endless delays at the United Nations’ International Seabed Authority, which is still developing regulations. Mining companies and others have spent years gathering data and providing input.

Meanwhile in US waters:

San Jose, CA – Impossible Metals, a pioneering US-based deep-sea mining company, has submitted a request to commence a leasing process for exploration and potential mining of critical minerals in the deep sea off the coast of American Samoa. Impossible Metals is the first company to request a lease of critical minerals under the Outer Continental Shelf Lands Act of 1953, which is regulated by the U.S. Bureau of Ocean Energy Management (BOEM), part of the U.S. Department of the Interior.

Impossible Metals has developed the only autonomous underwater robot (AUV) for selective harvesting. The novel underwater robot uses advanced robotics, AI, and a buoyancy engine to hover above the seabed, accurately identifying and avoiding nodules with visible life while minimizing disruption to the habitat and native biodiversity. This method will have the lowest environmental impact and cost among land and deep-sea mining approaches, setting a new standard for responsible resource collection.

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pictured:TMC pilot trials

Lars Herbst brought this bold and rather surprising deepsea mining development to my attention. Let the screaming begin!

NEW YORK, March 27, 2025 (GLOBE NEWSWIRE) (emphasis added) — TMC the metals company Inc. (Nasdaq: TMC) (“TMC” or the “Company”), an explorer of the world’s largest undeveloped resource of critical metals for building infrastructure, power generation, transmission, and batteries, today announced that its subsidiary The Metals Company USA LLC (“TMC USA”) has formally initiated a process with NOAA under the U.S. Department of Commerce to apply for exploration licenses and commercial recovery permits under existing U.S. legislation, the Deep Seabed Hard Mineral Resources Act of 1980 (DSHMRA).

Following extensive legal diligence on DSHMRA, NOAA’s implementing regulations and other applicable environmental protection legislation, the Company strongly believes that the U.S. seabed mining code offers the greatest probability of securing a permit for commercial recovery of deep-sea mineral resources in a timely manner.

Gerard Barron, Chairman & CEO of The Metals Company, commented: “Over the last decade, we’ve invested over half a billion dollars to understand and responsibly develop the nodule resource in our contract areas. We built the world’s largest environmental dataset on the CCZ, carefully designed and tested an offshore collection system that minimizes the environmental impacts and followed every step required by the International Seabed Authority. But, despite collaborating in good faith with the ISA for over a decade, it has not yet adopted the Regulations on the Exploitation of Mineral Resources in the Area in breach of its express treaty obligations under UNCLOS and the 1994 Agreement.”

“We believe we have sufficient knowledge to get started and prove we can manage environmental risks. What we need is a regulator with a robust regulatory regime, and who is willing to give our application a fair hearing. That’s why we’ve formally initiated the process of applying for licenses and permits under the existing U.S. seabed mining code. After extensive legal review and constructive engagement with NOAA and other officials across the U.S. government, we believe the United States offers a stable, transparent, and enforceable regulatory path. TMC USA expects to submit applications to NOAA in the second quarter of 2025. We’re encouraged by the growing recognition in Washington that nodules represent a strategic opportunity for America—and we’re moving forward with urgency.”

Previous deepsea mining posts

Greenpeace photo

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