Pacific CSOs Oppose U.S. Plan to Open American Samoa’s Exclusive Economic Zone

pacificblueline.org
Aug 13
7 min read

Attention: Bureau of Ocean Energy Management (BOEM), Pacific Region Office of Strategic Resources

760 Paseo Camarillo (CM 102)

Camarillo, CA 93010

Subject: Opposition to US Opening the EEZ of American Samoa in the Pacific Ocean to lease applications for Deep Sea Mining (BOEM-2025-0035 RFI Comments)

Dear Bureau of Ocean Energy Management,

We the undersigned are representatives of the wider Pacific movements and Civil Society Organisations that have tirelessly campaigned against Deep Sea Mining in the Pacific Ocean.

The Pacific Blue Line Campaign (PBL) draws a line on DSM and calls for it to be banned. This position is informed by science and by knowledge and respect for the affinity and kinship with the ocean and marine life and deep sense of responsibility of ocean guardianship that are shared by our indigenous populations across the Pacific Islands. It is also informed by our colonial history.

As stated in the Pacific Blue Line Declaration:

“Deep sea mining (DSM) is the latest in a long list of destructive industries to be thrust into our sacred ocean. It is a new, perilous frontier extractive industry being falsely promoted as a proven answer to our economic needs. While its promised benefits remain speculative, its pursuit is insidious. Even at an experimental stage, DSM is already proving harmful to Pacific communities, their livelihoods, cultural practices, and their wellbeing."

“Mindful of the nuclear legacy in the Pacific, and determined to not see it repeated, our Ocean must never again be used as the ‘testing grounds’ for dangerous pursuits that serve the interests of powerful states, institutions and industry. Rich states, promoting their multinational companies, facilitated by powerful institutions have been working with our own Pacific Island governments, enticing them with the promise of wealth, despite technologies for extracting minerals on the ocean floor remaining untested in terms of environmental safety."

"We call for a total ban on DSM within our territorial waters and in areas beyond national jurisdiction.”

Protecting the ocean and its living resources is also essential for food safety and security, subsistence livelihoods, economic lifelines, culture and way of life of all who live in Pacific Island countries, including future generations. Indigenous Pacific women in rural areas who engage in subsistence fishing and gleaning of non-fish products from inshore waters and reefs to put food on their families’ tables have a particular stake in protecting the health of our ocean environment and the safety of all forms of marine life. The concept of transboundary harm is well understood: mining the seabed in any of the EEZs of Pacific Island States and Territories will affect people living in neighboring Pacific Island States^[1] and Territories as the environmental impacts from mining the seafloor cannot be contained within any specific area of the ocean, which has its own rhythms and forces.

We are therefore alarmed by the April 8, 2025 announcement of the U.S. Department of Interior’s Bureau of Ocean Energy Management (BOEM) that it had initiated the first steps that could potentially lead to leases being granted to multiple mining companies to explore and mine the seabed in waters off American Samoa. That the announced ‘first steps’ were triggered by ‘an unsolicited request’ from a California-based company – Impossible Metals - to the Bureau of Ocean Energy Management (BOEM) to consider opening American Samoa’s EEZ for the auction of leases for exploration and mining in the Territory’s Outer Continental Shelf is deeply concerning.

Impossible Metals is a recently-established venture capital-backed start-up, supported with acceleration funding from Y Combinator and Climate Capital. Founded and headed by a self-described ‘serial entrepreneur’, naturalized American citizen Oliver Gunasekara, Impossible Metals aims to raise 1 billion in investment capital. The company claims it has invented a safe way to mine polymetallic nodules from the seafloor, using ‘autonomous underwater vehicles’ which will ‘hover’ above the seafloor and AI-driven remote control to selectively ‘harvest’ the nodules individually, without disturbing or destroying the habitat. The company’s claims have been found to be scientifically baseless and therefore false.

Impossible Metals is on a fast track to profit as a first-mover from seabed mining, which it expects will be made possible under President Trump’s Executive Order of 24 April 2025, Unleashing America’s Offshore Critical Minerals and Resources, which unilaterally opens the back door to DSM, bypassing established international law and governance. On April 29 2025, Oliver Gunasekara, as the company’s CEO, testified at a Hearing of the House Committee on Natural Resources, Oversight and Investigations Subcommittee on his credentials and vision of America taking the lead in global mineral production from the seafloor, using Impossible Metals’ technology.

Apart from referring to the far greater social and environmental impacts of terrestrial mining, Gunasekara’s testimony - titled “Exploring the Potential of Deep-Sea Mining to Expand American Mineral Production” - shows complete disregard and lack of understanding of ocean ecosystems and marine life, which go unmentioned. It’s a gung-ho, hard-sell business case and a primarily economic and defense argument for seizing the minerals on the seabed in US territorial waters, using the company’s technology. It also relies on the outdated argument that DSM is necessary for a green transition, since new advances in battery technology will eliminate the need for critical minerals from the seabed.

That minerals from the deep are expected to be used for the production of weapons of war is made clear in a throwaway line in Impossible Metals CEO’s Testimony: “These minerals will also power our economy through efficient batteries—including a resilient grid, tools for the warfighter, and transportation.” This envisaged military end-use of resources from the seabed of the Territory of American Samoa further sullies the profit-driven push for DSM by Impossible Metals. It also directly conflicts with the ethical principle in UNCLOS of ‘peaceful use’ of the seabed in areas beyond national jurisdiction.

The only reference to environmental concerns about DSM in this Testimony appears in the claim by Gunasekara that the company’s whizz technology ‘addresses each of the concerns of environmental advocates: it minimizes sediment disturbance and has no sediment plume because of the selective harvesting approach, preserves megafauna with AI-driven algorithms, and limits noise and light pollution near the surface because there is no dedicated support ship.’

Whatever technology is employed, experimental deep-sea mining carries enormous risks of causing irreversible harm to ocean ecosystems that are still poorly understood, even by marine scientists who are the first to say so. New discoveries of species of marine life in what were once believed to be lifeless regions of the deep ocean and seabed bear this out. The recent astonishing discovery of ‘dark oxygen’ being emitted by the nodules challenges established scientific understanding. We know the critical role of the deep ocean and seabed in storing carbon and methane gasses, thereby regulating the climate system which is already in crisis. Those who will be most affected by the impacts of seabed mining, who are also those most at risk from climate change and its impacts, strongly oppose DSM.

Almost all U.S. Pacific States and territories, including California, Washington, Oregon, Hawaii, American Samoa and Guam have restricted or banned deep-sea mining. In late July 2024, the Governor of American Samoa, Lemanu Peleti Mauga, issued an Executive Order placing a moratorium on seabed mining in the waters of American Samoa. The EO explicitly references the significant risks to marine biodiversity, including habitat destruction, pollution and the disruption of critical ecological processes which could have irreversible impacts on marine life and local communities. It also notes that deep-sea ecosystems, which remain among the least-understood places on earth, support vital ocean ecosystem elements such as fish stocks, coral reefs, and ecosystem functions, including water temperature regulation, carbon sequestration, and nutrient cycling. We understand that the American Samoan government remains unified in its opposition to DSM. Any approval of deep-sea minerals leasing plans would be contrary to the wishes of the local people and Government.

We end by citing what American Samoan scientist, Utumapu Dr. Andrew Pati Ah Young, Director of Discovery Biology at a biotech company in San Francisco, had to say about the lease request by Impossible Metals to conduct exploration and potential mining of critical minerals in the deep sea off the coast of American Samoa. In an address delivered at the meeting of the Western Pacific Regional Fishery Management Council in Honolulu on June 9 2025, Utumapu Dr. Andrew Pati Ah Young said:

“On behalf of the people of American Samoa, we respectfully express our unequivocal opposition to the lease request by Impossible Metals and to any deep-sea mining within American Samoa’s Exclusive Economic Zone. This is not a resistance to clean energy and economic progress, but a stand grounded in science, cultural responsibility, and historical lessons."

“Culturally, the ocean is not a resource to exploit—it is part of our Fa’asinomaga, our identity as Samoans. Our ancestral practice of Fa’asao, or conservation, is incompatible with destructive commercial mining. To proceed without understanding the consequences severs our connection to the ocean and future generations.”

For these reasons, we urge BOEM to abandon any deep-sea mineral leasing plans in the EEZ of American Samoa.

Sincerely,

Claire Slatter and Maureen Penjueli

Development Alternatives with Women for a New Era

On behalf of:

Alliance for Future Generations

Anne's Christian Community Health School and Nursing Services

Centre for Environmental Law & Community Rights Incorporated

Civil Society of Tonga

Council of Pacific Education

Deep Sea Mining Campaign

Development Alternative with Women for New Era

Emerging Leaders Forum Alumni

Fiji Council of Social Services

ICAN Aotearoa New Zealand

Lauru Land Conference of Tribal Community Trust Board Inc.

Pacific Blue Line

Pacific Conference of Churches

Pacific Islands Climate Action Network

Pacific Migration Partners

Pacific Network on Globalisation

Pacific Sexual & Gender Diversity Network

Pacific Women Mediators Network

Peace Movement Aotearoa

Project Sepik

Social Empowerment and Education Programme

Te Ipukarea Society

Tenakor Mangrove Women Association

Vanuatu Human Rights Coalition

Vanuatu National Healers Association

Vanuatu Young Women for Change

Vatu Mauri Consortium