THE PERILS
OF DEEP-SEA MINING
a briefing for financial institutions

2
Overview     
This briefing for financial institutions (FIs) provides an overview of the nascent industry of deep-sea 
mining (DSM) and the related environmental, social and governance (ESG) risks that it poses. It also 
provides several actionable recommendations that will allow FIs to avoid exposure to these risks.
Key findings:
●	 The latest scientific research indicates that the environmental damage caused by DSM is 
likely to be extensive, irreversible and unmitigable.1 DSM risks disrupting the global carbon 
cycle, threatens fisheries and food security, and would lead to irreparable biodiversity loss 
with devastating consequences for both people and planet.2
●	 Biodiversity must be placed at the core of FIs’ ESG strategies; the likelihood of future 
disclosure requirements on biodiversity is an important risk for FIs to consider given the 
inevitable biodiversity loss that would be caused by DSM. 
●	 FI involvement with the DSM industry is at odds with compliance with the International 
Finance Corporation’s Performance Standard 63 on biodiversity conservation and the 
sustainable management of living natural resources, due to its adverse impacts on “critical 
habitats” of significant importance to (Critically) Endangered and/or endemic/restricted-
range species.
●	 The future financial viability of DSM is highly uncertain owing to the unpredictable nature 
of future demand for seafloor metals, considerable litigation risk, and the technology being 
largely unproven at operational commercial scale. Consequently, any financial involvement 
with the DSM industry by FIs should be considered extremely high risk.
●	 DSM’s largest corporate backer, Lockheed Martin, exited the industry in March 2023 following 
the sale of its UK Seabed Resources subsidiary to Loke Marine Minerals, a Norwegian startup 
– evidence of major corporations’ increasing reluctance to invest in the DSM industry.4 
Shipping company A.P. Moller-Maersk is the latest major name to divest itself of interests in 
the deep-sea mining industry, with the sale of its stake in leading DSM proponent, The Metals 
Company (TMC).5
●	 An increasing number of nations are opposing DSM or calling for a precautionary pause or 
moratorium, including (as of April 2023) Chile, Costa Rica, Dominican Republic, Ecuador, 
Federated States of Micronesia, Fiji, France, Germany, New Zealand, Palau, Panama, Samoa, 
Spain, and Vanuatu.6
●	 Major companies including BMW, Google, Philips, Renault, Samsung and Volkswagen have 
signed a statement supporting a moratorium on DSM and pledging to keep DSM minerals out 
of their supply chains.7
●	 The growing global movement against DSM, and the industry’s lack of social legitimacy, 
presents a potentially severe reputational risk for FIs who provide support to it. This risk is 
highly likely to intensify in years to come as public awareness grows of the irreparable and 
far-reaching environmental impacts of DSM.
© MARUM
Cover image: NOAA Office of Ocean Exploration.

3
Recommendations to Financial Institutions
EJF recommends that FIs:
●	
Adopt and publish policies which explicitly exclude the provision of banking or other financial 
services8 to:
o	
DSM companies, or companies who have a significant share of their revenue or 
activities within DSM; and
o	
companies who have subsidiaries (or divisions of the same company) engaged in 
DSM within the corporate group.
●	
Engage with non-mining companies9 who are potential users of DSM metals to encourage them 
not to provide support for the industry by: (i) supporting calls for a global moratorium on DSM 
activities10; (ii) monitoring and tracking where they source minerals for their business; and (iii) 
excluding minerals/metals obtained from DSM from their supply chains.
●	
Engage with investors and other sources of DSM funding to encourage them not to provide support 
for the industry, in line with the conclusion of the United Nations Environment Programme Finance 
Initiative (UNEP FI) that there is “no foreseeable way in which the financing of deep-sea mining activities 
can be viewed as consistent with the Sustainable Blue Economy Finance Principles.”11
●	
Extend their ESG strategy to cover biodiversity (the protection and restoration of nature).
In order to action the above recommendations, EJF encourages financial institutions to carry out 
satisfactory due diligence in order to assess their own exposure (both direct and indirect) to the 
financing of DSM activities.12
€
DSM and the risks to financial institutions
DSM
risks for
FIs 
• physical disturbance
• habitat destruction
• sediment plumes
• noise & light pollution 
• fisheries impacts
• health & food security
• exclusion of
                             impacted groups
• unknown carbon
                      cycle impacts
• uncertain regulatory
     framework
• litigation risk
economic viability •
future demand •
DSM timescales •
growing opposition •
social legitimacy •
concerns

4
1. Background to DSM      
1.1. What is DSM?
DSM involves the extraction of mineral deposits from the seafloor, seamounts and hydrothermal 
vents at depths greater than 200 metres. Three types of deep-sea mineral deposits are of significant 
interest to mineral extraction ventures: polymetallic nodules, polymetallic sulphides, and cobalt-
rich ferromanganese crusts. These deposits contain metals such as cobalt, lithium, silver, and rare 
earth metals. 
Polymetallic nodules, which contain higher quantities of copper, cobalt, nickel, or manganese 
than any known mineable source on land,13 are currently the most sought after of the three deposit 
types. To obtain these nodules, heavy machinery remotely operated from a surface support vessel 
ploughs the seafloor, extracting a mineral-sediment mixture which is pumped through rigid hoses 
to production ships on the water’s surface. There is widespread concern amongst scientists that the 
clouds of suspended sediment particles produced by this mining process may have highly damaging 
and irreversible effects on the fauna of the deep sea.14 Once the mineral deposits reach the ships, they 
are then separated from the sediment and cleaned, with the sediment-rich wastewater discharge, 
laden with toxic heavy metals, released back into the water column15 where it is likely to further 
damage the delicate marine ecosystem.16
Types of mineral deposit targeted by deep-sea mining
ROV KIEL 6000, GEOMAR (CC BY 4.0)
Credit: Ed Harrison / China Dialogue Ocean (CC BY NC ND). Source: Aldred, J. (2019), ‘The future of deep seabed mining’,
China Dialogue Ocean. chinadialogueocean.net/en/conservation/6682-future-deep-seabed-mining/

5
Polymetallic massive sulphides are cleaved from mineral formations found near hydrothermal vents. 
Large volumes of sediments are first removed from the seabed to make space for a mining tool. The 
machine, equipped with a drum cutter, carves out blocks of ore which are then disaggregated into 
smaller pieces and pumped up to the surface vessel for processing. Wastewater is also pumped back 
into the water column.17 There is current concern over the potential resurrection of the previously failed 
Solwara I project (see Section 2.4) within the exclusive economic zone of Papua New Guinea, which is 
seeking to extract massive sulphide deposits.18
Cobalt-rich ferromanganese crusts covering the summit and slopes of seamounts are technically 
more difficult to exploit. The extraction process is similar to that used for polymetallic sulphides,19 
with the increased challenge that blocks of ore need to be carved out directly from the seafloor in a 
rugged environment.

6
To date, no large-scale commercial mineral exploitation in waters beyond national jurisdiction has taken 
place; the regulatory framework to allow DSM activity in such areas is currently being negotiated at the 
International Seabed Authority (ISA20), the intergovernmental body responsible for the regulation of 
DSM in areas outside of national jurisdiction. Nevertheless, taking action on DSM remains an urgent 
and critical issue. In July 2021, the Pacific Island nation of Nauru triggered the ISA’s “two-year rule”, 
giving the body two years to finalise rules and regulations for DSM. This could see applications for 
contracts for exploitation being accepted by the ISA as early as July 2023, before the risks of DSM are 
fully understood.
1.2. Why mine the deep sea?
The metals found in seafloor deposits are the same metals currently used in renewable energy 
technologies including solar panels, wind turbines and electric car batteries. The DSM industry claims 
that mining the deep sea is the only way to successfully manage the green transition to a low-carbon 
economy, arguing that demand for mined minerals will rapidly increase given the shift away from 
fossil fuels.21 However, the need to source these minerals from the deep sea is strongly refuted by states, 
scientists, businesses and civil society organisations22 who conclude that such an energy transition is 
fully feasible without extracting minerals from the deep sea.
Not only does mining deep-sea minerals pose a significant threat to deep ocean ecosystems, but it 
also has an uncertain future. Future demand for these metals remains unpredictable given growing 
improvements in battery and metal recycling and the rapid evolution of battery technologies, as well as 
the potential for demand to be met from terrestrial resources alone (see Section 2.4 on the financial 
risks of DSM).23
Circular Economy. Credit: RecondOil (CC BY 2.0)
The need to source these minerals from 
the deep sea is strongly refuted by 
states, scientists, businesses and civil 
society organisations who conclude 
that the clean energy transition is fully 
feasible without extracting minerals 
from the deep sea.

7
2. DSM and the risks for financial institutions
2.1. Biodiversity risks of DSM           
The DSM industry is riddled with uncertainty. We do not yet know enough about the deep sea to 
understand the magnitude and extent of damage to both the seafloor and the surrounding ocean 
ecosystem that would be caused by mining activities. What we do know, however, is that harm 
would be irreparable and result in a loss of biodiversity, impacting the oldest living organisms 
on the planet. 
“Loss of biodiversity in the deep sea would be inevitable and could be considered to be ‘forever’ on 
human time scales.”
Niner et al. (2018)24

The deep sea covers over 65% of the Earth’s surface, and makes up more than 95% of the Earth’s 
biosphere.25 It harbours an incredibly rich variety of organisms, believed to be comparable to the eclectic 
biodiversity of tropical rainforests.26  It is one of the last unknown frontiers of scientific knowledge on 
Earth;27 in the Clarion-Clipperton Zone of the Pacific Ocean, where mining is proposed to take place, it 
is estimated that up to 70–90% of the species collected are new to science.28 Scientists have discovered 
deep-sea corals estimated to be over 4,000 years old29 and sponges up to 11,000 years old – the oldest 
living animals ever observed on earth.30 
Increasing evidence shows that polymetallic nodules may be an important driver of biodiversity, 
abundance, and ecosystem functions in the deep sea. For example, the newly discovered deep-sea 
octopus known as ‘Casper’ lays its eggs on sponges that only grow on manganese nodules.31 Seamounts 
– where cobalt-rich ferromanganese crusts would be harvested – harbour rich and diverse ecological 
communities, with corals, sponges, feather stars and an abundance of pelagic fish.32 They are important 
aggregation, breeding, foraging and resting areas for emblematic species such as whales, sharks, and 
turtles,33 and are used as landmarks by migrating species.34 
The deep-sea “Casper” octopus lays its eggs on sponges that only grow on manganese nodules. 
NOAA Office of Ocean Exploration and Research, Hohonu Moana 2016. (CC BY-SA 2.0)

8
Independent reviews of the available scientific evidence commissioned by governments35 and 
conducted by civil society organisations36 are in agreement that DSM will cause potentially severe 
adverse impacts to the marine environment, its biodiversity, and ecosystems. Significant disturbances 
are expected, including direct damage to the benthic fauna, habitat destruction, and pollution from 
sediment plumes and wastewater discharge.37 Noise and light pollution will affect the behaviour of 
organisms; for example, noise from underwater mechanical vibrations will disrupt the ability of marine 
mammals to communicate and locate prey and predators, disturbing endangered migratory whales.38 
Owing to their life history traits, deep-sea organisms are extremely slow to recover from disturbance; 
experiments studying the long-term impacts of DSM in the Peru Basin show that wildlife remained 
significantly impacted 26 years after mining test disturbance.39 
While the available scientific evidence establishes a clear risk of serious adverse environmental 
impacts, the extent and magnitude of the damage DSM would cause to the marine environment remain 
unknown. Critical knowledge gaps remain that prevent fully informed, science-based decision-
making. In the absence of a solid baseline, environmental impact assessments are unreliable40 
and are likely to underestimate the extent and magnitude of environmental impacts.
Major FIs are already acting on the investment risk posed by DSM due to the severe risk of irreversible 
biodiversity loss. In December 2022, Norway’s largest private asset manager, Storebrand, announced 
it would no longer invest in companies involved in DSM in line with its new policy on nature.41 
Storebrand also divested from The Metals Company42 (TMC), reaffirming its commitment to “halting 
and reversing the loss of biodiversity”.43  
Bolosoma sp., glass sponge, NOAA Office of Ocean Exploration and Research, Deep-Sea Symphony: Exploring the Musicians Seamounts (CC BY-SA 2.0)
Scientists have discovered corals 
estimated to be over 4,000 years 
old and sponges up to 11,000 years 
old – the oldest living animals ever 
observed on earth.

9
Box 1: The finance sector and biodiversity conservation 
Whilst climate change remains a top ESG priority, biodiversity is rightly continuing to 
gain status as a key consideration in FIs’ ESG strategies. Biodiversity and the climate 
are interdependent,44 with the Network for Greening the Financial System (NGFS) 
highlighting the “climate-biodiversity nexus” when considering risks to financial stability 
in its 2021 report.45 
There has been a clear global movement within financial services towards nature-positive 
outcomes. Investment in greener activities has been increasing as FIs react to changes in 
investor demand, regulation, and litigation risk. At the COP 15 UN Biodiversity Conference 
in December 2022, 150 financial institutions signed a statement calling for governments to 
adopt a post-2020 Global Biodiversity Framework.46 126 financial institutions representing 
21 countries and over 18.8 trillion euros in assets have also signed the Finance for 
Biodiversity Pledge, committing to protect and restore biodiversity through their finance 
activities and investments.47 

Regulators and central banks are also targeting biodiversity, with the following noteworthy 
recent developments:
●	 The European Central Bank (ECB) outlined its supervisory expectations relating to 
governance and risk appetite (including disclosure) in its guide on climate-related and 
environmental risks and specifically referred to the risks caused by biodiversity loss.48 The 
ECB has taken a strong position and expects compliance with its expectations by banks 
under its supervision by the end of 2024.
●	 The UK’s Financial Conduct Authority is encouraging financial institutions to include 
wider environmental issues, such as biodiversity loss and nature, in their ESG strategies.49
●	 The Bank of England will be publishing its analysis of UK-level nature-related financial 
risks later this year, in line with its obligations under the Environment Act 2021, to 
consider how it can support biodiversity.50
“Financial institutions will increasingly be expected to be aware of how their business impacts 
on biodiversity, where their dependencies are and where the potential material financial 
risks arising out of biodiversity loss lie, and also to incorporate biodiversity considerations 
into their business strategy, governance, risk management, and public disclosures.”
Freshfields Bruckhaus Deringer51

Future disclosure requirements on biodiversity also remain an important factor to 
consider given the severe risk of irreversible biodiversity loss occurring as a result of DSM. 
While some countries such as France have already put in place mandatory biodiversity 
disclosures for FIs,52 this is not the case in many other nations, including the UK. However, 
FIs should be prepared for this type of regulation to become increasingly commonplace if 
the recommended biodiversity disclosures outlined in the beta versions of the framework 
produced by the Taskforce on Nature-Related Financial Disclosures (TNFD) are maintained 
in its final version.53

10

Box 2: The DSM industry and compliance with International Finance Corporation 
(IFC) Performance Standard 6 (PS6)
FI involvement with the DSM industry is at odds with compliance with IFC PS6, which 
provides guidance on biodiversity conservation and the sustainable management of 
living natural resources. It is one of eight standards used by the IFC to assess and manage 
environmental and social risks.54 
It is highly likely that areas of the deep seabed exploited by DSM projects would fall under the 
definition of “critical habitat” outlined in paragraph 16 of IFC PS6, owing to their confirmed 
or potential status as “habitat[s] of significant importance to Critically Endangered and/or 
Endangered species” (see Box 3) and/or “habitat[s] of significant importance to endemic and/
or restricted-range species”.55 Deep-seabed communities form isolated pockets of life, with a 
high proportion of species found nowhere else on earth,56 and even species observed only on 
polymetallic nodules.57 If these communities are decimated by mining, unique species may 
become extinct, causing irreparable biodiversity loss.58 
According to IFC PS6, no project activities should be undertaken in areas of critical habitat 
unless the conditions set out in paragraph 17 of the standard are fulfilled, including that the 
project does not lead to:
●	 measurable adverse impacts on those biodiversity values for which the critical habitat 
was designated, and on the ecological processes supporting those biodiversity values;
●	 a net reduction in the global and/or national/regional population of any Critically 
Endangered or Endangered species over a reasonable period of time.59
The available scientific evidence shows that DSM activities would likely contravene both of 
these requirements. Measurable adverse impacts from DSM activity on seafloor biodiversity 
values will be unavoidable.60 This is all the more concerning as proposals to offset biodiversity 
loss from DSM are believed to be either impossible or scientifically meaningless.61 
Additionally, the existence of Endangered species such as the Scaly-foot Snail (see Box 3) 
within DSM project areas, and the extremely slow speed at which deep-sea organisms and 
ecosystems are able to recover from disturbance (see Section 2.1) indicate that DSM is likely 
to cause reductions in the populations of Critically Endangered and/or Endangered species 
over a prolonged period of time.
© GEOMAR

11
Box 3: Impacts of DSM on species listed in the IUCN Red List of Threatened Species
The Scaly-foot Snail (Chrysomallon squamiferum) is the first species to be listed as at risk 
of extinction as a direct result of DSM activity. A marine gastropod with a known area of 
occupancy of just 12 km2, it has only been found at depths of between 2,400 and 2,900 
metres within three areas of hydrothermal vents in the Indian Ocean.62 Two of these vent 
areas are sites of interest for DSM companies owing to the presence of polymetallic massive 
sulphides.63 In 2019, the species was added to the IUCN Red List and classified as Endangered, 
with the IUCN Red List assessment stating that any DSM activity within the two areas – even 
initial exploration – is likely to severely reduce or completely destroy the snail’s habitat.64
The species is a clear example of how deep seafloor areas can fall under the IFC’s definition 
of a critical habitat (see Box 2). However, the critical gaps that remain in our knowledge 
of deep-sea biodiversity65 may lead to areas subject to DSM activity being mis-identified as 
non-critical habitat, as Endangered or Critically Endangered species remain undetected. 
Indeed, scientists are calling for more deep-sea species to be added to the IUCN Red List in 
order to bolster their recognition and protection,66 especially given the use of the list for 
compliance with IFC PS6.67 A further 184 hydrothermal vent molluscs were added to the 
IUCN Red List in 2021, of which 39 were Critically Endangered, and 32 were Endangered.68
Octocorallia: Alcyonacea, mushroom coral. Submarine Ring of Fire 2002, NOAA/OER  (CC BY-SA 2.0).

12
Sperm whales. Credit: 
Amanda Cotton / Ocean Image Bank
2.2. Climate risks of DSM
The impacts of DSM on the global carbon budget are not yet fully understood but could be 
severe, in effect negating millions of years of ecological and biochemical processes in just a 
few years.
There is scientific consensus on the fundamental role of the deep sea in the global carbon cycle.69 
DSM is projected to stir up millions of tonnes of seafloor sediments each year, potentially unlocking 
vast amounts of carbon that has been accumulating over millions of years. An unknown proportion 
of that carbon can be remineralised due principally to microbial activity, increasing the amount of 
CO2 dissolved in seawater.70 This in turn would accelerate ocean acidification, with negative effects on 
growth and reproduction for a wide range of marine organisms.71 Should that CO2 reach surface waters 
and be released into the atmosphere, it would also further compound global heating.
The destruction of deep-sea habitats by mining also risks disrupting key carbon sequestration 
mechanisms.72 For example, the eradication of chemosynthetic bacteria near active hydrothermal 
vents will remove a unique source of biological carbon fixation in the deep ocean.73
Disturbance to seafloor sediments by collector vehicles is expected to have long-term impacts on 
carbon flows in benthic communities. 26 years after mining, the amount of carbon stored in marine 
fauna and the amount of carbon going through the food chain both remain just over half the values 
observed in undisturbed areas.74
“[Deep-sea mining] may be one of the more damaging industrial impacts on the deep oceans, because of 
the potential for the broad spatial scale of the impacts. Impacts of nodule mining will be particularly 
extensive (likely 100s km2 per operation)....Long-term (>centuries) and broad-scale (>1,000km2) 
impacts…are likely.”
UK Deep Sea Mining Evidence Review75

13
2.3. Social risks of DSM 
DSM has the potential for significant environmental harm that threatens to severely impact 
vulnerable groups. Many of these impacts are poorly understood, including major unknown 
implications for the global carbon cycle.
Local and Indigenous communities, which rely heavily on marine resources for their food security and 
livelihoods, will likely shoulder the major burden of DSM activities. DSM is predicted to negatively 
impact fisheries, causing potential declines in fish populations.76 Tuna fisheries are a critical source 
of revenue generation for Pacific island nations,77 accounting for an average of 37% of government 
revenue, or up to 84% in some cases.78 Developing island nations such as Samoa and the Cook Islands, 
which take as much as 20% of their high seas tuna catches within areas subject to mining exploration, 
could be potentially disadvantaged by DSM impacts on tuna fisheries.79 
While the exact spatial extent of mining impacts is currently unknown, recent modelling of pollution 
discharged by operations in the Tonga-sponsored contract area observed it would take only three months 
to reach the waters of Hawaii and Kiribati.80 Scientists also warn of the potential for bioaccumulation 
of toxins in food webs, with possible risks for human consumption.81 This is a significant concern, 
with fish critical to food security across the Pacific, providing 50-90% of animal protein consumed by 
coastal communities across a broad spectrum of Pacific island countries/territories where per capita 
fish consumption exceeds the global average by more than 3-4 times.82 Mining operations further risk 
disrupting local cultural traditions and deep-rooted spiritual connections to the ocean, as highlighted 
by the impacts of exploration on the local shark calling tradition in Papua New Guinea.83 
The social legitimacy of DSM has also been called into question, as a result of the exclusionary nature 
of negotiations at the ISA, which marginalise the voices of those groups – such as fishing communities 
and Indigenous Peoples and Local Communities – most at risk of DSM’s negative effects.84 A continuing 
lack of social legitimacy may cause consumers to increasingly reject the use of DSM materials85 and 
companies with links to the industry.
Fishing in Fiji. Credit: Tom Vierus / Ocean Image Bank

14
2.4. The financial risks of DSM

FIs should view any involvement with the DSM industry as high risk, owing to the considerable 
uncertainty surrounding the economic outcomes and viability of DSM activities.86 
Largely unproven thus far at the commercial scale,87 DSM operations require significant capital and 
operational expenditure.88 Nautilus Minerals, a Canadian mining company, secured the first-ever permit 
for DSM in 2011 in the jurisdictional waters of Papua New Guinea. The project – Solwara I – subsequently 
failed amid legal challenges and heavy criticism from environmental and local groups. This led to 
Nautilus filing for bankruptcy in 2019, leaving the Government of Papua New Guinea US$120 million in 
debt. At present, not a single company is carrying out commercial DSM.
The industry’s long-term commercial viability rests heavily on whether the level and timing of future 
demand for the metals targeted by DSM operations will enable their profitable extraction from the 
seafloor. Owing to various regulatory, technical and economic factors, timescales for the development 
of DSM operations are highly uncertain and may not align with rates of increasing metal demand.89 
Additionally, a 2016 report by the Institute of Sustainable Futures found that, even under the most 
ambitious scenario – a transition to a 100% renewable energy economy on a global basis by 2050 – 
demand for these metals can be met without mining the deep sea, but rather from known terrestrial 
resources as well as improved recycling of metals.90 The authors also note the possibility that new 
terrestrial resource discoveries could occur before 2050, further increasing supply.91 Indeed, over the 
past 25 years, the number of known lithium reserves increased by a factor of ten, while cobalt, nickel and 
copper reserves have more than doubled.92 A study commissioned by the ISA similarly found that the 
terrestrial supply of key deep-sea metals is around 60 years of resources for nickel, 100 years for cobalt 
and more than 100 years for copper.93 As such, DSM may only serve to contribute to a global surplus of 
these metals, potentially even depressing market prices and making DSM economically unviable.94
Overview of Li-ion battery raw materials 
Source: Manhart, A. & McLennan, A. (2023). The rush for metals in the deep sea. Considerations on deep-sea mining. Study for Greenpeace e.V., Freiburg. February 2023.

15
Furthermore, future projections of the amount of these minerals required for the energy transition are 
extremely uncertain as they are unable to take into account innovations in battery technologies, which 
are developing rapidly and will significantly impact the mix of metals and materials that will be used, and 
thus levels of demand, in the coming years.95 An analysis by RMI concludes that this evolution of battery 
technologies has set in motion “a seismic shift in how we will organise energy systems as early as 2030”, 
with new battery chemistries expected to compete with the prevailing lithium-ion (Li-ion) technology.96 
Within the global passenger electric vehicle market, battery technologies that require neither nickel 
nor cobalt, such as lithium-iron-phosphate (LFP) batteries, have seen their market share rise to 31% in 
September 2022 compared to just 17% in January 2021.97 Recent breakthroughs in lithium-air batteries 
– which have the highest projected energy density of any next-generation battery technology – propose 
designs which use no cobalt at all.98
Demand for DSM metals is also highly likely to be negatively impacted by the global shift towards a 
circular economy. Current recycling rates of high-demand metals such as silver, lithium, neodymium 
and dysprosium are less than 1% – an increase in recycling would improve production rates and reduce 
incentives to mine new sources of supply.99 The introduction of new regulations, such as the forthcoming 
EU Battery Regulation,100 which provide mandatory obligations for battery recycling and collection, 
end-of-life requirements, targets for the recovery of metals and extended producer responsibility may 
all further reduce demand for virgin metals.

Box 4: Recent market developments illustrate the falling confidence of investors 
and corporates in DSM’s viability
●	 In March 2023, Lockheed Martin – the DSM industry’s largest corporate backer – 
announced the sale of its DSM-focused UK Seabed Resources subsidiary, which has held 
ISA exploration licences since 2013, to Loke Marine Minerals, a comparatively small 
Norwegian startup.101 While Lockheed Martin declined to give a reason for the sale, the 
company’s withdrawal from the DSM industry is reflective of growing scepticism towards 
DSM from major corporations.
●	 Falling investor confidence is also shown by the faltering share price of The Metals 
Company (TMC), one of the largest DSM companies worldwide by exploration area, which 
holds three exploration contracts for polymetallic nodules in areas beyond national 
jurisdiction and, together with Allseas Group, recently completed one of the first pilot 
tests of nodule mining in the Clarion-Clipperton Zone of the Pacific Ocean. TMC’s share 
price lost 90% of its value in the 12 months after its September 2021 Initial Public Offering 
(IPO), and its shares have regularly traded at below US$1 in recent months, resulting in the 
NASDAQ issuing a delisting notice to TMC in December 2022 and again in April 2023.102
●	 Shipping company A.P. Moller-Maersk is the latest major name to divest itself of interests 
in the DSM industry, announcing it is in the process of selling its stake in TMC.103 Maersk 
had previously been issued with shares in TMC in return for the provision of marine vessel 
services for TMC’s DSM exploration activities.104 
Within the global passenger electric vehicle market, battery technologies that require neither nickel 
nor cobalt, such as lithium-iron-phosphate (LFP) batteries, have seen their market share rise to 31% in 
September 2022 compared to just 17% in January 2021.

16
2.5. The legal and regulatory risks of DSM
The ISA is still in the process of negotiating the regulatory framework for exploitation of the 
deep seabed in areas beyond national jurisdiction. However, as a result of mounting opposition 
(see Section 3) and the complexity of issues involved, including a severe lack of knowledge of deep-sea 
environments, it is highly unlikely that the regulatory framework will be finalised in the near future, 
given that the adoption of exploitation regulations requires the consensus of all ISA Council member 
states. Indeed, as scientific knowledge about the environmental impacts of DSM continues to grow, it 
is possible that any finalised regulations will be crafted in a more restrictive manner. These regulatory 
uncertainties may well add to costs for DSM companies. 
A further threat to the DSM industry comes from risk of litigation. TMC has come under criticism for 
failing to disclose material environmental, social and economic risks associated with DSM, and is facing 
two class-action lawsuits from investors who allege that TMC made false and misleading statements, 
including downplaying “the environmental risks of deep-sea mining polymetallic nodules” and failing to 
“adequately warn investors of the regulatory risks faced by TMC’s environmentally risky exploitation plans”.105
Litigation risk extends to the environmental impacts of DSM upon third parties. Referring to data 
from Blue Peril, the first science-based visual investigation of the impacts of DSM in the Pacific Ocean 
conducted independently of the industry and the ISA, the Deep Sea Mining Campaign highlights that 
“new modelling heralds that should TMC begin commercial operations, significant environmental liabilities are 
likely to beset TMC, Allseas, and the governments that sponsor their DSM operations in the Pacific Ocean. The 
modelling indicates that pollution discharged by TMC in its Tonga license area would only take three months to 
reach the waters of Hawaii and Kiribati”.106
“Claims for loss and damage due to TMC’s operations could reasonably be expected to encompass economic 
impacts on Pacific Island nations, on Pacific islander communities, commercial fisheries, and marine-
based tourism. Health impacts may be suffered by consumers of mine waste-contaminated seafood, due 
to heavy metals released from the mining operations bioaccumulating through the food chain, as well as 
from the pollution generated by processing plants. These impacts could lead to additional liabilities.”
Deep Sea Mining Campaign, Shareholder Advisory on the Proposed Business Combination
between Sustainable Opportunities Acquisition Corporation and DeepGreen107 
Sibelius Seamount, NOAA Office of Ocean Exploration and Research.

17
3. Growing opposition to DSM: reputational risk for FIs


A growing number of governments, parliamentarians, scientists, NGOs and businesses are 
calling for a halt to DSM in areas beyond national jurisdiction, as a result of serious concerns 
over the impacts on marine biodiversity and highly vulnerable ecosystems (see Table 1 below). 
Critically, an increasing number of eminent private companies including BMW, Volkswagen, Samsung 
and Google have voiced concerns about DSM and publicly committed not to purchase minerals from 
the deep seabed,108 casting further doubt on the business case for commercial DSM. Additionally, the 
Initiative for Responsible Mining Assurance – which offers third-party certification of mining best 
practices through its Standard for Responsible Mining and counts Ford, Tesla and Microsoft among 
its members – has repeatedly underlined that it will not allow its certification system to be used by 
companies involved in DSM.109
The United Nations Environment Programme Finance Initiative (UNEP-FI) has cast doubt on the 
sustainability of DSM, stating that it sees “no foreseeable way in which the financing of deep-sea mining 
activities can be viewed as consistent with the Sustainable Blue Economy Finance Principles”, whilst also 
highlighting the industry’s considerable operational, regulatory, and reputational risks.110 Work 
commissioned by another UN body, the High-Level Panel for a Sustainable Ocean Economy, has also 
highlighted that “the potential to mine the deep seabed raises various environmental, legal and governance 
challenges, as well as possible conflicts with the United Nations Sustainable Development Goals”.111
“[T]here is no foreseeable way in which the financing of deep-sea mining activities can be viewed as 
consistent with the Sustainable Blue Economy Finance Principles, or compatible with the spirit and 
intent of the Sustainable Blue Economy.”
United Nations Environment Programme’s Sustainable Blue Economy Finance Initiative112 
In sum, the growing global movement against DSM presents a potentially severe reputational risk for FIs 
who support it. This risk is highly likely to intensify in years to come as public awareness grows of the 
irreparable and far-reaching environmental impacts of the industry. 
Dumbo Octopus, NOAA Office of Ocean Exploration and
Research, 2019 Southeastern U.S. Deep-sea Exploration.

18
GOVERNMENTS AND 
PARLIAMENTARIANS
COMPANIES
FINANCIAL INSTITUTIONS 
FISHING SECTOR
SCIENTISTS AND
CIVIL SOCIETY ACTORS
•	Pacific and Oceania: 
Palau, Vanuatu, Fiji, Samoa, 
Federated States of 
Micronesia (“Moratorium 
Alliance”), New Zealand
•	Europe: 
France, Germany, Spain
•	Latin America and
the Caribbean: 
Costa Rica, Chile, Panama, 
Ecuador, Dominican 
Republic
•	European Commission and 
the European Parliament
•	250 parliamentarians from 
over 50 countries
•	IUCN World Conservation 
Congress* 
•	BMW Group
•	Breitling
•	Google
•	Microsoft
•	Patagonia
•	Philips
•	Renault Group
•	Rivian
•	Samsung SDI
•	Scania
•	Volkswagen 
Group
•	Volvo Group
•	ABN AMRO
•	BBVA
•	Cooperative Bank
•	Credit Suisse
•	Generation Investment 
Management
•	Globalance
•	Fama Investimentos
•	Lloyds Banking Group
•	NatWest
(previously Royal Bank 
of Scotland)
•	Standard Chartered 
Bank
•	Triodos Bank
•	The European 
Investment Bank
•	Storebrand
•	African Confederation of 
Professional Artisanal 
Fishing Organisations 
(CAOPA)
•	 EU’s Long Distance, 
North-western Waters and 
Pelagic Advisory Councils 
(LDAC, NWWAC and 
PELAC)
•	International Pole and Line 
Foundation
•	Norwegian Fisheries 
Association
•	SATA (South Africa Tuna 
Association)
•	SAHLLA (South 
African Hake Long Line 
Association)
•	754 marine science and 
policy experts from
over 44 countries have 
signed a statement 
calling for a pause to 
deep-sea mining. 
•	Over 400 civil society 
organisations from 
across the world have 
joined a DSCC initiative 
calling for a moratorium 
on deep-sea mining.
€
* 81 governments and government agencies from 37 countries voted in favour of the motion calling for a moratorium. 577 NGOs and civil society
organisations also voted in favour.

Table 1: Opposition to DSM – Groups that have voiced opposition or concern over deep-sea mining

19
“My concern about deep-sea mining is that we know so little about these ecosystems, and that exploration 
may very well have significant unintended negative consequences for the ecosystem in the wider sense. 
And of course, we have to remember that the deep sea is really one of the very few pristine ecosystems 
remaining, and to just open up for exploitation without insight is close to madness.”
Jan Erik Saugestad – Executive Vice President, 
Storebrand Asset Management
Nations opposed to DSM or which have called for a precautionary pause or moratorium (as of April 2023)

20
Watch EJF’s new film
Report 
Executive summary 
“[There] may be permanent and irreversible risks to deep-sea ecosystems [as a result of deep-sea 
mining]. As such...the financial sector should join us in excluding deep-sea mining from their 
financing and investment activities.”
Johanna Schmidt – Investment Strategist,
Triodos Investment Management
For more information or to meet with a policy expert in this area, please email: 
Steve Trent, CEO   	
Suzi Shingler, Campaigns Coordinator
steven.trent@ejfoundation.org   	
suzi.shingler@ejfoundation.org


To view EJF’s report and film on DSM, Towards the Abyss: How the Rush to Deep Sea Mining Threatens People 
and our Planet, please see the links below:
EJF’s campaign to stop deep-sea mining is generously 
supported by Arcadia, a charitable foundation that works 
to protect nature, preserve cultural heritage and promote 
open access to knowledge. arcadiafund.org.uk
Credit: Image courtesy of Expedition to 
the Deep Slope 2007, NOAA-OE. (CC BY 2.0)

21
1	
 Fauna & Flora (2023) Update to ‘An assessment of the risks and impacts 
of seabed mining on marine ecosystems’, https://www.fauna-flora.org/app/
uploads/2023/03/fauna-flora-deep-sea-mining-update-report-march-23.pdf.
2	
 For more information, see EJF’s report on DSM: EJF (2023) Towards the 
abyss: How the rush to deep sea mining threatens people and our planet. 
https://ejfoundation.org/reports/towards-the-abyss-deep-sea-mining  
3	
 International Finance Corporation (2012) Performance Standard 6: 
Biodiversity Conservation and Sustainable Management of Living Resources, 
https://www.ifc.org/wps/wcm/connect/3baf2a6a-2bc5-4174-96c5-
eec8085c455f/PS6_English_2012.pdf?MOD=AJPERES&CVID=jxNbLC0. 
4	
Woody, T. (2023) ‘Deep Sea Mining Just Lost Its Biggest Corporate 
Backer’, Bloomberg UK, 22 March, https://www.bloomberg.com/news/
articles/2023-03-22/deep-sea-mining-just-lost-its-biggest-corporate-backer 
(accessed 27 April 2023).
5	
Khan, Y. (2023) ‘Shipping Giant Maersk Drops Deep Sea Mining 
Investment’, Wall Street Journal, 3 May, https://www.wsj.com/articles/
shipping-giant-maersk-drops-deep-sea-mining-investment-c226df39 
(accessed 4 May 2023).
6	
Deep Sea Conservation Coalition (undated) ‘Resistance to deep-sea 
mining: governments and parliamentarians’, ‘https://savethehighseas.
org/voices-calling-for-a-moratorium-governments-and-parliamentarians/ 
(accessed 27 April 2023).
7	
Noseabedmining.org (undated) ‘Business Statement Supporting a 
Moratorium on Deep Seabed Mining’, https://www.noseabedmining.org/ 
(accessed 29 March 2023); WWF (2021) ‘Business Backlash Against Deep-Sea 
Mining Grows’, https://wwf.panda.org/wwf_news/?4541466/Business-Backlash-
Against-Deep-Sea-Mining-Grows (accessed 27 April 2023).
8	
 To include lending, investing, capital markets underwriting, and 
insuring.
9	
 To include companies within the energy technology, consumer 
electronics, automotive, and telecommunications industries.
10	  Noseabedmining.org (undated) ‘Business Statement Supporting a 
Moratorium on Deep Seabed Mining’, https://www.noseabedmining.org/ 
(accessed 29 March 2023). 
11	  United Nations Environment Programme Finance Initiative (2022) 
Harmful Marine Extractives: Understanding the risks & impacts of financing 
non-renewable extractive industries, Geneva, https://www.unepfi.org/
wordpress/wp-content/uploads/2022/05/Harmful-Marine-Extractives-Deep-
Sea-Mining.pdf. 
12	  To help financial institutions with due diligence and the implementation 
of a DSM-policy, WWF engaged Profundo (NL) to carry out a market analysis 
with the goal of identifying companies engaged in DSM, as well as financial 
institutions with ties to these companies. This analysis provided an initial 
list which includes 52 parent companies and 72 subsidiaries to support 
further action. See WWF (2022) Deep Seabed Mining: WWF’s guide for financial 
institutions, https://wwfint.awsassets.panda.org/downloads/wwf_briefing_
financial_institutions_dsm.pdf.
13	  GEOMAR (undated) ‘Factsheet Manganese Nodules. Rich Mineral Fields 
on the Seabed’, https://www.geomar.de/fileadmin/content/entdecken/
rohstoffe_ozean/manganknollen/factsheet_manganknollen_en.pdf. 
14	  Fauna & Flora (2023) Update to ‘An assessment of the risks and impacts 
of seabed mining on marine ecosystems’, https://www.fauna-flora.org/app/
uploads/2023/03/fauna-flora-deep-sea-mining-update-report-march-23.
pdf; IUCN (2022) IUCN Issues Brief: Deep Sea Mining, https://www.iucn.org/
resources/issues-brief/deep-sea-mining.
15	  Cecco, L. (2023) ‘Leaked video footage of ocean pollution shines light on 
deep-sea mining’, The Guardian, 6 February, https://www.theguardian.com/
environment/2023/feb/06/leaked-video-footage-of-ocean-pollution-shines-
light-on-deep-sea-mining; Nauru Ocean Resources Inc. (2021) Collector Test 
Study, Environmental Impact Assessment: Testing of polymetallic nodule collector 
system components in the NORI-D contract area, Clarion-Clipperton Zone, Pacific 
Ocean, https://static1.squarespace.com/static/611bf5e1fae42046801656c0/t/
6152820c295c1543ff79796c/1632797221691/NORI-D+COLLECTOR+TEST+EIS_ 
FINAL_ABBREVIATED_RE.pdf.
16	  Hauton, C., Brown, A., Thatje, S., Mestre, N. C., Bebianno, M. J., Martins, 
I. et al. (2017) ‘Identifying Toxic Impacts of Metals Potentially Released 
during Deep-Sea Mining—A Synthesis of the Challenges to Quantifying Risk’, 
Frontiers in Marine Science, 4, https://doi.org/10.3389/fmars.2017.00368.
17	  Coffey Natural Systems (2008) Nautilus Minerals Niugini Limited, Solwara 
1 Project Environmental Impact Statement (Executive Summary), https://
dsmobserver.com/wp-content/uploads/2017/05/Environmental-Impact-
Statement-Executive-Summary-English-1.pdf 
18	  Anon. (2023), ‘Papua New Guinea Government to pursue Solwara 1 
deep sea mining talks’, Pacific Mining Watch, 23 March, https://mine.onepng.
com/2023/03/papua-new-guinea-government-to-pursue.html (accessed 18 
April 2023). 
19	  Japanese Organisation for Metals and Energy Security (2020) ‘JOGMEC 
Conducts World’s First Successful Excavation of Cobalt-Rich Seabed 
in the Deep Ocean’, https://www.jogmec.go.jp/english/news/release/
news_01_000033.html (accessed 31 March 2023).
20	  The International Seabed Authority (ISA), established under the 
1982 United Nations Convention on the Law of the Sea (UNCLOS) and the 
1994 Agreement relating to the implementation of Part XI of UNCLOS 
(Implementation Agreement), is the intergovernmental body of 167 member 
states and the EU which is responsible for regulating deep-sea mining in the 
international seabed (the Area).
21	  Deep Sea Mining Alliance (undated) ‘Technology development and 
knowledge transfer for a secure supply of raw materials’, https://www.
deepsea-mining-alliance.com/en-gb/home (accessed 29 March 2023); The 
Metals Company (undated) ‘Frequently Asked Questions’, https://metals.co/
frequently-asked-questions/ (accessed 29 March 2023).
22	  Deep Sea Conservation Coalition (undated) ‘Momentum for a 
Moratorium’ https://savethehighseas.org/moratorium_2022/ (accessed 28 
March 2023).
23	  Teske, S., Florin, N., Dominish, E. and Giurco, D. (2016) Renewable 
Energy and Deep Sea Mining: Supply, Demand and Scenarios, Broadway, 
Australia: Institute for Sustainable Futures, https://opus.lib.uts.edu.au/
bitstream/10453/67336/1/DSM%20-%20RE%20resource%20Report_9_
FINAL%20DRAFT-NEWTITLE-ANDNAME.pdf.
24	  Niner, H. J., Ardron, J. A., Escobar, E. G., Gianni, M., Jaeckel, A., Jones, 
D. O. B. et al. (2018). Deep-Sea Mining with No Net Loss of Biodiversity—An 
Impossible Aim. Frontiers in Marine Science, 5, 53, https://doi.org/10.3389/
fmars.2018.00053; Van Dover, C. L., Ardron, J. A., Escobar, E., Gianni, M., 
Gjerde, K. M., Jaeckel, A. et al. (2017). Biodiversity Loss from Deep-Sea 
Mining. Nature Geoscience, 10, 464–465, https://doi.org/10.1038/ngeo2983.
25	  Danovaro, R., et al. (2010) ‘Deep-Sea Biodiversity in the Mediterranean 
Sea: The Known, the Unknown, and the Unknowable’, PLOS One, 5, https://
doi.org/10.1371/JOURNAL.PONE.0011832.
26	  IUCN (2004) High Seas Bottom Trawl Fisheries and their Impacts on the 
Biodiversity of Vulnerable Deep-Sea Ecosystems: Options for International Action, 
https://portals.iucn.org/library/node/8532. 
27	  Sinniger, F., et al. (2016) ‘Worldwide Analysis of Sedimentary DNA 
Reveals Major Gaps in Taxonomic Knowledge of Deep-Sea Benthos’, Frontiers 
in Marine Science, 3, https://doi.org/10.3389/fmars.2016.00092. 
28	  Amon, D. J., Gollner, S., Morato, T., Smith, C. R., Chen, C., Christiansen, 
S. et al. (2022). Assessment of Scientific Gaps Related to the Effective 
Environmental Management of Deep-Seabed Mining. Marine Policy, 138, 
105006, https://doi.org/10.1016/j.marpol.2022.105006.
29	  Roark, E. B., Guilderson, T. P., Dunbar, R. B., Fallon, S. J. & Mucciarone, D. 
A. (2009). Extreme Longevity in Proteinaceous Deep-Sea Corals. Proceedings 
of the National Academy of Sciences, 106, 5204–5208,
https://doi.org/10.1073/pnas.0810875106.
30	  Jochum, K. P., Wang, X., Vennemann, T. W., Sinha, B. & Müller, W. 
E. G. (2012) Siliceous Deep-Sea Sponge Monorhaphis chuni: A Potential 
Paleoclimate Archive in Ancient Animals. Chemical Geology, 300–301, 
143–151, https://doi.org/10.1016/j.chemgeo.2012.01.009.
31	  Purser, A., Marcon, Y., Hoving, H.-J. T., Vecchione, M., Piatkowski, U., 
Eason, D. et al. (2016). Association of Deep-Sea Incirrate Octopods with 
Manganese Crusts and Nodule Fields in the Pacific Ocean. Current Biology, 26, 
R1268–R1269, https://doi.org/10.1016/j.cub.2016.10.052; GEOMAR (undated). 
‘Manganese nodules as breeding ground for deep-sea octopuses’, accessed 
08.02.2023, https://www.geomar.de/en/news/article/manganese-nodules-as-
breeding-ground-for-deep-sea-octopuses. 
32	  Heffernan, O. (2019) ‘Seabed mining is coming - bringing mineral 
riches and fears of epic extinctions’, Nature, 571, pp. 465-468. https://doi.
org/10.1038/D41586-019-02242-Y.
33	  Garrigue, C., Clapham, P. J., Geyer, Y., Kennedy, A. S., & Zerbini, A. N. 
(2015) ‘Satellite tracking reveals novel migratory patterns and the importance 
of seamounts for endangered South Pacific humpback whales’, Royal Society 
Open Science, 2, https://doi.org/10.1098/RSOS.150489; Morato, T., Miller, P. 
I., Dunn, D. C., Nicol, S. J., Bowcott, J., & Halpin, P. N. (2016) ‘A perspective 
on the importance of oceanic fronts in promoting aggregation of visitors 
to seamounts’, Fish and Fisheries, 17, pp. 1227–1233, https://doi.org/10.1111/
FAF.12126.
34	  Yesson, C., Clark, M. R., Taylor, M. L., & Rogers, A. D. (2011) ‘The global 
distribution of seamounts based on 30 arc seconds bathymetry data’, Deep 
Sea Research Part I: Oceanographic Research Papers, 58, pp. 442–453, https://doi.
org/10.1016/J.DSR.2011.02.004.
35	  Lusty, P. A. J., Jones, D. O. B., Diz, D., Durden, J. M., Grant, H. L. J. & 
Josso, P. (2021). Deep Sea Mining Evidence Review. British Geological Survey 
Commissioned Report CR/21/119, 463pp. Report produced by the British 
Geological Survey, National Oceanography Centre and Heriot-Watt University 
under contract to FCDO. https://www.bgs.ac.uk/download/deep-sea-mining-
evidence-review/; Dyment, J.,  Lallier, F., Le Bris, N., Rouxel, O., Sarradin, P.-M., 
Lamare, S., Coumert, C., Morineaux, M., Tourolle, J. (coord.) (2014). Les impacts 
environnementaux de l’exploitation des ressources minérales marines profondes. 
Expertise scientifique collective. Rapport, CNRS – Ifremer, 930pp. https://www.
inee.cnrs.fr/fr/impacts-environnementaux-de-lexploitation-des-ressources-
minerales-marines-profondes.
36	  Fauna & Flora (2023) Update to ‘An assessment of the risks and impacts 
of seabed mining on marine ecosystems’, https://www.fauna-flora.org/app/
uploads/2023/03/fauna-flora-deep-sea-mining-update-report-march-23.
pdf; Chin, A. and Hari, K. (2020). Predicting the impacts of mining of deep sea 
polymetallic nodules in the Pacific Ocean: A review of scientific literature. Deep 
Sea Mining Campaign and MiningWatch Canada, 52pp. https://miningwatch.
ca/sites/default/files/nodule_mining_in_the_pacific_ocean.pdf; Deep 
Sea Conservation Coalition (DSCC) (2022). Deep-sea mining: the science and 
potential impacts. https://savethehighseas.org/wp-content/uploads/2022/03/
DSCC_FactSheet2_DSM_science_4pp_Feb22.pdf.
37	  Weaver, P. P. E., Billett, D. S. M. & van Dover, C. L. (2018). Environmental 
Risks of Deep-sea Mining, in Salomon, M. & Markus, T. (eds.) Handbook on 
Marine Environment Protection: Science, Impacts and Sustainable Management, 
vol. 1, Springer, Berlin, 215–246; Jones, D. O. B., Amon, D. J. & Chapman, A. 
S. A. (2018). Mining deep-ocean mineral deposits: what are the ecological 
risks?. Elements, 14, 325–330, https://doi.org/10.2138/gselements.14.5.325.
38	  Williams, R., Erbe, C., Duncan, A., Nielsen, K., Washburn, T. & Smith, 
C. (2022). Noise from Deep-Sea Mining May Span Vast Ocean Areas. Science, 
377, 157–158, https://doi.org/10.1126/science.abo2804; Thompson, K. F.,

22
Miller, K. A., Wacker, J., Derville, S., Laing, C., Santillo, D. et al. (2023). 
Urgent Assessment Needed to Evaluate Potential Impacts on Cetaceans from 
Deep Seabed Mining, Frontiers in Marine Science, 10, 1095930, https://doi.
org/10.3389/fmars.2023.1095930.
39	 Simon-Lledó, E., Bett, B. J., Huvenne, V. A. I., Köser, K., Schoening, T., 
Greinert, J. et al. (2019) ‘Biological Effects 26 Years after Simulated Deep-Sea 
Mining’, Scientific Reports, 9, https://doi.org/10.1038/s41598-019-44492-w; 
Vonnahme, T.R., Molari, M., Janssen, F., Wenzhöfer, F., Haeckel, M., Titschack, 
J. et al. (2020) ‘Effects of a Deep-Sea Mining Experiment on Seafloor Microbial 
Communities and Functions after 26 Years’, Science Advances, 6, https://doi.
org/10.1126/sciadv.aaz5922.
40	  Clark, M. R., Durden, J. M. & Christiansen, S. (2020). Environmental Impact 
Assessments for deep-sea mining: Can we improve their future effectiveness? 
Marine Policy, 114, https://doi.org/10.1016/j.marpol.2018.11.026
41	  Storebrand (2022) Storebrand Policy on Nature, https://www.storebrand.
no/en/asset-management/sustainable-investments/active-ownership/
biodiversity-and-ecosystems/_/attachment/inline/42b9db43-4da4-4333-
a1cc-21680cf63260:6732fab29b23c226a80b1f117a10462748ff675b/86158%20
-Storebrand-Policy-on-Nature.pdf.
42	  Storebrand (2022) ‘Storebrand strengthens its commitment to 
nature’, mynewsdesk.com, 1 December, https://www.mynewsdesk.com/
storebrand-asa/pressreleases/storebrand-strengthens-its-commitment-to-
nature-3220297.
43	  Fixsen, R. (2022) ‘Storebrand dumps four mining stocks in new nature 
protection drive’, IPE, 1 December, https://www.ipe.com/news/storebrand-
dumps-four-mining-stocks-in-new-nature-protection-drive/10063766.
article. 
44	  A useful explanation of this interdependency is given by the European 
Commission in Horizon, the EU research & innovation magazine: “In a 
two-way process, climate change is one of the main drivers of biodiversity 
loss, but destruction of ecosystems undermines nature’s ability to regulate 
greenhouse gas (GHG) emissions and protect against extreme weather, thus 
accelerating climate change and increasing vulnerability to it. This explains 
why the two crises must be tackled together with holistic policies that 
address both issues simultaneously and not in silos”. European Commission 
(undated) ‘Climate change and biodiversity loss should be tackled together’, 
Horizon, https://ec.europa.eu/research-and-innovation/en/horizon-
magazine/climate-change-and-biodiversity-loss-should-be-tackled-together.
45	  Almeida, E. et al. (2021) NGFS Occasional Paper, Biodiversity and financial 
stability: building the case for action, https://www.lse.ac.uk/granthaminstitute/
wp-content/uploads/2021/10/Biodiversity-and-financial-stablity_building-
the-case-for-action.pdf.
46	  Principles for Responsible Investment (2022), ‘150 financial institutions, 
managing more than $24 trillion, call on world leaders to adopt ambitious 
Global Biodiversity Framework at COP15’, 13 December, https://www.unpri.
org/news-and-events/150-financial-institutions-managing-more-than-
24-trillion-call-on-world-leaders-to-adopt-ambitious-global-biodiversity-
framework-at-cop15/10926.article (accessed 25 April 2023)
47	  Finance for Biodiversity Foundation (2023), ‘About the pledge’, https://
www.financeforbiodiversity.org/about-the-pledge/ 
48	  European Central Bank (2020), Guide on climate-related and environmental 
risks: Supervisory expectations relating to risk management and disclosure, 
Frankfurt am Main: European Central Bank, https://www.bankingsupervision.
europa.eu/ecb/pub/pdf/ssm.202011finalguideonclimate-relatedandenvironm
entalrisks~58213f6564.en.pdf.
49	  Sadan, S. (2023) ‘Finance for positive, sustainable change’, Financial 
Conduct Authority, 10 February, https://www.fca.org.uk/news/blogs/finance-
positive-sustainable-change.
50	  Green Finance Institute (2023) ‘UK economy’s nature-related risk to be 
assessed for the first time’, https://www.greenfinanceinstitute.co.uk/gfihive/
insights/uk-economys-nature-related-risk-to-be-assessed-for-the-first-time/ 
(accessed 24th April 2023).
51	  Heath, M., Bowater, A., Orton, S., and May, H. (2023) ‘Financial 
institutions and biodiversity: the next hot topic in ESG’, Freshfields Bruckhaus 
Deringer, 22 February, https://sustainability.freshfields.com/post/102i8aw/
financial-institutions-and-biodiversity-the-next-hot-topic-in-esg.
52	  France requires financial institutions to disclose biodiversity risks and 
their targets and strategy for reducing their impacts on biodiversity (Code 
monétaire et financier, Articles L. 533-22-1 and D. 533-16-1).
53	  Taskforce on Nature-related Financial Disclosures (2023) The TNFD 
Nature-related Risk and Opportunity Management and Disclosure Framework 
Final Draft - Beta v0.4, https://framework.tnfd.global/wp-content/
uploads/2023/03/23-23882-TNFD_v0.4_Integrated_Framework_v6-1.pdf. 
54	   International Finance Corporation (2012) Performance Standard 
6: Biodiversity Conservation and Sustainable Management of Living 
Resources, https://www.ifc.org/wps/wcm/connect/3baf2a6a-2bc5-4174-96c5-
eec8085c455f/PS6_English_2012.pdf?MOD=AJPERES&CVID=jxNbLC0. 
55	  Ibid. at paragraph 16. 
56	  Wolff, T. (2005) ‘Composition and Endemism of the Deep-Sea 
Hydrothermal Vent Fauna’, Cahiers de biologie marine, 46, 97–104; Amon, D. 
J., Ziegler, A. F., Dahlgren, T. G., Glover, A. G., Goineau, A., Gooday, A. J. et al. 
(2016) ‘Insights into the Abundance and Diversity of Abyssal Megafauna in a 
Polymetallic-Nodule Region in the Eastern Clarion-Clipperton Zone’, Scientific 
Reports, 6, 30492, https://doi.org/10.1038/srep30492.
57	  Amon, D. J., Ziegler, A. F., Dahlgren, T. G., Glover, A. G., Goineau, A., 
Gooday, A. J. et al. (2016)’ Insights into the Abundance and Diversity of 
Abyssal Megafauna in a Polymetallic-Nodule Region in the Eastern Clarion-
Clipperton Zone’, Scientific Reports, 6, 30492, https://doi.org/10.1038/
srep30492.
58	  Vanreusel, A., Hilario, A., Ribeiro, P. A., Menot, L. & Arbizu, P. M. (2016) 
‘Threatened by Mining, Polymetallic Nodules Are Required to Preserve 
Abyssal Epifauna’, Scientific Reports, 6, 26808, https://doi.org/10.1038/
srep26808; Niner, H. J., Ardron, J. A., Escobar, E. G., Gianni, M., Jaeckel, 
A., Jones, D. O. B. et al. (2018) ‘Deep-Sea Mining with No Net Loss of 
Biodiversity—An Impossible Aim’, Frontiers in Marine Science, 5, 53, https://
doi.org/10.3389/fmars.2018.00053.
59	  International Finance Corporation (2012) Performance Standard 6: 
Biodiversity Conservation and Sustainable Management of Living Resources, 
https://www.ifc.org/wps/wcm/connect/3baf2a6a-2bc5-4174-96c5-
eec8085c455f/PS6_English_2012.pdf?MOD=AJPERES&CVID=jxNbLC0.
60	  Niner, H. J., Ardron, J. A., Escobar, E. G., Gianni, M., Jaeckel, A., Jones, 
D. O. B. et al. (2018) ‘Deep-Sea Mining with No Net Loss of Biodiversity—An 
Impossible Aim’, Frontiers in Marine Science, 5, https://doi.org/10.3389/
fmars.2018.00053; Van Dover, C. L., Ardron, J. A., Escobar, E., Gianni, M., 
Gjerde, K.
M., Jaeckel, A. et al. (2017) ‘Biodiversity Loss from Deep-Sea Mining’, Nature 
Geoscience, 10, https://doi.org/10.1038/ngeo2983. 
61	  Van Dover, C. L., Ardron, J. A., Escobar, E., Gianni, M., Gjerde, K. M., 
Jaeckel, A. et al. (2017) ‘Biodiversity Loss from Deep-Sea Mining’, Nature 
Geoscience, 10, https://doi.org/10.1038/ngeo2983.
62	  IUCN Red List (2019) ‘Scaly-foot Snail’, https://www.iucnredlist.org/speci
es/103636217/103636261#assessment-information (accessed 4 April 2023). 
63	  Ibid.
64	  Ibid.
65	  Amon, D. J., Gollner, S., Morato, T., Smith, C. R., Chen, C., Christiansen, 
S. et al. (2022) ‘Assessment of Scientific Gaps Related to the Effective 
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66	  Sigwart, D., Chen, C., Thomas, E.A., Allcock, A. L., Böhm, M., and 
Seddon, M. (2019) ‘Red Listing can protect deep-sea biodiversity’, Nature 
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67	  Bennun, L., Regan, E. C., Bird, J., van Bochove, J., Katariya, V., Livingstone, 
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68	  Thomas, E. A., Molloy, A., Hanson, N. B., Böhm, M., Seddon, M., Sigwart, 
J. D (2021) ‘A Global Red List for Hydrothermal Vent Molluscs’, Frontiers in 
Marine Science, 8, https://doi.org/10.3389/fmars.2021.713022; McVeigh, 
K. (2021) ‘Deep-sea mining may push hundreds of species to extinction, 
researchers warn’, The Guardian, 9 December, https://www.theguardian.
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mollusc-species-to-extinction. 
69	  IPCC (2021) Climate Change 2021: The Physical Science Basis, Contribution of 
Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on 
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70	  Herndl, G. J. & Reinthaler, T. (2013). Microbial Control of the Dark End of 
the Biological Pump. Nature Geoscience, 6, 718–724, https://doi.org/10.1038/
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Greeley, D. (2004). Oxygen Utilization and Organic Carbon Remineralization 
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45–52, https://doi.org/10.1023/B:JOCE.0000038317.01279.aa.
71	  Guinotte, J. M. & Fabry, V. J. (2008). Ocean Acidification and Its Potential 
Effects on Marine Ecosystems. Annals of the New York Academy of Sciences, 
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72	  Ocean sediments store almost twice as much carbon as terrestrial 
soils, and 80% of that carbon is stored in the top 1m of deep-sea sediments. 
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propagation of tailings from deep-sea mining under variable conditions 
by means of numerical simulations’, Deep Sea Research Part II: Topical 
Studies in Oceanography, 48, pp. 3469–3485, https://doi.org/10.1016/S0967-
0645(01)00053-4; Muñoz-Royo, C., Peacock, T., Alford, M. H., Smith, J. A., 
Le Boyer, A., Kulkarni, C. S. et al. (2021) ‘Extent of impact of deep-sea nodule 
mining midwater plumes is influenced by sediment loading, turbulence and 
thresholds’, Communications Earth & Environment, 2, https://doi.org/10.1038/
s43247-021-00213-8. 
73	  Orcutt, B. N., Bradley, J. A., Brazelton, W. J., Estes, E. R., Goordial, J. M., 
Huber, J. A. et al. (2020). Impacts of Deep-Sea Mining on Microbial Ecosystem 
Services. Limnology and Oceanography, 65, 1489–1510, https://doi.org/10.1002/
lno.11403.
74	  Stratmann, T., Lins, L., Purser, A., Marcon, Y., Rodrigues, C. F., Ravara, A. 
et al. (2018). Abyssal Plain Faunal Carbon Flows Remain Depressed 26 Years 
after a Simulated Deep-Sea Mining Disturbance. Biogeosciences, 15, 4131–4145, 
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75	  British Geological Survey, National Oceanography Centre, Heriot Watt 
University (2021). Lusty, P. A. J., Jones, D. O. B., Diz, D., Durden, J. M., Grant, 
H. L. J. & Josso, P., Deep Sea Mining Evidence Review, Commissioned Report 
CR/21/119, https://www.bgs.ac.uk/download/deep-sea-mining-evidence-
review/.
76	  Clark, M. (2013). Oceanic and deep-sea fishery resources of the Pacific: 
the potential impacts of deep sea mining. In SPC-EU Deep Sea Minerals 
Project. 4th Environmental Perspectives of Deep Sea Mineral Activities. Regional 
Technical Training Workshop Series, 9–13 December 2012, Nadi, Fiji. https://
dsm.gsd.spc.int/public/files/2014/4thWorkshopProceedingsReport.pdf.
77	  Jaeckel, A., Hanich, Q., Harden-Davies, H., van Leeuwen, J., Niner, H., 
Seto, K.L. and Voyer, M. (2022), ‘Seabed mining equity dilemmas in the 
Pacific’, RNZ, 8 February 2022, accessed 06.02.2023. https://www.rnz.co.nz/
international/pacific-news/461094/seabed-mining-equity-dilemmas-in-
the-pacific

23
78	  Bell, J. D., Senina, I., Adams, T., Aumont, O., Calmettes, B., Clark, S. et 
al. (2021). Pathways to sustaining tuna-dependent Pacific Island economies 
during climate change. Nature Sustainability, 4(10), 900–910. https://doi.
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79	  van der Grient, J. M. A., & Drazen, J. C. (2021). Potential spatial intersection 
between high-seas fisheries and deep-sea mining in international waters. Marine 
Policy, 129, 104564. https://doi.org/10.1016/J.MARPOL.2021.104564 
80	  Anon. (undated), ‘Blue Peril: A visual investigation of deep sea mining 
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81	  van der Grient, J. M. A., & Drazen, J. C. (2021). Potential spatial 
intersection between high-seas fisheries and deep-sea mining in 
international waters. Marine Policy, 129, 104564. https://doi.org/10.1016/J.
MARPOL.2021.104564; Clark, M. (2013). Oceanic and deep-sea fishery 
resources of the Pacific: the potential impacts of deep sea mining. In 
SPC-EU Deep Sea Minerals Project. 4th Environmental Perspectives of 
Deep Sea Mineral Activities. Regional Technical Training Workshop 
Series, 9–13 December 2012, Nadi, Fiji. https://dsm.gsd.spc.int/public/
files/2014/4thWorkshopProceedingsReport.pdf.
82	  Bell J. D., Johnson, J. E., Ganachaud, A. S., Gehrke, P. C., Hobday, A. J., 
Hoegh-Guldberg, O. et al. (eds.) (2011). Vulnerability of Tropical Pacific Fisheries 
and Aquaculture to Climate Change: Summary for Pacific Island Countries and 
Territories. Secretariat of the Pacific Community, Noumea, New Caledonia. 
https://coastfish.spc.int/component/content/article/412-vulnerability-of-
tropical-pacifc-fisheries-and-aquaculture-to-climate-change.html 
83	  Fainu, K. (2021), ‘‘Shark calling’: locals claim ancient custom threatened 
by seabed mining’,  The Guardian, 30 September 2021, accessed 07.02.2023, 
https://www.theguardian.com/world/2021/sep/30/sharks-hiding-locals-
claim-deep-sea-mining-off-papua-new-guinea-has-stirred-up-trouble; 
Childs, J. (2019), ‘Deep sea mining threatens indigenous culture in Papua New 
Guinea’, The Conversation, 19 February 2019, accessed 07.02.2023. https://
theconversation.com/deep-sea-mining-threatens-indigenous-culture-in-
papua-new-guinea-112012 
84	  Jaeckel, A., Harden-Davies, H., Amon, D.J. et al. (2023) ‘Deep seabed 
mining lacks social legitimacy’, npj Ocean Sustainability, 2, https://doi.
org/10.1038/s44183-023-00009-7.
85	  Ibid.
86	  Lusty, P. A. J., Jones, D. O. B., Diz, D., Durden, J. M., Grant, H. L. J. & 
Josso, P. (2021) Deep Sea Mining Evidence Review, British Geological Survey 
Commissioned Report CR/21/119, Nottingham: British Geological Survey, 
https://www.bgs.ac.uk/download/deep-sea-mining-evidence-review.
87	  See summary of stakeholder responses to Question 10.2.4. in Lusty, P. A. 
J., Jones, D. O. B., Diz, D., Durden, J. M., Grant, H. L. J. & Josso, P. (2021) Deep 
Sea Mining Evidence Review, British Geological Survey Commissioned Report 
CR/21/119, Nottingham: British Geological Survey, https://www.bgs.ac.uk/
download/deep-sea-mining-evidence-review; Manhart, A. & McLennan, A. 
(2023) The rush for metals in the deep sea. Considerations on deep-sea mining, 
Hamburg: Greenpeace e.V., https://www.greenpeace.de/publikationen/
Greenpeace_Studie_Tiefseebergbau_0.pdf. 
88	  Roth, R., Kirchain, R., Field, F., Peacock, T. (2018). ‘Understanding the 
Economics of Seabed Mining for Polymetallic Nodules’, Presentation by 
MIT given to the ISA Council Meeting in Kingston, Jamaica, 6 March 2018, 
https://web.archive.org/web/20221006182343/ https://www.isa.org.jm/files/
files/documents/economicspmn_0.pdf; Lusty, P. A. J., Jones, D. O. B., Diz, D., 
Durden, J. M., Grant, H. L. J. & Josso, P. (2021) Deep Sea Mining Evidence Review, 
British Geological Survey Commissioned Report CR/21/119, Nottingham: British 
Geological Survey, https://www.bgs.ac.uk/download/deep-sea-mining-
evidence-review.
89	  Lusty, P. A. J., Jones, D. O. B., Diz, D., Durden, J. M., Grant, H. L. J. & 
Josso, P. (2021) Deep Sea Mining Evidence Review, British Geological Survey 
Commissioned Report CR/21/119, Nottingham: British Geological Survey, 
https://www.bgs.ac.uk/download/deep-sea-mining-evidence-review.
90	  Teske, S., Florin, N., Dominish, E. and Giurco, D. (2016) Renewable 
Energy and Deep Sea Mining: Supply, Demand and Scenarios, Broadway, 
Australia: Institute for Sustainable Futures, https://opus.lib.uts.edu.au/
bitstream/10453/67336/1/DSM%20-%20RE%20resource%20Report_9_
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91	  Ibid.
92	  Simas, M., Aponte, F. & Wiebe, K. (2022) The Future is Circular. Circular 
Economy and Critical Minerals for the Green Transition, Trondheim: SINTEF, 
https://sintef.brage.unit.no/sintef-xmlui/bitstream/handle/11250/3032049/
CircularEconomyAndCriticalMineralsReport.pdf?sequence=7&isAllowed=y.
93	  Lapteva, A., Chernova, A., Khodina, M., Mustafa, T., Mustafina, F. & 
Smolnikova, A. (2020) Report to the International Seabed Authority: Study 
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economies of developing land-based producers of those metals which are likely 
to be most seriously affected, https://web.archive.org/web/20221206013119/
https://www.isa.org.jm/files/documents/impactstudy.pdf.
94	  Ibid.
95	  Deep Sea Conservation Coalition (2021) Deep-sea mining: what are the 
alternatives? https://savethehighseas.org/wp-content/uploads/2021/07/
DSCC_FactSheet9_DSM_Alternatives_4pp_14July_web.pdf; Manhart, A. & 
McLennan, A. (2023) The rush for metals in the deep sea. Considerations on 
deep-sea mining, Hamburg: Greenpeace e.V., https://www.greenpeace.de/
publikationen/Greenpeace_Studie_Tiefseebergbau_0.pdf.
96	  Bloch, C., Newcomb, J., Shiledar, S. and Tyson, M. (2019) Breakthrough 
Batteries: Powering the Era of Clean Electrification, Basalt: Rocky Mountain 
Institute, https://rmi.org/wp-content/uploads/2019/10/rmi_breakthrough_
batteries.pdf  
97	  Adamas Intelligence (2022) ‘Passenger EV Battery Chemistries: LFP for 
the Massive, NCM for the Majority’, https://www.adamasintel.com/lfp-for-
the-massive-ncm-for-the-majority/ (accessed 30 March 2023).
98	  Harmon, J. E. (2023) ‘New design for lithium-air battery could offer 
much longer driving range compared with the lithium-ion battery’, Argonne 
National Laboratory, 22 February, https://www.anl.gov/article/new-design-
for-lithiumair-battery-could-offer-much-longer-driving-range-compared-
with-the-lithiumion; Evans-Pritchard, A. (2023) ‘The coming EV batteries 
will sweep away fossil fuel transport, with or without net zero’, The Telegraph, 
7 March, https://www.telegraph.co.uk/business/2023/03/07/coming-ev-
batteries-will-sweep-away-fossil-fuel-transport-without/.
99	  Teske, S., Florin, N., Dominish, E. and Giurco, D. (2016) Renewable 
Energy and Deep Sea Mining: Supply, Demand and Scenarios, Broadway, 
Australia: Institute for Sustainable Futures, https://opus.lib.uts.edu.au/
bitstream/10453/67336/1/DSM%20-%20RE%20resource%20Report_9_
FINAL%20DRAFT-NEWTITLE-ANDNAME.pdf.
100	 European Council (2022), ‘Council and Parliament strike provisional 
deal to create a sustainable life cycle for batteries’, 9 December, https://www.
consilium.europa.eu/en/press/press-releases/2022/12/09/council-and-
parliament-strike-provisional-deal-to-create-a-sustainable-life-cycle-for-
batteries/
101	 Woody, T. (2023) ‘Deep Sea Mining Just Lost Its Biggest Corporate Backer’, 
Bloomberg UK, 22 March, https://www.bloomberg.com/news/articles/2023-03-22/
deep-sea-mining-just-lost-its-biggest-corporate-backer 
102	 The Metals Company Inc., Form 8-K filed with the United States 
Securities and Exchange Commission, 6 December 2022, https://www.
sec.gov/ix?doc=/Archives/edgar/data/0001798562/000110465922124759/
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www.sec.gov/ix?doc=/Archives/edgar/data/1798562/000110465923047863/
tm2312599d5_8k.htm 
103 Khan, Y. (2023) ‘Shipping Giant Maersk Drops Deep Sea Mining Invest­
ment’, 3 May, https://www.wsj.com/articles/shipping-giant-maersk-drops-
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104 Sustainable Opportunities Acquisition Corp (2021). Form S-4 filing with 
Securities and Exchange Commission. 5 August 2021. https://www.sec.gov/
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bleopp.htm
105	 U.S. District Courts, New York Eastern District, Carper v. TMC The Metals 
Company Inc. et al., 1:21-CV-05991, 28 October 2021, https://unicourt.com/
case/pc-db5-carper-v-tmc-the-metals-company-inc-et-al-1065767.; U.S. 
District Courts, New York Eastern District, Tran v. TMC The Metals Company 
Inc. et al., 1:21-CV-06325, 15 November 2021, https://unicourt.com/case/
pc-db5-tran-v-tmc-the-metals-company-inc-et-al-1077085. See also: Anon. 
(2021) ‘Alert: TMC The Metals Company Inc. f/k/a Sustainable Opportunities 
Acquisition Corp. Investors with Substantial Losses Have Opportunity to Lead 
Class Action Lawsuit – TMC, SOAC’, Businesswire, 28 October, https://www.
businesswire.com/news/home/20211028006295/en/ALERT-TMC-the-metals-
company-Inc.-fka-Sustainable-Opportunities-Acquisition-Corp.-Investors-
with-Substantial-Losses-Have-Opportunity-to-Lead-Class-Action-Lawsuit-
%E2%80%93-TMC-SOAC  and Anon. (2021), ‘The Metals Company’s Fortunes 
Sink As Deep Sea Governance Body Meets to Rush Rules’, MiningWatch 
Canada – Deep Sea Mining Campaign, 9 December 2021, https://miningwatch.
ca/news/2021/12/9/metals-company-s-fortunes-sink-deep-sea-governance-
body-meets-rush-rules#2 
106	 Anon. (2022) ‘Doomed deep sea miner The Metals Company under huge 
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107	 Deep Sea Mining Campaign (2021) Shareholder Advisory: The Proposed 
Business Combination between Sustainable Acquisition Corporation and 
DeepGreen, https://miningwatch.ca/sites/default/files/advice_to_soac_
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108	 Noseabedmining.org (undated) ‘Business Statement Supporting a 
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(accessed 29 March 2023).
109	 Initiative for Responsible Mining Assurance (2022) ‘IRMA’s Deep Sea 
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110	 United Nations Environment Programme Finance Initiative (2022) 
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111	  Haugan, P.M., Levin, L.A. (2020) What Role for Ocean-Based Renewable 
Energy and Deep Seabed Minerals in a Sustainable Future?, Washington 
D.C.: World Resources Institute, https://oceanpanel.org/wp-content/
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112	  United Nations Environment Programme Finance Initiative (2022) 
Harmful Marine Extractives: Understanding the risks & impacts of financing 
non-renewable extractive industries, Geneva, https://www.unepfi.org/
wordpress/wp-content/uploads/2022/05/Harmful-Marine-Extractives-Deep-
Sea-Mining.pdf.

24

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Anemone attached to a carbonate boulder. Aquapix and   
Expedition to the Deep Slope 2007, NOAA-OE, (CC BY-SA 2.0).