Unser Zeichen: 00506GS Ihr Zeichen: Date: May 6, 2014

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1 BIOLAB Forschungsinstitut, Postfach 1115, D Hohenwestedt Stakeholder Survey (ISBA/Cons/2014/1) International Seabed Authority Port Royal Street Kingston Jamaica Unser Zeichen: 00506GS Ihr Zeichen: Date: May 6, 2014 Dear Sir or Madam, Please find in the following the comments of Prof. Hjalmar Thiel and Dr. Gerd Schriever on the Stakeholder Engagement for the Developing a Regulatory Framework for Mineral Exploitation in the Area: Dr. Gerd Schriever and Dr. Hjalmar Thiel are deep sea ecologists with many years of experience in basic and applied deep-sea studies, particularly environmental studies related to mining polymetallic nodules (Pacific Ocean) and metalliferous sediments from the Atlantis II Deep (Red Sea). Together they have proposed and led the multidisciplinary DISCOL project ( ), and G. S. will participate in the project DISCOL REVISITED in Their results are published in various journals and reports or presented at symposia and workshops, for DISCOL results see the 22 papers in: Thiel (ed.) Gerd Schriever is director of Biolab Forschungsinstitut and of Oktopus, a company producing equipment for deep-sea research ( Hjalmar Thiel has been professor of biological oceanography at the University of Hamburg, retired in We agree that our personal details and our submission may be made publicly available. BIOLAB Forschungsinstitut Dr. Gerd Schriever Kieler Str. 51 D Hohenwestedt Postfach/ P.O. Box 1115 D Hohenwestedt Germany Telefon / Phone +49 (0) Fax +49 (0) Handy / Cell-Phone (0171) Ust.-Id. Nr./ Vat.-Id. No Steuer-Nr. / Vat-No

2 _ Gerd Schriever is interested to participate further in the stakeholder discussions and being part of a stakeholder group. His -contact is: schriever@bioloab.com Phone: Fax:

3 _ We comment on Part B: Environmental management terms and obligations as follows: B 16-General recommendations: In contrast to earlier years, when environmentalists believed and argued that km 2 would be disturbed in polymetallic nodule mining by each mining unit / contractor, it is known today that the suitable mining area within the claims is subdivided in small, minable blocks of varying size, irregularly distributed within the claim area. According to latest information a total mineable area of 10,500 km², subdivided in smaller units, is identified in one of the German claims. In a paper by Thiel, Schriever and Foell (2005) we assumed that by mining one block, an area of 200 km 2 would be disturbed at maximum (based on data from the French claim). We also assumed that species in general would have a distribution wider than this area, i. e. species might not be lost by mining. These are two hypotheses based on rather poor data. We tried to assemble a broader data base from other claims, but we were informed that information on mining block size and distribution were not available. Whether this was true or not, we suggested - and herewith we repeat this suggestion - that contractors should deliver information on size and distribution of mining blocks and the order, in which the blocks are proposed to be mined, when delivering their mining application. We suggested and suggest also that the ISA should have the right to direct the block order of mining under environmental aspects. The rationale behind this suggestions is that all mining activities should leave enough space, truly undisturbed stretches from which re-colonization of the disturbed area will occur. This concept needs information and discussion of the size of mining blocks, their order of mining, the space in between blocks, minimal area of species, species (morphological) distribution versus population (genetically) distribution. New information and knowledge may be available and the concept of leaving much undisturbed space between mining blocks may need modification. But the ISA should direct the ratio between undisturbed and disturbed areas within each claim. Within the exploitation guidelines ISA should recommend that the discharge of any tailings from the surface platform (ship or platform) from the rise of material and cold deep sea bottom water including material from the dewatering process before transport on land should be done close to the seafloor (about 50m above). An overview about Tailings discharge in deep sea mining is given by Schriever and Thiel The advantage of a near bottom discharge of tailings will be: 1. Before the mining will start, a baseline study of the pelagic fauna and flora and chemical and oceanographic data within the water column need to be done from the sea surface down to the bottom to document the state of the art in case an accident with environmental impacts happens on the surface platforms.

4 _ 2. During mining no monitoring of disturbances of the pelagic fauna and flora in the water column and of its physical and chemical structures need to be executed. Such investigations should be restricted to a bottom water layer (see above). This layer needs to be defined in its vertical extent according to the mining impacts. Ship based processing and the discharge of remains of any ore should not be allowed. Monitoring of any exploitation of deep sea mineral resources should be done by independent scientists or companies mandated by the ISA. B 17 - restoration, rehabilitation, obligation We think that any restoration or rehabilitation of seafloor areas disturbed by mining would increase the impacts already executed through mining. Therefore, any follow up action should be avoided. It may be justified for some rare species living at hydrothermal vents (not our field of expertise), but since mining should be restricted to former, inactive vent areas this may be not a valid concept. Concerning "obligation" see B 24. B 19 what ecosystem function are critical to restore As we know too less about the ecosystem functions in the deep sea and especially in nodule areas this question cannot be answered. B 24 - other fees or levies Releasing the contractors from (1) monitoring studies in the water column (except in the bottom layer, see above) and also from (2) restoration and (3) rehabilitation measures after mining, saves enormous costs for ship time, personal and equipment. An equivalent of these saved resources should be paid partially into an "ISA Environment Research Fund". Why? Large research projects related to environmental mining impacts will be necessary also in the future. Contractors cannot expect that multidisciplinary projects will be funded from national resources. The disturbance and re-colonization study DISCOL and additional projects were solely funded by the German Ministry of Education and Science for a period of 10 (!) years, including 4 (!) research cruises of about 4 to 7 weeks each. The follow up DISCOL REVISITED, with a 2-months cruise in 2015 will be funded by the same ministry with small contributions from participating European countries. The project MIDAS is approved by the European Council. Such broad oceanographic contributions to environmental studies seem to be too large for national funding. They need international support and according to the principle "disturber (polluter) pays" the funding of such projects fall into the obligation of the contractors.

5 _ Contractors should pay a yearly fee into the ISA Environmental Research Fund, e. g. the sum equivalent to 10 days charter of a large research ship. This would allow the support of larger research projects of common interest to all contractors. Such projects should be discussed and decided upon by the LTC plus invited scientists. Research should be conducted by an international research group, the principle investigator(s) proposed by the LTC. A similar proposal was published by Thiel, Foell and Schriever References Thiel, H. (ed.) 2001 Environmental impact studies for the mining of polymetallic nodules from the deep sea. Deep-Sea Research II, 48 (17/18), (2001). Thiel,H., G. Schriever und E. J. Foell (2005): Polymetallic nodule mining, waste disposal and species extinction at the abyssal seafloor. - Marine Georesources and Geotechnology 23, Thiel, H., E. J. Foell and G. Schriever Conceptual proposals for environmental investigations of deep-seabed mining. Underwater Mining Institute, Kiel OneMine.org Schriever, G. and Thiel, H Tailings and their Disposal in Deep-Sea Mining. Proceedings of the Tenth (2013) ISOPE Ocean Mining and Gas Hydrates Symposium, Szczecin, Poland, September 22-26, 2013, Hohenwestedt 06 May 2014