Cook Islands EEZ showing nodule abundance and islands consulted. SBM/21021952
Te Ipukarea Society’s response to the article by Gerald McCormack published in Cook Islands News on Thursday, February 11, 2021 on the impact of six mines on benthic megafauna.
Although McCormack is a well-respected
terrestrial ecologist in the Cook Islands, and has done extensive reading on
the topic, he is not an expert on deep sea biology or deep sea mining. As such,
the Seabed Minerals Authority (SBMA), being the regulatory body, should have
had the article peer-reviewed before sharing his opinions as if they were expert
conclusions. For the SBMA to promote his conclusions, on their website and in a
paid/sponsored Facebook post, without peer review by independent deep-sea
scientists, is irresponsible.
Some of McCormack’s conclusions on impacts to
megafauna (animals which are visible to the naked eye) are apparently derived
from a report of a Japanese research cruise report dated 2001, which included a
50km video transect. Only 22km of the transect was through high-density nodule
areas (HDNA). If, as assumed by McCormack, the single transect was 1m wide, the
area it covered equates to 0.022 sq.km – smaller than two rugby fields. That is
only 0.00004 per cent of HDNA and 0.000001 per cent of our EEZ. To make
conclusions about the likely impact of six deep-sea mines on megafauna based on
this tiny area cannot be considered a precautionary approach (a requirement in
international law under the UN Convention on the Law of the Sea).
Our arguments include:
• The very limited data collected, may suggest
some of what McCormack states in the article, but these surveys are nowhere
near comprehensive enough to show anything with a reasonable amount of
confidence. The results of this one-off survey should not be compared to the
results of the extensive surveys conducted over many years in the Clarion
Clipperton Zone (CCZ – an area in the north central Pacific Ocean where deep
sea research is taking place by independent researchers and mining companies).
Te Ipukarea Society maintains that much more research should be conducted in
the Cook Islands EEZ, and this be done as much as possible by independent
deep-sea biodiversity specialists.
• McCormack’s calculations of area within the
Cook Islands Exclusive Economic Zone (EEZ) which will be destroyed by these six
hypothetical mines – 20,000km2 - do not take into account the impacts of
sediment plumes. Modelling, which is still ongoing, indicates that sediment
plumes (uplifting sediment from the sea floor) could travel significant
distances from the mining site, even up to 100km away. The settled sediment
from the plume could smother other fauna (including microfauna, those invisible
to the naked eye), even if the layer is less than 1cm thick. Therefore, the
impact of mining will be far greater than just on the fauna directly removed
with the nodules. Some deep sea scientists predict this could impact between
two and five times more than the mined area.
• The photos taken during the Japanese survey
did not identify fauna down to the species level, and therefore do not provide
an accurate depiction of biodiversity. Even if our nodule rich areas do have
lower abundance and/or species diversity than the CCZ that does not make them
less significant. In fact, they could be more significant if not found
• In an article by McCormack last year, he
argues that a precautionary approach for the Cook Islands might be allowing one
mine to go ahead, after exploration, with ongoing monitoring to inform further
activity. McCormack has not referenced any data collected since then which
would justify his newly stated conclusion of six mines having minimal impacts.
• It is very premature to be making
conclusions about how many mines can go ahead with minimal impact on megafauna,
let alone the rest of the environment: the tolerance of our deep-sea fauna to
plumes and other mining impacts has not been determined; geographical range and
distribution of our deep-sea fauna has not been determined; our Marae Moana
Marine Spatial Planning has not been completed, and; ecotoxicological effects
on the food web and fisheries have not been determined. Furthermore, social,
economic, and cultural implications have not been studied in depth or shared
with our people.
• Finally, McCormack points out that the
destruction by mining in the Cook Islands CCZ concession (coordinated by
Belgian company GSR) will likely be worse than the destruction in our own EEZ.
In that case, perhaps it is time to re-think our role as a sponsor state for
this destruction, and instead focus on our global commitments to halt
While it may not have been McCormack’s
intention to provide justification for the Government to licence up to six
mining operations over a 40 year period, that is in fact the take home message
that most people will see. This view is further encouraged by the paid
promotion of the article by the SBMA. We need much more time to conduct
research to inform our conclusions on whether or not to mine our deep sea bed
at all, let alone allow six mining licences, even if only three at a time as