Offsetting The Effects Of Deep Sea Mining Activities

ECO Interview

An interview with Captain Chris Goldblatt, CEO, Fish Reef Project

A pioneer of the sustainable seafood movement, Christopher Fisher Goldblatt has enjoyed many years as a fishing vessel operator, free dive spear fisherman, and international seafood trader. He has worked in over 30 countries with fishermen and fisheries managers and is the founder and managing director of the Fish Reef Project, which has been given observer status by the International Seabed Authority. Goldblatt is also the author of seven oceanrelated books, contributing columnist to oceanrelated publications, and producer of films for international ocean film festivals.

The Fish Reef Project has been given observer status by the International Seabed Authority. What does your role entail?
The ISA is a United Nation-sanctioned body set up to manage the extraction of deep sea minerals. It includes over 160 nations and has been at work for 20 years creating the operating agreements for extraction that prevent conflicts between nations and assure a degree of fairness and access for smaller nations. The ISA meets every July for nearly three weeks. Fish Reef Project was vetted over a full year and voted in as a permanent observer to the ISA by all member states. Observer status provides access to the general assembly and intimate discussions about the future of deep sea mining. We also speak on record at the general assembly. The duty of observers is to address issues that may otherwise not be discussed and to lend an outside perspective. In the case of the Fish Reef Project, we are an NGO that was concerned that no action was being taken to offset the coming environmental impacts of deep sea mining, either by NGOs, industry, or state parties. We are proud to say that we have provided leadership in this realm by creating a worldwide system of measurable marine biomass offsets known as the International Marine Mitigation Bank (IMMB) that can help balance the scales of nature once impacts occur to the deep sea. Fish Reef Project has a specific mission to restore and enhance the marine ecosystem, and the IMMB is the perfect vehicle to accomplish this vital task.

What can nations do to avoid irreversible damage to ocean ecosystems?
Impact avoidance is paramount and should always be the first option. There are three types of deep sea mining: hydrothermal vents for sulfides, which have the most sensitive ecosystems; cobalt-rich crusts; and poly-metallic or manganese nodule fields. Once the impact occurs in the deep sea, especially with regards to the manganese nodule fields, the reality is that there is no fixing it in the area of impact. Hence, to restore and enhance more bio-diverse nearshore ecosystems such as coral reefs is the very best way to balance the scales of nature. By aiding nearshore ecosystems, we can bring massive socio-economic benefits to local communities that otherwise would never see a single benefit from deep sea mining. The Law of the Sea states very clearly that the ocean should be seen as single system and not compartmentalized—so this way of acting is in good keeping with the Law of the Sea. The Law of the Sea, that was in part originally motivated by mineral extraction rights, also clearly states that project owners have a clear legal obligation to make environmental recompense for their impacts—so it is vital that a solid, measurable system such as the IMMB be created. The Equator Principals expressly require that projects funded by its many members mitigate or offset their environmental impacts regardless of where they occur. In many cases the Equator Principals cannot be met due to lack of a good mitigation/offset structure. The IMMB system will allow such projects to meet the terms of Equator Principals and bring the projects into compliance, thus resulting in greater political, social and ecological stability.

Can you explain how the International Marine Mitigation Bank (IMMB) works?
We deploy purpose built reefs using reef balls, which are a type of underwater concrete igloo with holes in them. Over 700,000 reef balls have been placed in 70 countries over 30 years, with more than 100 peer-reviewed studies conducted to prove success. The reef balls are perfect as they have a known surface area and can be properly measured for performance, plus they have a large amount of cave area that is needed for fish recruitment.

As time goes on, a third-party verifies the number of tons of biomass on each reef. Each ton of biomass becomes a credit in the IMMB. Biomass includes everything living on or near the reefs balls, including coral, fish, kelp, lobster, scallops, abalone, sponges, octopi, etc. Once a project owner is tasked by a legal controlling authority to mitigate and the impact level is determined, the parties come to terms with how many credits are required to offset the stated impact. The credits are issued via serialized watermarked certificate and sold to the project owner, and signatures are required from all parties on each certificate. Credits can be conditionally transferred if, for some reason, they are never used. Usually, a multiple of the level of biomass that is impacted is created on the positive side of the equation using the IMMB system, so nature comes out ahead. If, for instance, 10 tons of biomass is impacted, typically anywhere from 3 to 10 times the amount of biomass is created using the IMMB.

We share a full 20% of our revenues with the nations that host each reef, so it can be an important revenue stream for many island nations. The IMMB creates hundreds of local jobs, food security for locals, and cultural preservation; attenuates some effects of sea level rise; and provides eco-tourism and study opportunities. The IMMB allows deep sea mining as a vehicle to directly reverse the declining state of coral reefs in many areas and literally shares the wealth, both monetarily and ecologically. For instance, our initial hub will be Papua New Guinea where locals and the ecosystem have been effected by land-based mining over the years. Approximately 85% of the people in Papua New Guinea are subsistence harvesters and ignoring effects of mining (land or deep sea) on their marine protein, such as fish, would not be wise; in the past, violence has occurred as a direct result of environmental destruction without due regard for citizens. More reefs equal more food security, and more food security equals more political stability.

Fish Reef Project has plans to create reefs at the nearest points of land adjacent to Solwara-1, the first deep sea mine to go into operation owned by Nautilus Minerals in Papua Ne Guinea. Our reefs will, in part, offset some of losses to the ecosystem as well as compensate locals who may be affected by the operation. It is in everyone's best interest, including future deep sea miners and the ISA, that Nautilus Minerals takes its mitigation liabilities seriously by supporting the Fish Reef Project and the IMMB system. As of this writing, no formal agreement has yet been made with Nautilus; however, we are moving ahead with the reefs just the same as they will become credits in the bank that can be used for other purposes should Nautilus decline to take ownership of the credits.

 new layout3 01 web

As shown in this example project site layout, the Fish Reef Project approach is quite simple.

How do deep sea mining companies benefit from a marine mitigation bank?
Currently, mitigation is required both in international and national waters in many regions; however, there is usually no good vehicle that can accommodate this requirement, so we allow mitigation to happen that otherwise might not occur. This helps companies comply with the Law of the Sea and national laws and can provide a partial defense in the case of law suites and in the court of public opinion. By using the IMMB system, companies benefit in several ways. The exact locations of mining is commercially sensitive; if they were to mitigate at the area of impact, then the mining locations would likely become public—the IMMB allows offsets to occur far away from the mining area and, thus, protect the exact mining locations. The IMMB (managed by NGO Fish Reef Project) is tasked with defending the offset reefs. Therefore, we defend the work that has been done, thus relieving the company of this obligation. The IMMB can lower political risks that often leads to strife, violence, and operational shut down. The IMMB ensures that developing nations benefit from deep sea mining in terms of both dollars and ecology. When companies self mitigate, generally nobody believes anything good happened—we remove that issue altogether as we can show the public the benefits of our reefs as credible third party. If companies were to try and self mitigate, they can lose valuable operating time and personnel—we streamline the situation by selling pre-made credits that accomplish far more for the ecosystem in the long run than patch work self-mitigation attempts and bring costs way down for industry. We do hope that some deep see remediation also occurs, namely near the hydrothermal vents, however our focus is currently nearshore only.

Where has mitigation banking has succeeded in the past?
Mitigation using a system of credits and purpose built reefs has a long and successful history in the U.S. In the U.S., compensatory mitigation laws are well defined. For instance, Southern California Edison has created marine mitigation credits by building a reef that will soon grow to be over 300 acres. The reef, known as Wheeler North, located off San Clemente, California is there to offset the damage caused by the warm water outfall from the San Onofre Nuclear power plant. The first phase of the reef is amazing with vast kelp growth. Another example: AT&T funded dozens of mitigation reefs in California to offset the impact of laying cable on hard bottom. The AT&T reefs have dramatically increased fish populations in many areas. In addition, the port of Los Angeles has a reef planned as part of it offsets for port expansion. Mitigation reefs exists all along the Eastern seaboard as well—often times, the reefs are very far away from the actual area of impact. It is natural to apply this same logic to deep sea mining.

What role is industry playing in updating rules, regulations, and procedures for deep sea mining?
Currently, the Law of the Sea states that mitigation must take place for impacts to the marine environment. However, it is vague when it comes to specifics. At the ISA, one hears two phrases often: “For the benefit of all humanity” and “Concern for the marine environment.” Fish Reef Project and the IMMB address both of these concerns. The staff at the ISA does a very good job; however, they do not have ample staff to truly deal with the environmental side of deep sea mining. In order to ensure that mitigation occurs for deep sea mining, it is imperative that staff be added to the ISA to oversee and, at times, ratify environmental projects such as the IMMB. I think the industry should lobby the ISA or table a vote to add a few staff members for this purpose and perhaps provide extra funding as such. Already China's state-run deep sea mining entity COMRA is doing their part to try and balance the scales of nature by agreeing to take support the IMMB and Fish Reef Project by agreeing to take ownership of a significant slug of our IMMB mitigation credits. However, COMRA has asked that the ISA oversee the transaction and having additional environmental staff would help facilitate such requests from their members.

What else does your NGO specialize in?
We work to attenuate the massive explosion of purple sea urchins that have created massive barrens in California that reduced bio-diversity. Purple sea urchins exploded after El Niñ o killed off their main predator, the sun star. We work with existing sea urchin fishermen to reduce the numbers of the smaller purple urchins that usually have no market value (the larger red urchins are usually the target species). We donate the purple sea urchins to a company that then creates a unique soil product and dietary supplement so they are not wasted. Also, we are beta testing an eco-cable protection system where we lay specialized reef balls on either side of exposed telecom cables. We then create a proper 5-acre reef a mile or so away to draw fishing pressure away from the cables. The protection system reduces the chances of the valuable cable being cut by anchors and fishing nets while increasing fish abundance; at times, it can be considered a form of mitigation when such liability exists for installing cables. Also the reef balls near the cables create a sonar signature so vessels can easily detect the cables on a simple fish-finder and stay away from them. We have a special unit that provides ready-made mitigation solutions for all manner of marine impact that occur in specifically California waters. We have a strong community outreach and educational arm that works with schools and the community to educate them about the marine ecosystem and our projects.

The IMMB can also be used to offset impacts to the marine ecosystem caused by land-based mining. Mine tailing runoff can cause severe coral reef destruction. In Papua New Guinea, this a real issue that we hope to help with. Our staff project manager in Papua New Guinea , Dr. Wilfred Lus, former head geologist for PETROMIN, is doing a great job getting things off the ground. The IMMB system can also be used for all manner of marine impacts, including those associated with oil and gas. When a territorial dispute exists, such as in East Timor, credits can be bought that brings revenues and reefs to the affected country and can work as a form of strategic compensation to reduce conflicts. For more information, visit International Seabed Authority: www.isa.org.jm and Fish Reef: www.fishreef.org.



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