Høringssvar fra MHWirth AS

Hei,

Vedlagt er høringssvar fra MHWirth AS i forbindelse med forslag til konsekvensutredningsprogram for mineralvirksomhet på norsk kontinentalsokkel.

Under er et samendrag av punktene:

1. The EIA of the pre-opening phase must be a fully transparent process, where everyone – including both, the public as well as the private sector – has access to the collected (raw) data, the results and conclusions derived therefrom, and can participate in the activities in connection with the EIA itself.

2. The commercial exploration phase should, in addition to collect remotely sensed data, allow for drilling and testing key technologies that may be relevant for exploration as well as for future exploitation.

3. It is proposed to follow international exploration codes such as ISBA/16/A/12/Rev.1; in particular Annex 2, §19 (i) regarding the data to be collected and provided to the respective authority.

4. Environment and social aspects should be seen in connection with onshore mining and differentiated by the type of DSM activity and resource. Based on the available information (e.g., see MIDAS research project), we consider eSMS[1] to be the most eco-friendly target for initial DSM due to low or no hydrothermal activities, lower impact on the ecosystem and smaller footprint compared to polymetallic nodule mining.

5. It is seen positive to follow or to use the UN's sustainability goals as a reference in the Hearing Document.

6. Early clarity is needed on the areas that will be opened for commercial exploration and those being protected or excluded from exploitation, to avoid or reduce spending resources on non-mining areas.

7. In general, information is requested on the fiscal regime to assess the pre-feasibility of future projects and to allow decisions to be made before committing to expensive exploration and EIA campaigns.

[1] Referring to Extinct Seafloor Massive Sulphide (eSMS) deposits, including inactive systems or deposits. See research paper of J.W. Jamieson and A. Gartman (2020) for a more elaborated definition.

Med vennlig hilsen

Jens Christian Heffermehl

Project Manager Manager Marine Minerals

MHWirth

Mob: +47 90176133

jens.heffermehl@mhwirth.com | http://www.mhwirth.com

MHWirth AS
Visiting Address: Butangen 20, NO-4639 Kristiansand, Norway
Postal Address: PO Box 413, Lundsiden, NO-4604 Kristiansand, Norway
Registered in Norway, registration no. 942 524 544 VAT