NORI Collector Test Environmental Impact Statement


NORI Collector Test Study - Environmental Impact Statement

This is a copy of the final Environmental Impact Statement submitted by Nauru Ocean Resources Inc (NORI) to the International Seabed Authority (ISA) to support their request to test a 1/5th scale collector, riser-air lift system and nodule separator (plus all other associated deep sea mining equipment) in the Clarion-Clipperton Zone.

This EIS was subsequently accepted by the ISA and NORI (Allsea and The Metals Company) proceeeded with the test.


This Environmental Impact Statement outlines the anticipated impact that a 1/5th scale test of Allsea's polymetallic nodule collector will have on the environment in the Clarion-Clipperton Zone.

This document is important because NORI needs to test the collector in real life in order to see the impact that it has. This is a test, and whilst scientific research, engineering and modelling indicate that the impact on the environment is likely to be low or minimal, a real-life test is nonetheless required to confirm these. Test have the potential to go wrong, and this document outlines that potential, the possible impacts, and the mitigating measures that have been put in place.

The conclusion is that the collector test is a fundamental component of a deep sea mining operation, that the testing is required, that the risk is low, and that all mitigating measures have been put in place to reduce risk to the environment.

The result of this EIS was that NORI / Allseas / The Metals Company proceeded with the collector test in late 2022.

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On July 29th, 2021, Nauru Ocean Resources Inc (NORI) submitted its Collector Test Study Environmental Impact Statement (EIS) to the Secretary General of the ISA for initial review. The document was simultaneously released for public stakeholder review and comment. This updated EIS considers reviewers' comments and incorporates further information that has become available during the interim. In particular, the inclusion and assessment of additional baseline data from completed offshore campaigns which adheres to an established environmental impact assessment (EIA) process of impact identification, significance analysis and risk assessment. This represents a significant advancement in the development of a robust environmental impact statement (EIS) framework for deep sea mining projects.

The inclusion of a Collector Test into the commercial EIA process provides the opportunity to assess the technical performance of the prototype collector system and its potential environmental impacts in the mining lease area which is proposed at a scale and duration of activities that is sufficient to meet the study objectives but of insufficient magnitude to incur any serious harm to the marine environment. As such, the Collector Test is essentially an experiment dedicated to test and refine the technical performance of the equipment and provide empirical (in-situ) environmental monitoring data during and after the test, which is essential to inform impact predictions and to apply best mitigation practices to a full-scale commercial system.

If there were to be no opportunity to carry out the Collector Test, or if it were to be undertaken in un-representative, shallow or nearshore environments, the information collected would be considered of limited application to the actual physicochemical and ecological conditions prevalent in the CCZ. Furthermore, without the Collector Test, there is little other analogous information available at the current developmental stage of deep-sea polymetallic nodule mining. The Collector Test therefore represents a critical component of NORI's studies, as it provides the observations and measurements of the performance and impacts to the seabed and water column that could not be acquired by any other means.

Mining projects in national jurisdictions do not typically include a full (separate) EIS for component testing of equipment or environmental studies because much understanding of the characteristic sources, pathways and impacts of disturbances and emissions already exists from the long history of terrestrial mining activities. In a typical terrestrial EIS, the individual technical studies that make up and support the sequence of environmental investigations and impact assessment steps are incorporated as appendices to the overall commercial EIS, but not as a separate EIS.

The focus of an EIA is to identify significant impacts that have the potential to cause serious harm to the receiving environment - not to mitigate all impacts to zero, as this is both an impossibility and undesirable when the objective of the test is to characterise impacts at a non-commercial scale. The EIS presents the regulator with a description of the residual impacts to the environment that are predicted to remain after all appropriate management and mitigation measures have been applied. Ultimately, the regulator determines whether approval of the project (and hence acceptance of its residual impacts and the associated risks) is justified by the overall benefits to global communities. If a project is approved, the regulator will require comprehensive monitoring to ensure actual impacts do not exceed those predicted and may impose additional requirements such as the need for further environmental studies as a condition of approval.

The requirement for a prior environmental impact assessment and an environmental monitoring programme to be carried out during and after the specific (collector) activity during exploration is given in ISBA /25/LTC/6/Rev.1 (2019) “Recommendations for the guidance of contractors for the assessment of the possible environmental impacts arising from exploration for marine minerals in the Area”, specifically Section VI. B. (Paragraphs 33[a-g] and 34). The recommended scopes of work are listed in Section VI.


Nauru Ocean Resources Inc. (NORI) plans to carry out testing of a polymetallic nodule collector system (the Collector Test) in the NORI-D lease area (NORI-D) of the eastern Clarion Clipperton Zone (CCZ), Central Pacific Ocean. NORI has commenced an Environmental and Social Impact Assessment (ESIA) in support of an application to the International Seabed Authority (ISA) for a contract to commercially collect deep-sea polymetallic nodules. Testing of a prototype collector vehicle (PCV) and riser system is a pivotal component of the overarching commercial ESIA. The ISA recommends a dedicated assessment of the technical and environmental performance of the prototype system, which is one fifth of the proposed commercial scale.

The Collector Test Environmental Impact Statement (EIS) must be submitted to the Secretary-General of the ISA no later than one year in advance of the activity taking place. The current schedule has the NORI-D Collector Test EIS being submitted Q3/2021 and the test being conducted in Q3/2022, with the overarching commercial EIS to be submitted Q2/Q3 2023.

The Collector Test will take place in international waters and will adhere to the latest recommendations of the ISA (paragraph 38 and Annex III in ISBA/25/LTC/6/Rev.1; 30 March 2020), the governing body that organises, regulates, and controls all mineral-related activities in international waters beyond the limits of national jurisdiction (referred to as “The Area”). This recommendation defines the activities that require an EIA, the form and content of the EIS, and guidance on expectations for baseline studies, monitoring and reporting.

Conclusion & Recommendation

The Collector Test is an essential component of the commercial ESIA. It is necessary to demonstrate the technical, economic, and environmental feasibility of operations proposed for the commercial phase of the project. The Collector Test is an opportunity to demonstrate the feasibility of the nodule collector system and test any assumptions made during its design.

The information presented in this EIS supports the finding that the proposed mitigation measures, additional project specific controls and small scale of the test program sufficiently minimise all physicochemical, biological, and cumulative impacts to non-significant levels. In the absence of significant residual impacts, the risk of the Collector Test resulting in 'serious harm' to the marine environment at a regional scale, is 'Low'.

The Collector Test should proceed under the conditions described in this EIS which will be operationalised in the Environmental Monitoring and Management Plan to be submitted to the ISA prior to mobilization. The learnings from the information gathered during testing should be reflected in the findings of the commercial EIS and applied to the design and operations of the full-scale system to reduce uncertainty and minimise environmental impacts during commercial operations.

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Phillip Gales is a serial entrepreneur who has built tech companies in various heavy industries including Oil & Gas, Construction, Real Estate and Supply Chain Logistics. Originally from the UK, he now lives in Toronto, Canada, with his wife and young family.

Phillip holds an MBA from Harvard Business School, and an MEng in Electrical Engineering from the University of Cambridge, specialising in Machine Intelligence.