My submission to the Bureau of Ocean Energy Management's (BOEM) Request for Information and Interest: Commercial Leasing for Outer Continental Shelf Minerals Offshore American Samoa
Submitted originally August 14, 2025. Click here for original submission on BOEM website.
The issue of deep-sea mining in the Pacific ocean waters of my islands isn't just an abstract policy debate for me—it is deeply personal rooted in the need to protect our environment and our way of life.
—Sandra King Young
I'm Sandra King Young. I live in American Samoa and was raised and educated here. My professional background, including time in Washington D.C. and serving as American Samoa's Medicaid Director from 2013-2024 has only deepened my commitment to serving my people and my territory.
The issue of deep-sea mining in the Pacific ocean waters of my islands isn't just an abstract policy debate for me—it is deeply personal rooted in the need to protect our environment and our way of life.
It is with this profound commitment that I strongly oppose Impossible Metals, Inc.'s request for a lease, and indeed any deep-sea mining or exploration, near our pristine Rose, Manu'a, and Swains Islands that are part of the U.S. territory of American Samoa.
Exploration, I believe, will invariably lead to extraction, and the potential consequences are unacceptable. The undeniable truth about mining, whether on land or beneath the sea, is that it is a destructive process that causes permanent environmental damage. As a respected ecologist specializing in deep-sea environments, Andrew Thaler, has stated, "The place where they actually physically mine, I would not expect to see recovery happening within human lifetimes." This irreversible sacrifice to our marine environment is a burden we, as the current generation, cannot responsibly pass on to the future. Our duty is one of responsible stewardship, not reckless exploitation.
The motivation behind these companies' rush to mine the deep sea floor is overwhelmingly financial. Arguments citing energy crises or geopolitical rivalries with nations like China are merely thinly veiled excuses to generate profits for mining companies, their partners, subsidiaries, and shareholders. Any notion that American Samoa will significantly benefit financially from these activities is a specious claim: As a U.S. territory, we do not control our own waters—the U.S. federal government holds jurisdiction over our outer continental shelf, and it is they who lease and sell these seabed areas, and they who will ultimately collect the lion's share of revenues. This creates a situation of unequal bargaining power, leaving us politically powerless to halt these permits, even in the face of widespread local and global opposition. This imbalance of power and the timing of the EO and lease application to BOEM, I fear, renders the entire public comment process deeply suspect.
While these companies may acknowledge some damage to the marine environment, often deeming it "negligible," for Samoan and other Pacific peoples who have navigated and fished these waters for thousands of years, any destruction to our fragile marine ecosystem is unacceptable. The ocean is not merely a resource; it is our home, our identity, and our livelihood. This situation regrettably mirrors a long-standing pattern of exploitation: the strong preying on the weak, the wealthy on the poor, the powerful on the powerless. American Samoa, as a U.S. territory, finds itself in a co-dependent economic relationship with America, with approximately 75% of our budget stemming from federal grants. This dependency severely limits our ability to control our own resources and destinies.
This predicament should compel a critical re-evaluation of American Samoa's political relationship with the United States. If the U.S. federal government disregards our objections to deep-sea mining, perhaps it is time to leverage the U.N. Committee on Decolonization to initiate a process with the U.S. toward true self-governance, allowing us complete control over our economic and natural resources. Federal approval of sea-bed mining exploration and/or leases would reflect a failure to uphold the principles enshrined in the 1900 Deed of Cession, which aimed to protect American Samoa's oceans, lands, and way of life.
Claims by companies like Impossible Metals, suggesting their methods are more environmentally friendly, do not negate the fundamental reality that marine ecosystem damage will still occur. Impossible Metals is a young, venture-capital-funded enterprise driven by the financial opportunities in seabed mining, not by a genuine commitment to preserving our unique marine environment or way of life. This isn't about scientific necessity; it's about the financial value of precious metals and being accountable to investors.
For those of us who call American Samoa and the broader Pacific home, protecting our oceans is paramount to preserving our very existence. Industrialized nations, bearing the largest carbon footprints globally, should shoulder the responsibility for environmental solutions. It is morally unjustifiable to place our marine environment at risk of permanent destruction for the sake of global battery production and corporate profits, especially when we contribute so little to global carbon emissions. Therefore, for all the reasons outlined above, BOEM must unequivocally deny Impossible Metals' lease application for the seabed areas within our EEZ, and indeed, all other applications targeting the American Samoa EEZ.
This urgent issue should serve as a catalyst for a profound conversation within American Samoa about our political relationship with the U.S. The pursuit of true self-governance and control over our historical domains and natural resources is an idea whose time has arrived. The alternative—allowing complacency and apathy to prevail—will inevitably lead to the continued erosion of our culture, heritage, and way of life.
Thank you for the opportunity to comment.
Sandra Salevasa King Young, JD