In response, the Bureau of Ocean Energy Management (BOEM) has issued Requests for Information (RFIs) on mineral leasing processes for the Outer Continental Shelf of American Samoa and the Commonwealth of the Northern Mariana Islands (CNMI). RFIs are the first step when BOEM receives a commercial request for leasing. BOEM also announced in December that it had initiated a review for a potential mineral lease off the coast of Virginia, sparked by an unsolicited request from a potential lessee.
The June 2025 RFI for offshore American Samoa received 76,443 submissions. BOEM’s record of public comments received states that “several commenters remarked that the ocean is not only a resource but a fundamental part of Samoan identity…a living entity that connects Samoans across generations and islands.” BOEM received more than 65,000 comments on the RFI from the Marinas Islands announcement when the extended period closed in January. It is reasonable to assume that any leasing activities going forward will take place under a high level of visibility and expectation of accountability from stakeholders.
Critical Decisions Pending
Currently, BOEM has now completed area identifications for potential critical mineral leasing for both American Samoa and CNMI. In all its public documents, BOEM concedes there is still much analysis to take place before a lease sale occurs.
As these processes move forward, BOEM is well-positioned to draw on its experience and established practices to ensure consideration of cultural resources and consultation with local sover-eignties and communities are embedded in mining operation planning.
Success depends on industry’s willingness to also commit to best practices that proactively invest in cultural resources. At this early stage, industry should thoughtfully consider how it can move beyond simply “checking the box” in terms of compliance and forge meaningful partnerships with impacted communities to address cultural resourcerelated concerns. Therefore, we offer these actionable recommendations:
Integrate Indigenous Insights
Incorporating Tribal nation input early in the process, especially in the case of BOEM’s consultation for the Gulf of Maine wind energy areas, allowed the agency to identify areas to avoid and significant areas of concern that would need to be mitigated upon lease issuance. In addition, throughout the leasing and permitting processes conducted for offshore wind in the Atlantic, Tribal nations emphasized their knowledge of marine habitats and site conditions, such as the prevalence of glauconite, a material that proved to be challenging for developers during construction. While agencies have policies and practices that emphasize the incorporation of indigenous knowledge, industry can enhance and complement those efforts in its surveying and planning.
Encourage Local Capacity Building
Permitting processes for critical mineral operations will likely be accelerated. A common complaint heard during offshore wind permitting is that Tribal nations lack the necessary resources to review government documents and conduct consultation associated with impacts to cultural resources. Early planning should consider the need for resources to provide indigenous people with the opportunity to develop and hire their own experts.
Consider Cultural Resources
The novelty of deep-sea mining suggests the need for new processes to assess cultural resource-related impacts. Nevertheless, industry should study lessons learned from offshore energy activities and build thoughtful, deliberate consideration of cultural resources into its operational plans.
The success of the deep-sea mining industry will depend on its willingness to commit to best practices that proactively invest in cultural resources—establishing social license among stakeholders and, consequently, enabling future growth. searchinc.com
