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regulating deep seabed mineral resource development and of encouraging other industrialized countries to join us in that venture. Should we engage in such an action, it would be the functional equivalent of pre-empting the Law of the Sea Conference on this issue. We do not believe that language to the contrary in Section 10a of H.R. 9 would avoid this problem. The international reaction might well be severe and any hope we and many other countries have for creating a stable and rational legal order for the development of ocean mineral resources and other ocean uses could be destroyed.

Some nations

that do not wish to negotiate the substance of their unilateral claims could more easily achieve their objectives while arguing that it is the U.S. that bears full responsibility for disrupting the negotiations.

The U.S. has committed itself to the proposition that the regulations and use of deep ocean mineral resources should be accomplished under an international agreement which in particular would be of benefit to the developing countries. This result would be rendered largely impossible if H. R. 9 were passed and seabed mining commenced pursuant to its terms. The Bill would establish the size of blocks which would be exploited, the length of time the miners could occupy their blocks, the fees which they would pay and the international procedure which would accord them exclusive legal rights. We believe these are the kinds of things which the world needs to establish by international agreement for the future development of seabed resources, and

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which the United States does not need to do today. As I have

previously pointed out, in our view, what the mining industry really needs now is some assurance that their continuing investment will not be jeopardized by a new treaty.

Several of

Putting to one side the fact that H.R. 9 is defective because it would have the effect of establishing a relatively permanent regime for deep sea mining, I may also say that I believe many of its specific provisions are premature. them are similar to ones proposed in the U.S. Draft Convention on the International Seabed Area, and while they were carefully drawn on the basis of the best information available to serve as a starting point for negotiation, we recognize that they are subject to modification in the light of new knowledge and the international negotiations. As yet, provisions such as those relating to subsurface mining, block size and length of tenure, and work requirements and their magnitude have been little discusse by the U.N. Seabeds Committee because attention has focused on larger issues. Hence, we have little feel for the negotiability of such terms to other nations in the light of their own knowledge of the seabed and their own convictions with respect to a minerals allocation and management system. To adopt such terms i advance of such discussions might well prejudice our negotiating position and lead to later adoption of a much different system that would be difficult for us to adjust to or accept.

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During the past year we have redoubled our efforts to gather as comprehensive a data base as possible in order

to assure that the specific provisions which will ultimately emerge at the U.N. Law of the Sea Conference regarding the resource management system will be sound from a resource management perspective. We must bear in mind that deep sea mining is very much a new and untried industry and several years of development of seabed resources will be required before definitive decisions can be made with respect to all of the details of a licensing system. Nevertheless, the information we expect to obtain in the very near future is likely to give us a fairly firm idea of the kinds of detailed provisions which will be necessary to assure the resource manager's ob

jectives.

At the present time, however, we would not be prepared to finalize the specific arrangements which we think should be applicable to seabed mining. In short, we not only believe that provisions like those in H.R. 9 would tend to prejudice the detailed licensing system we wish to negotiate in the Law of the Sea Conference, but are also premature for now.

In order to make clear the detail and

complexity of the decisions which a resource manager must make, I would like to set forth a few examples of areas in which further information would be useful.

First, Section 2 (c) taken together with Section 4 (a),

would cause

the Secretary of the Interior to issue licenses

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for subsurface blocks of a specific size.

Provided certain

minimum annual expenditures were met, the legal rights granted pursuant to such licenses would be valid as long as commercial recovery occurred in that block. If it does not occur within 15 years the licensee would simply have occupied that block for 15 years and all other persons subject to the jurisdiction of the U.S. would have been precluded from doing so. We have .concentrated our efforts so far on acquiring maximum

information about manganese nodule deposits rather than on subsurface mineral deposits because only the former seem to be economically attractive enough for early exploitation. Accordingly, we would be most reluctant at this time to formulate final conclusions about the size of a block, the length of time needed to develop the block, the work requirements, and the environmental safeguards. Based on our current knowledge of subsurface mineral resources, the fees and royalities which the Government would no doubt require would bear no reasonable relationship to the resource potential or the technology needed to mine the area.

Section 2 (c), taken together with other sections of the Bill, would establish that surface blocks should be 40,000 square kilometers and that these should be reduced to 10,000 square kilometers not later than the commencement of commercial recovery or 10 years, whichever occurs first. What this means is that deep sea miners under H. R. 9 would have 10 years to explore a 40,000 square kilometer block and the right to exploit the

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resources of a 10,000 square kilometer area for as long as they wish, provided minerals are recovered at a substantial rate of production for the primary purpose of marketing or commercial use. I should point out, Mr. Chairman, that the U.S. draft seabeds treaty presented to the U.N. used the same figures. We used those figures, however, for the sake of discussion and have continued to study new information regarding the technology of

deep sea mining.

Determination of a proper block size and the number of blocks of any given size which would be awarded to a single company is a complex decision.

Without going into great detail, it may be useful for the Committee to be aware of some of the variables which enter into such a determination.

One should know much about the

ore concentration and ore grade and its geographic and geological distribution, the efficiency of the mining recovery system, particularly the actual collection device, and the efficiency with which that device can sweep the bottom. All of these factors are directly related to the amount of production which a particular company wishes to achieve, that is, for reasons of either economy or size of production plant, companies may wish to produce anywhere from 1 to 3 million or more tons of nodules per year. We have been gathering a considerable amount of information pertaining to these factors. There is at this stage no reason to change our earlier view that block sizes should be in the neighborhood of 40,000

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