Response to “Cautionary Tales for Science‐Based Policy in Deep‐Sea Mining Governance”

ABSTRACT

The policy analysis article “Cautionary Tales for Science‐Based Policy in Deep‐Sea Mining Governance” by Villar‐Muñoz (2026), https://doi.org/10.1111/1758‐5899.70185 , addresses what the author perceives as “low‐certainty claims” in the context of deep‐sea mining and contrasts them with perceived “realistic scenarios” to argue that additional guiding principles were needed to distinguish between uncertain hypotheses and established evidence for better informed political decisions. Our publication was chosen as one of the “low certainty” examples to support this claim. Here, I address several misrepresentations of our findings that, when rectified, seriously affect the validity of the conclusions of Villar‐Muñoz. Our peer‐reviewed finding that deep‐sea polymetallic nodule material is comparably radioactive as several materials commonly classified as “naturally occurring radioactive material” (NORM) was based on decades of analyses, direct comparisons, and written by trained experts in the field. The chronology reveals that the “realistic scenario” was not a contrasting result, but a consequence and a confirmation of our independently funded and publicly accessible research. Prior decades of investigations guided by economic interests had failed to report the requirement of active radiation management during polymetallic nodule handling. Consequently, the precautionary principle would suggest maintaining independent routes of research and open communication of scientific findings because they are the only proven way to arrive at “realistic scenarios”.