Comment from Cashman Dredging & Marine Contracting

Cashman Dredging & Marine Contracting Co., LLC (CDMC) supports BOEM’s evaluation of potential Outer Continental Shelf mineral development offshore Virginia and other viable regions. We recognize the concerns raised regarding seafloor habitat, sediment disturbance, fisheries, protected species, and coastal industries. These concerns require serious, site-specific study, but they should not prematurely lead to the conclusion that all seabed dredging, or mineral recovery is inherently unacceptable. Marine dredging and sediment removal have been performed for centuries for navigation, coastal restoration, beach nourishment, and environmental remediation. The Industry has developed precise positioning systems, controlled excavation and material-handling methods, environmental monitoring programs, and operating restrictions designed to minimize impacts. CDMC has applied these capabilities on highly regulated remediation projects, including the Upper Hudson River PCB cleanup and work associated with the Gowanus Canal cleanup, where complex sediment-removal activities were performed under stringent environmental requirements. Responsible development of domestic mineral resources could strengthen the nation’s economic resilience and national security. Critical minerals, including rare earth elements, are essential to advanced defense systems, aerospace equipment, semiconductors, telecommunications, energy infrastructure, and modern manufacturing. The United States remains dependent on foreign sources for many of these materials, and the evaluation of domestic resources can help diversify supply chains, reduce exposure to geopolitical and trade disruptions, support American manufacturing, and create maritime jobs. Cashman supports BOEM’s continued evaluation of the RFI Area through a practical, phased, and site-specific process that recognizes the proven capabilities of the U.S. offshore energy and marine construction industries. That process should include appropriate coordination with fisheries and other ocean users, use of established industry practices, and environmental safeguards proportionate to the scale and risks of each proposed activity. While not every location or proposal will be suitable, decades of offshore oil and gas development demonstrate that experienced American operators, contractors, and mariners can conduct complex offshore activities responsibly and efficiently under a well-established regulatory framework. Applying that experience to offshore mineral recovery could support American maritime jobs, strengthen domestic mineral supply chains, enhance national and economic security, and generate meaningful benefits for coastal communities and the broader U.S. economy.