#39 When the Numbers Don't Add Up: Steven Emerman's Independent Assessment of the Metals Company Pre-Feasibility Study

Steven Emerman, owner of Malach Consulting and a former Princeton and Cornell-trained geophysicist, brings an unusual perspective to deep sea mining. He came to it from decades of evaluating mining disclosures across the terrestrial mining industry. Commissioned by the Deep Sea Mining Campaign, Greenpeace International, and Mining Watch Canada, Emerman reviewed The Metals Company’s pre-feasibility study not as an ecological or policy document, but strictly as a financial and regulatory one. His conclusion: even under the company’s most optimistic assumptions — best-case metal prices, a below-standard discount rate, and a novel category of “recoverable resources” not recognized under SEC regulations — the project’s own numbers show it terminating at the end of year seven with zero profit.

What makes this conversation particularly valuable for listeners tracking the commercial viability debate is Emerman’s grounding in mining industry norms. He walks through why the distinction between reserves and resources matters so much to investors, why the zero-tailings claim reflects a fundamental misunderstanding of ore processing chemistry, and why the assumed smelting and refining capacity in Indonesia involves layers of speculation that the PFS doesn’t adequately address. He’s careful to distinguish what the document does and doesn’t disclose and what it’s required to disclose under SEC regulations. His full report is available publicly and is referenced throughout this episode.

* Emerman’s Report: Implications of the Metals Company Pre-Feasibility Study for Next Steps by the Company https://dsm-campaign.org/wp-content/uploads/2026/03/Implications-of-The-Metals-Company-Pre-Feasibility-Study-for-Next-Steps-by-the-Company.pdf

Chapters

00:00 – Introduction and context for the conversation01:03 – Who is Steven Emmerman? Background and consulting work04:14 – Previous involvement in deep-sea mining discussions05:20 – How this report came about06:33 – What “independence” means in consulting08:12 – Handling client pressure and report revisions11:02 – Personal views vs scope of the report12:32 – Podcast framing and approach to the discussion15:49 – What is a pre-feasibility study (PFS)?16:24 – The stage-gate process in mining projects18:23 – Internal vs public role of PFS documents20:00 – Regulation and the role of independent experts23:36 – What is a “qualified person”?25:42 – Key conclusion: should the project proceed?26:11 – How this compares to typical PFS evaluations

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