Key points
- TMC USA and partner Mariana Minerals are planning a Brownsville nodule processing and refining facility that depends on USG funding support.
- Barron said TMC’s consolidated USA-A application is the first filed under new NOAA rules adopted in January 2026.
- Public comments on the USA-A consolidated application are open through October 19, 2026, and a virtual public hearing was held on October 13.
- TMC’s tolling arrangement with Japan’s PAMCO remains available as a capital-light option for processing nodules.
Gerard Barron, Chairman and CEO of TMC the metals company Inc., published the following letter to shareholders on LinkedIn on October 13, 2026.
Many TMC investors have questions about USG funding for the Brownsville plant, the USA-A certification and the USA-B lawsuit.
Some speculate if these issues can explain the falling stock price. I personally believe the decline is not based on anything fundamental, and we have seen periods like this over the years where negativity can feed on itself. While I don’t have tangible news to share just yet, I can offer some color on why I remain very confident.
USG funding for the Brownsville plant: TMC USA, together with our partner Mariana Minerals, are committed to building a domestic nodule processing and refining facility in the United States, but with one caveat. It has to be in the best interests of our shareholders. The PFS/FS studies for staged construction are well under way, with a talented and motivated team working hard on the Brownsville project. But at the end of the day, the capital requirement is substantial and USG support is a prerequisite. Engagements with multiple U.S. agencies continue. The process is taking longer than we expected, but we aren’t the only priority for these Government agencies, and it’s evident that these agencies remain fully committed to resolving America’s critical minerals shortages, and seafloor nodules remain a vital part of that solution. As CEO (and a substantial shareholder), my number one fiduciary duty is to the shareholders, and it is my job to minimize dilution as we build what could become a new American mining major. Access to capital matters, but so do deal terms. While these USG engagements are in progress, we do not intend to pursue other capital markets transactions. Our cash position remains robust.
Japan remains open to us: As I made clear at our last earnings call, the capital-light option of sending nodules to Japan for processing on a tolling basis remains available to us. Our working relationship with PAMCO remains excellent, and this option provides us with maximum flexibility as we work towards first production.

USA-A certification: Many of you expected certification in June based on the 100-day certification process envisioned in the DSHMRA statute. What we need to appreciate is that our consolidated application is the first of its kind under the new rules just adopted by NOAA in January this year. Getting the details right matters, even when it takes time. We remain in regular communication with NOAA and remain very optimistic about continued progress toward certification.
USA-B litigation: Most mining permits in the United States are challenged by environmental NGOs; that’s simply part of doing business here. We anticipated legal challenges and are prepared. In our view, the lawsuit against NOAA mischaracterizes the process. NOAA has not “greenlit” exploration—it certified our application to advance to further review. The process was thorough. Public comment has taken place, and environmental review is underway. A complaint is not a court ruling, and this case does not impact the USA-A application.
Your voice matters, too. Public comments on the USA-A consolidated application are open through October 19, with a virtual hearing today. I encourage you to read the materials and participate.
My confidence remains strong. I’m invested alongside you—and focused on disciplined funding and delivering a critical minerals project at scale.
Gerard