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Strategic Environmental Assessments in Mining

There appears to be an increase in SEAs relating to the extractive/mining sector, including the Central Namib Uranium Rush study, which caught my eye.

Shortlink: http://wp.me/p27qSt-cL

Therivel et. al.’s  textbook entitled Strategic environmental assessment (first published in 1992) defines SEAs “as the formalized, systematic and comprehensive process of evaluating the environmental impacts of a policy, plan or progamme and its alternatives”. Note the absence of the term “project” for which the predictive planning tool of choice would be an environmental and social impact assessment or ESIA. The textbook also describes one role of SEAs “as a way of ‘trickling down’ the objective of sustainability”. This suggests that an SEA should be carried out ‘upstream’ to enable ‘a sustainability trickle down effect’ and provide a decision making framework that can be used for project related decision making, including ESIAs.

One SEA which caught my attention is a recent study completed in 2011 for the ‘Central Namib Uranium Rush’. It describes itself as the first ever SEA for a mineral province. However, it also notes that this “SEA differs from most others conducted elsewhere because the development in question is neither a policy, plan nor programme, but rather a collection of projects, each being conducted by individual companies that are not related to each other, and in many cases, undertaken in isolation of each other”. This made me wonder if the Namib SEA could also have been called a (Strategic) Cumulative Assessment. Also, this SEA arrived perhaps a bit late to the party. It seems that many key decisions have already been taken in advance of the SEAs.

As apparently characteristic for SEA studies, the Central Namib Uranium Rush study was also financed by a donor. In this case, Germany, through the Bundesanstalt für Geowissenschaften und Rohstoffe (BGR which is Germany’s Federal Institute for Geosciences and Natural Resources), appears to have provided the funding for the SEA study.

According to a summary presentation by Dr Rainer Ellmies about the Central Namib Uranium Rush SEA study, the direct cost of the SEA were US$1 million and the study took 1.5 years to complete. But this does not seem to provide the full context at least not in terms of time scale which seems typical of SEAs. As the Namib SEA report indicates, the “necessity” for this study was “recognized” (?) in 2007, a main contractor  was selected in 2009, presumably after a terms of reference was developed and agreed by the key decision makers (and purse string holders), and the final report was published in January 2011. A more ‘inclusive’ approach puts the time frame for the Namib SEA at about 4 years.

A (brief and incomplete) review of the study left some of the following impressions with me - and I would like to invite you to share yours.

The extensive stakeholder engagement process used for this SEA is remarkable and deserve commendation (see Appendix B of the SEA study). This effort included a dedicated one-day workshop with approximately 50 youth.

Other aspects appear somewhat more ‘generic’ in nature. Not sure if you need a $1million SEA to recognize that there is/will be shortages relating to water, power, infrastructure, and skilled workforce to develop large scale projects in an underdeveloped region that characterizes the Erongo study area. These bottlenecks exist with or without any Uranium or any other sort of rush. Similarly, issues such as land use and regional economy, health, radiation and safety, environment, heritage, mine closure and post-mining land uses are important issues to the sector/region – and the SEA is not uncovering any unique insights here.

However, pulling the data and issues together, incorporating engagement and consultation, identifying key bottlenecks and putting this in front of decision makers and the wider public is an outcome which is worth every penny!

So, for example, I can see how forecasting the water needs of the uranium mining sector from about 7 million cubic meters per year (Mm3/a) in 2008 to 48-64 Mm3/a in 2015 and putting this into a context of nationwide water supply in Namibia (67 Mm3/a) can be illuminating. Or that quadrupling of energy demand by 2015 for the regional Uranium sector alone deserve some thinking and planning (not least as a serious project risk for investors). Not to mention the lack of capacity of the government to deal with permitting/approval and monitoring without a much needed scaling up in capacity that is proposed with concrete suggestions in the SEA report.

The Namib SEA concludes that the Uranium Rush presents significant opportunities in terms of growth and development, and highlights some of the risks/trade-offs. Examples of trade-offs include that some of the activities related to the Uranium Rush are located in a proclaimed national park, one of the most popular tourist hot-spots in the country. And there are the usual uranium mining/life cycle risks to consider.

It also seems that the private sector developers have been doing their own forecasting, risk assessments and are developing their own solutions - such as  building water desalination plants and back-up power generation capabilities – or may choose to delay investments or invest elsewhere altogether. At the time of the SEA, four uranium mining licenses had been granted: two mines were operational (one already for several decades), the third was undertaking trial mining, and the fourth was beginning construction. The operating mines are Rio Tinto’s Rössing – which also produces an impressive site sustainability report that underlines its CSR leadership position and serious efforst to support capacity building - and Paladin ResourcesLanger Heinrich. Two mines under construction comprise AREVA ResourcesTrekkopje and Forsys Metals’ Valencia. And two further uranium mining projects are still in development stage (Bannerman’s Etango project, formerly known as Goanikontes, and Extract Resources’ Rössing South or Husab project).

According to the SEA, the Erongo Region has no coherent development vision and the Namibian government readily embraces a wide range of development proposals without necessarily assessing their implications at a strategic level. The study also proposes ways that the operators in the industry can collaborate to achieve a common approach towards long term management and monitoring. So while some of the proverbial horses may have bolted from the stable before the SEA was initiated/completed, there is still an opportunity for the Namib SEA to create positive impacts by transparently informing current and future developments and decision making.

What did you like/dislike about the Namib SEA or other extractive SEA examples you have come across?

About the author: Mehrdad Nazari (MBA, MSc, LEAD Fellow) is a Corporate Responsibility, Sustainability Reporting & ESIA Advisor, and Director of Prizma. He was previously an environmental consultant with Dames & Moore, Principal Environmental Specialist at the EBRD and CSR Research Director at CoreRatings. Mehrdad is also a GRI-approved trainer on GRI's sustainability reporting framework and a licensed AA1000 Assurance Provider.

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8 Responses to “Strategic Environmental Assessments in Mining”

  1. August 1st, 2011 at 1:07 pm

    Fernando Loayza says:

    Congratulations for setting up this blog on SEA in the mining sector. I would like to call the attention of your readers to the work on SEAs in mining at the World Bank. In the World Bank’s SEA pilot program three pilots (West Africa Minerals Sector Strategic Assessment; Sierra Leone Mining Sector Reform. A Strategic Environmental and Social Assessment and the Rapid SEA of Malawi’s Minerals Sector)were undertaken. Also, the Bank’s mining department (SEGOM) has assisted client countries in undertaking SEA in countries such as Cameroun, Mauritania, Pakistan, etc. SEA has become an tool of preference in environmental assessments of mining technical assistance projects

    The reports of the mining SEA pilots can be found and downloaded from this link:

    http://go.worldbank.org/P29R8UOZH0

    A short guidance note on applying SEA in mining sector reform has been also produced by the World Bank. The link is the following: http://siteresources.worldbank.org/INTRANETENVIRONMENT/Resources/ENVNoteno4.pdf

    Let’s keep this exchange of information and ideas on SEA as a sustainable development tool for the mining sector.

  2. August 13th, 2011 at 2:34 am

    Mania Lamprou says:

    Two points here as a first -not in deep- study of the post.
    SEA is not EIA, has a basic difference in scale, so when we define the thre p’s (plan, project, procedure) it is nessecery to know what this is about. The current study is about everything since it includes also the management of natural recourses.
    The second one is about the thinking process on the way to decision. A good analysis, even the data are not enough but still good, has to include a double entrance matrix. you can check about it on IAIA in Prague http://www.iaia.org/specialmeetings/prague11/
    I have to study more on this post and come back to you more precise. Thanks.

  3. August 13th, 2011 at 6:53 am

    Mehrdad Nazari says:

    Many thanks Fernando and Mania for your comments and links to other SEA materials. – Mania, I look forward to your additional comments in due course.

  4. August 31st, 2011 at 7:59 am

    Mehrdad says:

    The International Association for Impact Assessment (IAIA) has organized a conference on Strategic Environmental Assessment entitled SEA Implementation and Practice: Making an Impact? The event will be held from 21 – 23 September 2011 in Prague. For further detail, please visit the conference website.

  5. December 1st, 2012 at 6:52 pm

    Mehrdad says:

    Miguel Bisnar posted this note on LinkedIn:

    The UNEP published in 2004 “Environmental Impact Assessment and Strategic Environmental Assessment – Towards An Integrated Approach” which could be found at its website and also a Manual on Environmental Impact Assessment. These are good guidance documents if properly interpreted and implemented. The Philippines was one of the pioneer countries who subscribed to the concept of EIAs.In the 1970’s, its Philippine Nuclear Power Plant underwent a series of environmental studies although there was no formal public hearing (it was under Martial Law). But the process was conducted by the regulatory agencies (I was one of the regulatory representative) without any short-cuts. The study also included risk assessment (normally done for US nuclear power plants).

    SEA is a good tool and should be part of the long term program of any country or government and which should be shared by neighboring countries for a harmonious development and competition for resources. Difficulties always arises when countries have common boundaries and need for resources. Classic examples are Spain (water) and the Nile River and now the South China Sea.

    When leaders and politics change, the previous agreements and plans are set aside. That is why we have a chaotic world of conflict. If only the United Nations can exert its role as a governing body, then probably these conflicts, social injustices including war can be avoided.

  6. February 5th, 2013 at 5:18 pm

    IFC’s Draft Cumulative Impact Assessment Guidance out for Comments | PRIZMA says:

    [...] response and covenanting – or even PR – strategy (however effective that may be). But would a Strategic Impact Assessment further ‘upstream’ not be a more powerful approach to help with broader and more transparent [...]

  7. July 19th, 2013 at 8:02 am

    Mehrdad Nazari says:

    The Swedish International Development Cooperation Agency (Sida) is sponsoring the Advanced International Training Programme on Strategic Environmental Assessment. Civil servants, SEA practitioners and strategic planners and decision makers in the following countries in Africa are eligible to apply: Ethiopia, Kenya, Mali, Mozambique, Rwanda, Tanzania, Uganda and Zambia. The program runs from December 2013 to May 2015. The application and more information can be found here

    http://www.niras.com/Business-Areas/Development-Consulting/International-Training-Programmes/Strategic-Environmental-Assessment-2014.aspx

    The application deadline is 30 September 2013.

  8. September 30th, 2014 at 6:55 am

    IDB hosts Wind Power Challenges & Solutions Seminar | PRIZMA says:

    […] of multilateral and development banks, tools such as strategic environmental assessments (see here) or cumulative impact assessments (see here) were apparently not utilized to support Mexican […]

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