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.

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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.