Responsible Mining and risks

Responsible Mining and risks

Jul 31st, 2019

Responsible Mining and risks is based on a recent article discussing Pebble Mine controversial project and in particular its Draft Environmental Impact Statement (DEIS). 

Responsible Mining and risks

The paper by NRDC Joel Reynold describes Pebble Mine as “Perhaps the most widely condemned development project anywhere”. It also explains that over the past eight years, four major global mining companies have abandoned the project. Namely:

  • Mitsubishi Corporation in 2011,
  • Anglo American in 2013,
  • Rio Tinto in 2014, and finally
  • First Quantum Minerals in 2018.

Severe criticisms by Richard Borden

The paper then describes the severe criticism Richard Borden, a 23-year Rio Tinto mining expert, permitting specialist, and former Head of Environment for its copper, diamonds, and coal divisions, brought forward. These have been formulated in a series of six detailed comment letters criticizing the DEIS. The subject areas include among others:

  • project economics,
  • geotechnical and spill risks,
  • reclamation and closure,
  • alternatives, and finally
  • water management.

Criticisms by Richard Borden generally take the form of qualitative or quantitative objections to statements or values.

For example:

  • “the Pebble DEIS does not even meet industry standard practice” or
  • the mine is not economically feasible, due to negative NPV and closure costs. And also,
  • a certain parameter will be x to y times larger than reported in the DEIS,
  • etc…

Beyond the criticisms and toward Responsible Mining and risks

The paper and Mr. Borden’s letters demand a revision of the DEIS.

We are not going to discuss the various criticisms but focus on the process.

Indeed, we do not believe that re-doing the DEIS will solve the problem.

Instead we would propose to undertake a holistic risk assessment of the project “as is”. That is as described in the DEIS, with the parameters used in the DEIS.

Then a second version of the same risk assessment should be prepared with the parameters proposed by the opponents.

Both risk assessments should be quantitative and use the same corporate and societal tolerance threshold.

At that point it will be possible to clearly see which areas have divergences that require review and would “make-or-break” the project beyond the basic economic viability.

Those analyses should of course include the closure and post closure periods.

As of yesterday (2019-07-30) we have learned that EPA has reversed the Obama-era ‘veto’ and will now focus on the permit review process. Our proposed roadmap would certainly help bring clarity in the risk informed decision making process.

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Category: Consequences, Hazard, Risk analysis, Risk management

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