EIA Delay Update

Hi Guys,
I have been actively supportive in this forum. I have always tried to be honest no matter how tempting it is to obscure information to support my own interests.
I have now however decided to sell down my holdings in GGG.
I have done so not because I don’t see promise in the project. I am just not prepared to wait for as long as I now suspect it may take to get the project up and running as the market can be brutal when it waits. Especially too as the approvals have dragged on for so long already and it seems it may be a lot longer still based on the below feedback direct from the Head of the ERMRA (Greenlands Environmental Ageny for the Minerals Resources Act) who process the EIA.

The drafts inadequacy appears  quite substantial and  the timeframes suggested below and amount of studies yet to be completed concerning.

I am a bit dissapointed to discover this to be honest as the company has had ample time to submit a full application. However I will keep researching the project and  will reinvest again  once I am given considerable further reassurance that advancements are actually going to occur.


"When the EIA-report is drafted it must live up to the requirements of the EIA-guidelines, before the authorities can accept the draft for public consultation. One of the requirements is, that the citizens of Greenland shall be able to read the material in english, greenlandic and danish. A non-technical summary of the material in comprehensive language shall be included. In addition there are a number of content requirements.

The general purpose is, that the material presented to citizens shall be comprehensive and complete in accordance with the Mineral Resources Act and Government of Greenland guidelines.

The current materials and drafts do not live up to these at this point in time. The requirements are:

“
- The EIA shall identify, predict, describe, assess and communicate potential environmental impacts of a proposed mining project in all its phases including exploration, construction, operation, closure and after closure
- The EIA shall cover the entire area that may be affected by the project. If the project includes areas outside the mining area, for instance roads, harbours, pipelines, airstrips and shipping routes, effects of these shall be covered as well
- The EIA shall present measures to address and mitigate the identified impacts
- The EIA shall include all aspects in relation to nature, wildlife and public health regarding exposure to hazardous substances
- The EIA report shall be prepared not later than when a company decides to apply for an exploitation license for a mineral deposit
- The MRA may require the EIA updated if, among others, processes, area and activities are changed
- The EIA report shall be based on environment baseline studies typically covering 2-3 years before the area will be affected by activities and construction.”

(Guidelines for preparing an Environmental Impact Assessment (EIA) report for mineral exploitation in Greenland, Mineral Resources Authority 2015, page 5).

The guidelines are publically available on www.naal.gl in Greenlandic and Danish here: https://naalakkersuisut.gl/da/Naala...ur-Miljoe/Miljoestyrelsen-for-Raastofomraadet.

The guidelines are available in english at www.govmin.gl

Verification that all EIA requirements are in accordance with the guidelines, is performed by the scientific advisors of the Environmental Agency for Mineral Resource Activities, Greenland Institute of Natural Resources and Danish Centre for Environment and Energy at Aarhus University.
A group of experts evaluate whether the drafts for the EIA are in accordance with the Mineral Resources Act and the Guidelines. If the evaluation concludes that aspects are missing or inadequate, the authority can, in accordance with The Mineral Resources Act §74, pt. 2, decide that additional material for the EIA must be provided, or that the EIA responsible party must make additional further studies or assessments of specific conditions of importance to the EIA.
At the current juncture, the draft EIA is not in accordance with the language version requirements nor with the content requirements. The EAMRA has provided feedback on this to the applicant company, who is responsible for the EIA."