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    The Nature Conservation Society, an activist non-profit organisation have shared their closing statement. Interesting to note just how flimsy their arguments are. Keep in mind, Talga would have presented a mountain of evidence re: water quality control etc. against this emotional rubbish. Their argument about the future expansions are pointless, the permit isn't for the future expansions and they will have their own individual hearings.

    Forgive the formatting, if I corrected it Hotcopper would cause problems and remove spaces for some words.

    https://norrbotten.naturskyddsforeningen.se/slutligt-anforande-om-planerade-grafitgruvan-i-nunasvaara/

    "Final speech on the planned graphite mine in Nunasvaara

    The Naturskyddsföreningen in Norrbotten's final statement regarding the plans for a graphite mine in Nunasvaara is submitted during the court proceedings on February 21, 2023.

    You can read more about the negotiations and our commitment to the mining plans here:
    https://norrbotten.naturskyddsforeningen.se/nunasvaara-rattegangen-har-borjat-om-den-planerade-grafitgruvan/

    Our closing statement in full below.

    2023-02-21
    Main hearing in a case concerning an application for a permit according to the Environmental Code
    for mining operations, etc. at Nunasvaara Södra
    FINAL PRESENTATION

    Claims
    Our claims have previously been submitted and reported verbally when
    the main hearing began. During the negotiation, nothing has emerged
    which changes our previous demands that the application
    - in the first place must be rejected
    - otherwise rejected.
    It is quite the opposite, and not least after the company's presentations below
    the hearing and today that our conviction about the correctness of our
    claims have been strengthened.

    Sustainability and green transition
    Talga believes that sustainability is not a section in a report from the company
    without the core of the company's business strategy and vision, and that the graphite is one
    critical raw material for the green transition.
    Sustainability and green transition have become slogans for mining operations.

    But how sustainable and green is it for the local community here in northern Sweden?
    In a basically untouched landscape, the company wants to open four mines and more
    one that has been the subject of the negotiation. The plan is not to break
    120,000 tonnes annually but not 520,000 tonnes annually for 25 years. Operation
    with blasts as described occurring only during
    the summer semester will quickly expand into year-round blasts.
    The total environmental consequences for the whole intended
    the operating area between the Torne and Vittangi rivers does not yet exist
    presented.

    The activities in the area now reported are said to provide little or little
    consequences for reindeer husbandry, but the area is in fact growing fast
    completely useless when work with and in 4 mines is started.
    Transport operations will not take place in a limited area but in
    the whole area all year round.

    Regarding the absolute necessity of graphite for car batteries, it can
    the statement also needs to be revised. IEA (International Energy Council),
    of which Sweden is a member, has reviewed critical issues in a 2022 report
    the role of metals in the "green" transition. Transition to so-called “solid
    state" batteries is clearly desirable and ongoing, because the batteries
    capacity with that technology is increased. The graphite needed for the anodes can then
    will be greatly reduced.

    All international research agrees that the most urgent to
    reduce the warming of our earth is to stop the emissions of
    greenhouse gases. If the mines were to be built here, this would help
    hardly to reduced emissions but instead to a strong local increase in an area that is today basically free of extensive emissions. Any
    reduction for these increased emissions in the near term has not been reported or
    hardly calculated if, how and not least when these planned
    graphite anodes in electric vehicle batteries have reduced emissions.

    There are no green mines today and not tomorrow either. They never will be
    ecologically sustainable.

    The company's only and inherently legitimate goal of making money for the shareholders can
    not be assigned a greater value or be approximately as durable
    alternative in comparison with long-term preservation of an ecologically sustainable
    area with great natural values and which is at the same time irreplaceable for ours
    cultural people the Sami and the reindeer husbandry.

    The motives
    Our motives for the claims made have been reported and we believe that
    the motives have been further strengthened during the negotiation. Not least
    it emerges from those during the negotiation period now by Bergsstaten
    announced the applications from the company for processing concessions for
    Nunasvaara North, Niska South and North. Of these applications
    it appears with desirable clarity that the three additional mines are planned
    for operation at the same time as Nunasvaara south.
    From the application documents: “Together with the deposit at
    Nunasvaara Södra may mine up to 520,000 tonnes per year
    when both projects are in operation at the same time.”
    It is then unequivocally according to the environmental code, that they are collective and cumulative
    the effects on nature and the environment must be reported and assessed at the same time and
    not piecemeal and divided but collected and whole.

    Nature 2000The Natura 2000 area consists of Torne, Tärendö and Kalix riverswater system with main channels, lakes and tributaries. Torne river and Kalix riverare Swedish national rivers and their extensive catchment areasextends from Treriksröset and northwestern Lapland and down toThe Gulf of Bothnia.The conservation plan appears under the heading Prioritizedconservation value: "Torne and Kalix river system is designated as a Natura2000 area because it is made up of free-flowing rivers such as iare essentially unaffected by hydropower and regulation. Therebymost of the river is characterized by natural, seasonalwater level variations which, among other things, create particularly rich speciescoastal zones along lakes and waterways. Thanks to this, the system has adiversity and connectivity, both upstream-downstream and withadjacent shore habitat, which provides opportunity for the rich biologicaldiversity that can be found there.

    Streams constitute a special species kingdomhabitat. Functioning spawning grounds and rearing environments for fish ithe current stretches are important for a rich aquatic fauna. The relatively good onewater quality also constitutes a great value and an important basis forthe diversity of the area.”Under reported threats, Mining operations are cited." Mine establishment andmining involves a major negative and irreversible intervention in the affected natural environment. Valuable nature is at risk of disappearing, while leakage of harmful and turbid substances can have a major negative impact.”Regarding substances with a negative impact on the aquatic environment, the following is stated:"Discharge, leaching or leakage of substances that affect the water environmentnegative occurs from many different sources, including terrestrial nutrients,mining operations, individual drains and soil disturbance in areas withsulphide soils. Even when the local impact is not great, it canthe combined effect of all emissions/leakage still create tangiblenegative effects".

    The combined impact from the 4 mines in the area comes without
    hesitation to create additional discharges both in the Vittangi and Torne rivers and
    this impact must first be fully clarified before any permits
    considered.

    In the overall review of the impact on the river, it should be cumulative
    the effect of emissions into the river is also factored in from the mines in Kiruna and i
    the vicinity of Kaunisvaara, all of which are planned for expanded operations
    together with another possibly additional copper mine in Kiruna
    namely Viscaria.

    The national river must be protected.

    Technical description
    No account has been provided, despite previous questions, about it
    The capacity of the planned sand and waste rock storage is also sufficient for
    the needs of the additional mines. The magazine is only reported
    needed for the first 11 years of a total of 25 years of mining, after which
    refilling is intended to take place. The magazine will then be filled to a total
    disposal needs, which have been calculated at 1.4 Mm3. The
    the deposit requirement probably won't be enough even for the additional ones
    the mines and to build a warehouse which must be from the start
    undersized does not seem reasonable. The company also reports that
    alternative is "under investigation" as shown in the EIA
    (Environmental impact statement) to the new applications for
    processing concessions. Before the collective management of gray rock
    and enrichment sand for all mines have been reported, i.a.
    the environmental consequences were not reported.

    Reindeer nutrition
    In Talga's annual report for the year 2022 there is an interesting matrix that on it
    the vertical axis reports "Meaning for the shareholders" and on the horizontal
    axis "Impact on Talga's success". At the top of the vertical and
    almost to the far right of the horizontal are two dots, on one it says
    "Reindeer Herd Welfare" (Reindeer Herd Welfare) and on the other
    "Indigenous rights and relations" (Indigenous rights and relations).
    From what emerged during the company's and the Sami villages' accounting, it seems
    in any case, this matrix meaning was forgotten during the production of
    the reindeer nutrition analyses, when the consultant obviously avoided to
    consult those they concerned and the only ones with real knowledge.

    The company claims that the impact will be small or insignificant, then none
    operations must take place during the winter months, which is why reindeer grazing could
    be made possible. The serious thing, however, is that the description itself
    the work becomes seriously flawed with 4 mines in operation and the entire area between
    Torne and Vittangi rivers become industrialized. The Nature Conservation Association believes that this situation must be taken into account already now with knowledge of what is planned. The Nature Conservancy reminds that the UN's declaration of non-people, together with other principles of international law, gives the Sami people rights according to the principle of Free and Informed Prior Consent (FPIC). There is no consent yet from the Sami villages concerned.

    Reflections
    We can state that very much of the overall content of the application
    with the original EIA and various detailed appendices underneath
    The "investigation period" before the announcement has been changed, corrected and even during the hearing new or changed information has been submitted.
    One such interesting example was when the company suddenly presented a new one
    natural value inventory carried out in 2022. The company had previously stated in response to "second opinions" submitted by SNF and local representatives on completed inventories that this second opinion had no real value, as nothing new had been added. The new inventory reported by the company during the negotiation and carried out in 2022 turned out to be largely consistent with the Nature Conservation Association's second opinion. Additional areas and species of natural value are reported, which in total affect the assessment of protection values.
    Mining companies occasionally state that the permit processes are unnecessary
    long processing times. We can with the experiences from this
    negotiation do not draw any other conclusion than that the background work for
    the application may not have been enough, then so much supplementary and
    revised documentation has had to be drawn up and reported.

    EU Environment Commissioner Virginijus Sinkevicius responded during a visit to Kiruna
    recently when the mining issues were in the center and the mining industry talked about that
    it must be easier to get permission for new mines: "We will not
    compromise or weaken the protection of nature for more
    mines”.

    For the Nature Conservation Society in Norrbotten County
    Björn Lundquist"
    Last edited by Gvan: 27/02/23
 
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