Ongoing SP Discussion, page-1180

The mining company will have to justify that the Calerizo will not suffer damage.

One of the most repeated requirements in the reports that give content to the scope document is that the mining company will have to give guarantees that its project to extract lithium in Valdeflores does not affect the underground water mass of the Calerizo. This document serves as the basis for the company to draw up its environmental impact study, a key text to determine if the mine and industrial plant are viable. For its writing, there have been reports from sixteen public bodies, five groups and three individuals. Thus, the Risk Planning section of the General Directorate of Emergencies specifies in its report that from the documents provided by the company "the perimeter of the Calerizo is not clearly observed and whether or not it really affects the areas of implantation of the treatment, stockpiles of topsoil and installation of sterile.

The Geological and Mining Institute of Spain supports the same idea when pointing out that the environmental impact study must provide "a hydrological characterization in the environment close to the future exploitation -mining- with the establishment of an adequate network of control of the groundwater quality. The Nature Conservation and Protected Areas service details that one of the alternatives for the industrial plant, the one that borders the Miajadas highway, "would be located on what some studies consider part of the Calerizo, an issue that should be clarified in the study" of environmental impact. And Public Health delves into the idea by considering that since "this type of activity -mining- can affect the natural environment by producing different emissions" "non-incidence" in the Calerizo aquifer should be guaranteed.

And these warnings are greater in the report of the Tagus Hydrographic Confederation, an organization that emphasizes that not only is the Calerizo in the area, but also two other aquifers to be assessed,In addition, it specifies the level of incidence that each of the alternatives would have to locate the mineral treatment plant and the waste collection. Thus, from the option next to the Miajadas highway, he ensures that a "qualitative" incidence in the Calerizo aquifer "could be expected". This alternative is the most likely. But for the CHT, the southern option, in the Sierra de la Mosca, "would be the most favourable" as it had no impact on any of the aquifers. The CHT concludes that before processing "the mandatory water concession, it is understood that a detailed hydrogeological investigation is appropriate."

The projected mine's distance from other mines and from the town center is another issue emphasized in several of the study reports. The first is the town hall, which emphasizes "the need to justify in detail the distance to the urban center" of the elements and facilities that make up the activity. Groups opposed to the project, such as Salvemos la Montaña and Adenex, allude to the distance, which in its report details that “the minimum distance of 2,000 meters from urban centers” is not being met. And the General Directorate of Public Health also alludes to this issue when it states that "the exact distance from the mine and its facilities to the urban centers of Cáceres should be specified."and Sierra de Fuentes, taking into account the location of residential, a hospital, the penitentiary center, a nursing home...».

There is a third issue that recurs in many of the reports and consultations. It is the "urban infeasibility" of the project, according to Adenex, which stresses that the classification of the land in Valdeflores "does not allow uses linked to extractive activities." The Cáceres City Council also refers to this issue in its report. And Ecologists in Action does the same when alluding to the "manifest incompatibility of the action with the regime" of the land uses established by the plan.

The proposal to bring the water that will be used in the mine and in the industrial plant of the waste treatment plant (Edar) also faces objections. One is from the Spanish Ornithological Society, which ensures that the water supply from the treatment plant "does not include essential elements to be realistic." Public Health also considers that with the data included in the initial project "the contribution of water from the treatment plant would not be sufficient."

Among the consultations, the report of the Nuclear Safety Council (CSN) draws attention, which points out that the object of the mining project is the production of lithium hydroxide concentrate and adds that mining and concentrate activities are "susceptible to producing an impact significant radiological impact on human health", stating that the environmental impact study will have to assess the identification of the potential impact that "should focus on the possible presence of radioactive material of natural origin associated with the mineral, the waste and production residues and to the concentrate, as well as in the management of water and leachate, in the event that these may present concentrations of natural radionuclides significantly higher than the typical values of the environment”.What the CSN does is remember that the study must take into account a series of regulations and standards.

Binding nature of the reports in the impact study

The mine project and its environmental impact study will require an integrated environmental authorization, according to the consideration made by the General Directorate of Sustainability. The documentation will have to undergo a period of public information and a hearing procedure must be given to the interested parties, at the same time the sectoral reports of the competent bodies must be requested, opinions that "will have a binding nature for the purposes of resolution of the procedure", as recalled in the environmental legislation of Extremadura.