Apologiesin advance for the word dump but I was sitting around on a beautiful Sundayafternoon in Sydney and thought I would read up on the mining permit process inSweden and Talga’s progress. That sounds a bit sad doesn’t it? Hahaha
I had a read of this paper “Mineral extraction in Swedish Sápmi: The regulatorygap between Sami rights and Sweden's mining permitting practices” (October 2020)- https://www.researchgate.net/publication/344539364_Mineral_extraction_in_Swedish_Sapmi_The_regulatory_gap_between_Sami_rights_and_Sweden's_mining_permitting_practices
Pretty interesting (well it was to me anyway) as itdetails the process especially in relation to reindeer husbandry Below are the keypoints that stood out to me and it bodes very well for granting of the miningpermits.
Mining Permit
- The Mining Inspectorate is a separate decision-making body under the Swedish Geological Survey (SGU) and issue the mining permit.
- A mining concession does not grant the applicant the rights to actually operate a mine, however an approved mining concession is a pre-requisite for obtaining other permits, such as environmental and building permits which are required under other acts to be able to pursue mining activity.
- They are not aware of any resolved cases in which a company has been granted a mining concession and has not been granted the subsequent remaining and necessary permits. Thus, the mining concession is the primary permit that indicates permissibility of the project as a whole.
- The basic prerequisites for obtaining a concession are straightforward; if certain conditions regarding the value of and access to the mineral deposit are met, then the Mining Inspector must grant a concession.
- There is, thus, a presupposed bias in the Swedish Minerals Act that favour the granting of a mining concession
- Prior to the permit decision, the Mining Inspector consults the County Administrative Board. The County Administrative Board has an important function to coordinate and safeguard Swedish State interests regarding the land and resource management interests in the region, including reindeer herding. If the Mining Inspector and the County Administrative Board disagree on the balancing of public interests relevant to the location, the permit decision is, instead, made by the Swedish Government.
- To date, there are only two cases whereby the Country Administrative Board and the Mining Inspector have agreed to reject a concession permit application on the basis of significant impacts on reindeer herding. Both decisions have been appealed. There are thus far no final cases whereby a mining concession permit has been denied based on potential impacts on Sami reindeer herding.
Environmental Permit
- The permitting authority for mining operation applications is the Land and Environmental Court (LEC).
- It is not designed to hinder environmentally hazardous activities but, rather, to mitigate and manage potentially significant negative impacts on the environment and human health from such activities.
- A mining or related activity can only be denied if the site is exceptionally unsuitable, if the environmental and/or health impacts would be unacceptably severe.
- Both the mining concession and environmental permit stages require the mining company to undertake separate environmental impact assessments (EIAs)
The balancing of opposing interests
- A critical and complex consideration during a decision on any mining concession application is the balancing of different, and often opposing, public interests concerning the land-use in a certain area
- The Environmental Code postulates that combined land-uses are preferable. Hence, an a priori assumption that mines and reindeer herding should, and can, co-exist is institutionalized. Only where interests are considered to be genuinely incompatible is the decision-maker obliged to prioritize one interest over the other
- It is not surprising that conventional socio-economic considerations (i.e. tax revenue and regional employment) commonly prevail, and mining interests are usually prioritized. There are only a few cases where incompatibility of land-use interests has been accepted and an actual prioritizing of land-use took place as a result.
Conclusion
- The most important decisions around permissibility of new mines concern the mining concession phase, because this phase is where the balancing of competing land-uses is assessed and decided, and this cannot be repealed at a later stage
Permitsare always a risk, just take a look at Infinity Lithium. They’re in a world oftrouble because some activist groups and the local government are vehementlyopposed to their lithium mine in Spain due to the proximity to the nearbytown.
Thankfullywe don't have this problem and from the above I think Talga are in a prettygood place. There are a couple of de-risking factors that help me sleep a biteasier too.
- Talga are already approved for a 25,000 tonne trial mine and the Environmental Review Committee within the Norrbotten County Administration Board issued a three-year environmental permit.
- The Swedish Geological Survey (SGU) designated the entire resource as a mineral deposit of national interest meaning municipalities and central government agencies may not authorize activities that might prevent or significantly hinder exploitation of the mineral deposit. They noted the deposit’s significance to the country’s supply capacity and its special material properties and concluded the deposit constitutes a unique natural asset of valuable substances or materials. Further, they consider locally produced graphite could help strengthen the competitiveness of the Swedish battery manufacturing industry and that, as the known highest grade graphite deposit in the world, Vittangi could ‘meet a great need not only within Sweden but internationally’.
- On 27th of January the SGU responded to Talga’s 500,000 tonne mining permit application and said the “SGU therefore limits its response to those issues that it considers relevant for consultation prior to the assessment under the Environmental Code. In this respect, SGU considers the consultation document to be solid. However, there are certain issues that need to be clarified”. The issue was how the underground mining may affect groundwater flows and water balances
- State owned mining company LKAB are on board as a JV partner. This will be critical to the point above as they have significant expertise in underground mining and operate a number of underground mines at depths of more than one kilometre. They also have second to none knowledge of the Swedish mining permit process.
- The project is perfectly aligned to the EU's strategy of creating a regional battery and EV supply chain to reduce sovereign risk and reliance on imported materials, as we all as minimcarbon emissions in the production process.
I think the key factor is the SGU assessment underthe environmental code in relation to the mines effect on the water. With LKABon board I hope they can easily resolve this and the mining permits can then begranted. No doubt the permits will weigh on the SP until then, but there's nothing that has me too worried at the moment.
(20min delay)