Updated 02/05/2002

Comments Received

Weekly Comments:

April 12-17

April 5-12

March 29- April 5

This page lists the comments MMSD received on its Draft Report.

All comments received up to the end of the comments deadline (April 17 2002) are listed below and MMSD did its best to reflect them in the finalisation of the Report, as testimony to the diversity of opinion that exists in the sector.

Comments received are displayed on a weekly basis. Those comments received after the deadline are also displayed (lower down the page), along with comments which were not submitted to MMSD but which became publicly available over the internet or in publications.

Where the authors of comments have submitted additional documents, contact mmsd@iied.org if you would like the accompanying documents in full. Only direct comments on the Draft are included here.

Comments received will be assembled into a separate document which will be available when the Final Report comes out in published form.

Click here to view Draft Report Chapters.

Click here to view Final Report.

Disclaimer

Comments received, April 12-17

Dr Jack Testard & Dr Patrice Christmann, BRGM (The French Geological Survey). These views are the sole views of the authors and do not represent an official statement of BRGM.

Comments document
(PDF 389 KB)

Jean-Claude Lauzier, Canadian International Development Agency

Comments document
(PDF 101KB)

JJ Coetzee, Independent Mining & Strategy Consultant, South Africa

Comments document
(PDF 294KB)

Nicholas Aspinall, Geological Community Development Consulting, Indonesia

Introduction: Congratulations on this report. It outlines all the challenges facing our industry. Without revolutionizing the way the industry operates there is no way forward. This means new challenges, which means new opportunities.

Chapter Nine: The key to mining's future is community relations and community development especially in developing countries.

Chapter Sixteen: Southeast Asia may not be the ideal choice for future mining investment. The problem is governments in these regions do not understand mining. This is evident from their mining laws and policies. Ironically countries like Indonesia have a booming small-scale mining industry, 99% of which is illegal.

Bruce Marsh, USA

Thank you for all your efforts on developing the MMSD report. I believe that the final report should be required reading for all professionals currently working in or with the mining industry and could make a very helpful text book for college students to better understand how the mining industry is getting more complicated.

The report reads as if it has been edited carefully by a committee. Unfortunately the scope of the effort was far too broad in trying to deal with all mining activities in all countries of the world. The draft report is thus a very general report which will do little to change the world and help mining companies better operate.

Most disappointing however is that the report gives very little data to show the tremendous progress that the industry as a whole has been making especially in the past 10 years. Many companies are doing good work and some of the trends such as the number of environmental and social professionals working directly or indirectly with the industry are not presented. I expect that the MMSD team has a great deal of this kind of information and it should be presented in graphs and tables to make a more powerful case that the industry is responding and changing to the increasingly complex world.

I appreciate the enormous task to try and bring all this together in a format that is acceptable to the companies paying for this effort, however more transparency on the MMSD process (including things like the names of the companies who funded the MMSD effort and how much they paid) would help the credibility of the process. MMSD staff should be more transparent on the review process and how the industry (and certain companies inside the industry!) has clearly led this process rather than continue to present that the process has been one open to all stakeholders.

Dr. Allen White, Global Reporting Initiative

Comments document
(PDF 36KB)

Barry Golding, Australia

Please find attached a copy of my response which I hope the authors will accept as constructive criticism. I have reviewed only the structural and philosophical aspects of the report as editing for grammar and clarity are not my strong points. The report would benefit from editing by a disinterested editor unfamiliar with the jargon of either the management or mining industries. This would improve the readability of the report and hopefully make the meaning clearly understood by a lay reader. I list just two example. As a professional in the industry I don't understand what is meant by a "minerals system", a "minerals production system" may be clearer but even so needs definition. In Table 16-1, I am not sure what an "ongoing, intentional, and inclusive dialogue that involves widening circles of stakeholders" means or what it implies for the mining industry.

Comments document
(PDF 148KB)

British Geological Survey

Comments document
(PDF 91KB)

B Nokwindla, South Africa

One is not sure how the opening of access to women in the mining industry has been considered in the report, perhaps streamlining this issue with gender and the declaration by heads of state of SADC. There are numerous reports on this issue should you need them.

Communities and Small-Scale Mining (CASM) Network, c/o DFID, UK

Comments document
(PDF 338KB)

Leni Berliner, Mining & Metals 21 Inc., USA

Comments document
(PDF 52KB)

Prof Rene Van Berkel, Curtin University of Technology, Australia

Comments document
(PDF 212KB)

Dr. Antony R. Berger, IUGS Geoindicator Initiative, Canada

I disagree strongly with the underlying assumption that ASM is by definition a bad thing, and “will – and should – disappear naturally if progress towards sustainable development is made.” ASM can provide sustainable and profitable livelihoods for individuals, families and remote communities who work small deposits under proper conditions. Examples that I have seen in developing countries include beach sand
operations in Sri Lanka, salterns in Tanzania, and tanzanite mines in Kenya. The small-scale gem pits in Sri Lanka have provided a steady employment for several generations of "miners" as well as the basis for a considerable industry of cutting and setting. In Canada, the Inuit quarry labradorite in a small-scale operation that does not interfere with their traditional way of life.

The Chapter argues that “From an economic perspective, resources can be mined far more efficiently and intensively using large-scale mining methods, and in terms of environmental damage, small-scale mining has a greater impact per unit of output.” How can this be so where mineral deposits of small size are involved? You cannot apply large-scale methods to small beach sand deposits, and to pegmatite-hosted deposits. These are surely only economic when worked on an appropriately small scale.

Antonio Juarez Milmann Martins, Ministry of Mines and Energy, Brazil

In the first place, congratulations for the wonderful job you have done so far. It is indeed quite a task to put together in one report so many contributions on several themes worldwide. My suggestion is that you prepare an Executive Report to be presented and discussed in the Toronto meeting, even if it isn't the very final one. This procedure would perhaps allow the arrival to some objective and conclusive positions concerning the World Summit, specially for the preparatory meeting to be held in Bali about five weeks from now. It is important that the mining sectors of different countries speak the same language on a common agenda.

Colin Boocock, Consultant

Chapter 13:
In the light of the problems associated with the use of mercury, it may be worth noting that GEF and UNIDO are currently starting a global mercury project whose eventual aim is to eliminate the use in artisanal mining. I strongly believe that one of the weakness in regulation of the sector, particularly in francophone Africa, has been the fact that artisanal miners are not given title to the areas that they are working. Introducing a claims systema for artisanal miners could be a way of solving this. Having title to their mining areas may enable artisanal miners to attract finance as claims can provide collateral for loans. As far as environmental management is concerned in artisanal and small-scale mining it will be difficult to extend the EIA process to this activities, but a way of addressing the issue is drawing up simple best practice guidelines for their activities. This would require input from aid agencies and NGOs in their application.

General Comment:
I felt that junior companies were commonly singled out for their poor record. Whilst not questioning that some junior companies have poor records, I am just a bit concerned that it may be the impression, in some cases, that they are the only ones to blame for the mining industry's poor image.

EuroGeoSurveys, Belgium

Comments document
(PDF 62KB)

Henry Brehaut, Canada

Comments document
(PDF 184KB)

Tony Berger, Canada

1) Any special pleading from the mining industry for access to protected lands should acknowledge that it is not up to the mining industry to make land use decisions alone, but rather local governments and the people behind them.

2)A mine within a park or protected area (PA) will have a finite life and the economic spin-off accordingly finite. A PA provides through tourism and visitor spending employment opportunities and spin-offs that can be far longer lasting. Not only for people in but also around the PA.

3)The chapter should acknowledge that there is considerable interest among the earth science community in protecting places of special geological and mining interest. A great many parks and protected areas have been established specifically or in part to protect geological “resources” such as fossils (e.g. Dinosaur Provincial park, Alberta), unusual rock complexes (the ophiolites of Gros Morne National Park, Newfoundland – also a World Heritage Site), and spectacular geological phenomena (the geysers of Yellowstone NP; the volcanoes of Tongariro NP in NZ). Unesco is currently promoting the development of “geoparks”, and there is an international project to identify and preserve “geosites” of special scientific value. Moreover, some World Heritage Sites were established specifically to preserve mines or mining districts: e.g. Roros in Norway, and Wieliczka Salt Mine in Poland.

Al MacDonald, Talmac Consulting, Canada

First off, congratulations on collating the massive amount of data from the MMSD process into a very readable single document. My critique is mainly levelled at chapter 3's efforts to profile the "key players" in the minerals sector. It is not that MMSD has failed to identify those key players. Rather, the unfortunate aspect is that they are treated as discrete entities far removed from one another. This is entirely illusory in what I have personally described as a mineral "production system."

As you make the Herculean effort to shrink this document down to a final format, I would urge the writers to speak more about relationships, and less about description. I would think that the main readers of the final report will have a relatively well attuned sense of what large multinationals, junior explorers, labour unions, and NGOs are (although illustrating the breadth of difference inside these categories are valuable). What they may not understand equally is the relationships between interest groups with a stake in the "mining game", and how the perceptual gulf between different stakeholders have been created and maintained over time. While I realize that Chapter 3 is more of a foundation chapter for the overall document, I found limited assessment in subsequent chapters of the fundamental perceptual dividing lines between stakeholders. Misunderstandings, misinformation, lack of ability to communicate in all manner of scenarios from initial exploration through to revenue sharing, etc all come back to these fundamentally different worldviews.

I personally would like to see (as a visual person, this is my own crutch) some schematics detailing the typical relationship patterns between mining stakeholders. A very simple example that I think MMSD could certainly improve upon would be Figure 3 on page 20 of "Industry in Transition", my report for MMSD North America. Additionally, for those readers who want to better understand the portion of the mineral production system made up by the corporate mining sector, can I recommend an iteration of Appendix 4 in the same book, which breaks down the multitudes of corporate actors from juniors through global MNCs, and the typical relations between them.

I think that identifying these relationships and the impacts they have on stakeholders are one of the essential needs to be fulfilled by MMSD. A very simple example is the relationship between junior and senior firms in the global mineral production system. One theme of my report was that perceptual gulfs do not only exist between "miners" and "outsiders" (a gross simplification of reality), but also between firms of different size and organizational focus. The notion of "sustainable mining" means many different things to different corporate actors, who have unequal capacities to react to changing economic, environmental and social demands. Regardless of individual capacity however, these firms are all caught up in the same web of an integrated production system. What small firms do has implications for large firms and vice versa. Yet, many in the industry still refuse to recognize this interdependence. As one person stated to me " Grouping large and small firms into one industry may be your fatal flaw; they are apples and oranges". The fatal flaw may indeed be that the exploration roots of the industry may not be able to fuel the maintenance of the global mining tree, without support from above.

The above is but one example of the sorts of paradoxes that need to be exposed by MMSD in their final report. I will include with this comment a short discussion note on self-regulation in the industry that MMSD is welcome to post to interested readers. [Please contact mmsd@iied.org to receive this document.] I think it speaks to some of the issues mentioned above, and indeed questions what type of agenda for change the industry will be willing to involve itself in at a substantive level.

A final note: kudos to the writers of the recommendations and agenda for change aspects of the report. One thing that I have heard from many parties in the corporate and NGO sector is a concern that MMSD would be a watered down PR process; I think that the proposals for change agencies are perhaps stronger than expected. A challenge has been issued; will the industry answer the call?

International Zinc Association

Comments document
(PDF 113KB)

International Council on Mining and Metals

Comments document
(PDF 764KB)

Kenneth Arne, Minerals Consultant, Kyrgyz Republic

Comments document
(PDF 56KB)

Nelia C. Halcon, Chamber of Mines, the Philippines

Comments document
(PDF 203KB)

AREZ, Zambia

First and foremost we wish to put it on record and congratulate the MMSD IIED TEAM for the excellent execution of the MMSD global coordination. We have no doubt that almost all the salient details with respect to minerals sustainable development regionally have been ably articulated. In this regard we wish to amplify mainly on the need for an integrated approach in finding the way forward to the MMSD framework. We would suggest that the way forward must be based more on case studies - actual experiences in the minerals sector - the lessons learnt documented.

It is a fact that in most third world countries the mineral wealth is perceived as the necessary resource to drive sustainable development. However despite the many years of mineral wealth exploitation in the third world sustainable economic development has been elusive, the reasons are varied. For example in the Zambian (dependent on mining) scenario, despite over 80 years of minerals exploitation the Zambian economy is still in the back waters of severe poverty.

From this and other similar experiences, MMSD path need to incorporate development of parallel sustainable activities among the indigenous people at an early phase of the mining lifecycle. It has been recognized that for the MMSD to succeed the Governments would need to play a key role in facilitating sustainable growth for a more general appreciation of the world minerals endowment. The NGO community, as independent development partners, must also be in the forefront in prodding Governments and private mining enterprise to stay focused in pursuit of MMSD. The Governments have a major role to play in facilitating the alternative economic activities. In this regard issues of mine social management planning could start to be implemented at the Mine post-feasibility or start up stage, i.e. funds earmarked for post-closure rehabilitation could be used as a revolving loan fund (creating independent fund management trust) to pursue the identified alternative livelihood for the indigenous communities.

The MMSD must emphasize the need to develop minerals development financing
mechanism/models that ensures a consistent financial availability for sustenance of on-going mining/minerals operations to mitigate against downturns in the mining lifecycle. This is to avoid unsustainable impacts of sudden mine abandonment / unplanned closures due to financial pressures.

Alcan inc.

Comments document
(PDF 154KB)

Bill Carr, Department of Mineral and Petroleum Resources, Australia
personal comments

Comments document
(PDF 265KB)

The Bureau of International Recycling

Comments document
(PDF 109KB)

Construction, Forestry, Mining & Energy Union of Australia

Comments document
(PDF 155KB)

Camilo D. Leon, The Pennsylvania State University, USA

Comments document
(PDF 35KB)

Claude LeCoq, International Nickel Study Group, Netherlands

On behalf of the International Nickel Study Group (INSG), I would like to make the following comments on the MMSD's draft report.

1. Although the INSG is a world authoritative source of statistical information on nickel markets, there is no mention of our intergovernmental organization neither in chapter 3, nor in chapter 12, which provide a kind of inventory of the relevant (intergovernmental) organizations able to provide useful information to the mineral and metal sectors. It is astonishing as the other well-know information providers on that specific sector, such as CRU or WBMS that use extensively our data, are widely mentioned.

2. Among the intergovernmental initiatives in the field of Sustainable Development, it is also surprising that the Non-Ferrous Metals Consultative Forum on Sustainable Development established by the 38 Member countries of the International Copper Study Group (ICSG), the International Lead and Zinc Study Group (ILZSG) and the International Nickel Study Group (INSG) is hardly mentioned in your survey, with the exception of the Product Stewardship initiative listed in the chapter 11 as the key component of the whole Consultative Forum (see pages 11-8 and 11-9).

To conclude, I would suggest to include at least the Study Groups in the list of the significant data providers for their respective metal markets.

Chilean Copper Commission

Comments document in Spanish (attached left) and English summary of comments below.

Points of disagreement with MMSD

Executive Summary:
P2. It is not always clear that mining brings economic and social benefits to the host countries either, and the minerals sector sometimes operates where there is poor governance, including corruption, and is thus associated with it. Given the background to mining in Chile, this clearly points to the need for a much wider scope of analysis than is assumed by the statement above. This position has obviously emerged as a central concern for MMSD, but is a point of view that does not reflect the situation in Chile.

Definition of Sustainable Development:
Another point on which they fundamentally disagree with MMSD's analysis is the assertion on p.8 that: 'a balance has to be achieved between expanding minerals consumption in developing countries to meet growing populations' basic needs, and expanding everyone's consumption to match current levels in industrial countries. Ecologically, the latter may be globally unsustainable.' This statement indicates that the main definition of sustainable development being used here, is one that is based on consumer behaviour and the level of use of natural resources. This is a one-sided perspective favouring the position of those countries that are more technologically advanced, but does not consider the negative consequences of this process for countries that are producers of raw materials which can be difficult to predict.

Agenda for Change:
the creation of new international institutional bodies; new regulatory framework for conventions, codes; countless financial instruments; overemphasis on role of World Bank, financial institutions and insurers to intervene in national affairs that goes beyond their jurisdiction and infringes national sovereignty.

Comments document
(PDF 51KB)

Clara Baretic de Padilla, Universidad de Los Andes, Venezuela

In general terms, the report seems comprehensive and accurate. It looks suitable to be used as a basis in decision-making processes, especially those devoted to mediating the problems that hamper the implementation of sustainable development programmes. Nevertheless, I would like to highlight the lack of presence of the academic sector and how this could be fostered to participate in these important tasks.

Clive Wicks, WWF, UK

Chapter 7: Land, mining and indigenous people

I think that the key issue has been missed out in the reference to ILO 169. The key issue is that companies have to have the "Prior and Informed" consent of Indigenous people before they can do anything on their land. The "Informed" means than the indigenous people have to be fully informed on the total impact of the mining operations on them and their environment.

Philippines: I circulated a paper by the Catholic Bishops of the Philippines to the
President and People of the Philippines and I have attached it again. This letter asks that a number of mining operations should be halted and that new mining should be banned because of the damage the industry has caused to the environment and people of Philippines. Basically the Mining Industry has lost its license to operate in the Philippines.

Operating in sensitive areas: Criteria for operating in areas of high biodiversity. I am surprised that no reference is made to WWF " To Dig or not to Dig" document. This was distributed at the meetings we attended and some delegates commented on it. The document is supported not only by IUCN but also by UNEP (see page 4 of the report). It has also been put on the UNEP website: www.mineralresourcesforum.org and the WWF website: www.wwf.org.uk/filelibrary/pdf/to_dig_or_not_to_dig1.pdf.

Chapter 10: Marine disposal

I am particularly concerned about the comments on marine disposal. I have attached the paper that Dr Martin Angel prepared for us [please contact mmsd@iied.org to receive this document.] We have strong reservations about Marine disposal and the current practises have been condemned by many Australian and PNG scientists. Their objections were recorded in the Australian film "Dateline" on 27 June 2001.

Riverine disposal: This is totally unacceptable to WWF and many other civil society organisations. The damage goes far beyond the riverine eco system and reports say that it affects the marine eco systems including the fish reproductive systems. It has been condemned by many Scientists from the region as well as internationally.

Natural capital: I think this Para is missing the key point that has been made by the UN and many other agencies. The real problem is that developing countries natural capital has been depleted and shipped off to rich Developed countries with little long term benefits to the developing countries. This is referred to in the World Bank reports as the "Paradox of plenty."

Respect for National Environmental and Social Legislation: One of the major complaints about the Mining companies is that they have either undermined or bypassed National Environmental and Social laws by agreeing to "Contracts of Work" with the Mining Departments of governments which do not respect National Laws. This totally undermines the Environmental and Social departments of the governments who created the laws in the first place. These departments often do not have the political support of Mining and Oil and Gas depts. When this happens the company risks being accused of corruption. Many questions are being asked as to how these contracts were signed often by politicians who left office shortly after signing leaving their successor with major problems.

Category 1-1V: It is important to mention that the Cats 1-1V only cover 6% of the Worldsurface. IUCN has confirmed that this is not adequate to protect the Worlds
Biodiversity but respect for the Amman Declaration is at least it is a first small step.

David M Chambers, Center for Science in Public Participation, USA

Comments document
(PDF 105KB)

David Harries, Canada

Comments document
(PDF 46KB)

Hugh Salvesen, Foreign & Commonwealth Office

Comments document on Voluntary Principles section of Draft Report
(as tracked changes):

Comments document
(PDF 10KB)

Jerome F. Cole, International Lead Zinc Research Organization, Inc.

Below are our comments Chapter 5 Case Studies on Minerals. Our comments are limited to the case study “Lead.”

1. We suggest elimination of the paragraph 6-8 of this section. It is highly inappropriate for this document to enter into the argument over whether or not society should reduce its dependence on the automobile. Also, the argument that reduction in automobile use would limit the use of lead, while true, would also limit the use of most other metals as well. The implied assertion that lead use needs to be reduced is also questionable.

2. It is suggested that a paragraph be added noting the contribution of lead to sustainable development. Lead acid batteries are important components in the use of renewable energy. Possible wording follows: The international lead industry, through the International Lead Zinc Research Organization (ILZRO), has embarked upon a program to bring 24-hour electricity to poverty-stricken areas along the Amazon River in Peru, now with limited or no electricity. In July 1997, ILZRO, the Solar Energy Industry Association (SEIA) and the Ministry of Energy and Mines of Peru signed a Memorandum of Understanding leading to the design and installation of pilot remote area power supply (RAPS) hybrid systems to supply 24-hour electricity to remote communities,. The systems incorporate renewable energy (solar) and existing diesel gensets, advanced batteries to store energy and supply it throughout the day, and state-of-the-art power electronics.

The RAPS project, which is being funded by industry and a variety of national and international governmental bodies will be completed in June, 2002. The effort is aimed at helping to assure sustainable development of rural communities by providing electricity necessary to increase income-generating activities. Specific benefits will include: reduction in diesel fuel use, which will reduce current fuel costs; reduction in environmental damage from diesel exhaust and fuel spillage in this environmentally sensitive area; availability of 24-hour electricity; enhancement of the population’s quality of life and economic activity in the villages.

Ian E. Marshall, Ian E. Marshall Consulting Services, Canada

Comments document
(PDF 62KB)

Jennifer Hinton, University of British Columbia, Canada

Comments document
(PDF 11KB)

Department of Mineral and Petroleum Resources, Government of Western Australia

Comments document
(PDF 58KB)

James F McDivitt, UNESCO and Colorado School of Mines (retired)

Comments document
(PDF 33KB)

Kwabena Mate, Bentsi-Enchill, Letsa & Mate, UK

Comments document
(PDF 20KB)

Dr D N Wilson, LDA International

Comments document
(PDF 10KB)

Dr Carolyn Stephens & Mr Mike Ahern, London School of Hygiene & Tropical Medicine, UK

Comments document
(PDF 23KB)

Miguel Jimenez, Peru (personal comments)

Comments document in Spanish (attached left) and English summary of comments below.

The suggestion that 'mining companies tend to operate in countries characterised by weak governance structures and corruption', implicitly assumes that all mining practices are dishonest and unlawful. Following this line of reasoning, it can similarly be inferred that all NGOs, not only those opposed to mining, are also institutions that are run illegally. While there have been cases where it has been proven that funds have been illegally embezzled from their intended use by NGOs (in Peru for example), this is only one part of the picture. To tarnish them all with the same reputation is therefore unfair.

On reading the report I quickly became disillusioned at reading statements, which instead of raising the level of debate and contributing to ideas and ways forward, came up with these kinds of imbalanced generalisations. I don't suppose in Canada for example, a 'weak governance structure' allows the mining sector to operate through annexing itself to corrupt practices. The real question that needs to be asked instead is how, through the efficient use of their natural resources, has Canada managed to become a global power, and why can't Third World countries like Peru aspire to achieve the same thing?

I think that the effort, time and money poured into MMSD should have led to an outcome that aims to have an honest and serious debate about the use of natural resources for development. This needs to engage all affected parties, and provide a framework where all parties can come together respecting each other's rights and views to discuss opportunities for development that results in a better quality of life for all.

Speaking as a geologist and on behalf of geologists, I want to underline that we have not deliberately set out to 'destroy the environment', 'threaten indigenous communities' or 'violate peoples human rights', but are normal people seeking to excel in their chosen profession. Although I work for a mining company operating in the North of Peru, I want to emphasise that the opinions expressed here are mine alone and not those of the company I work for.

Comments document
(PDF 11KB)

Department of Minerals and Energy, Republic of South Africa

Comments document
(PDF 47KB)

Paul Bateman, The Gold Institute, USA

Comments document
(PDF KB)

Prospectors & Developers Association of Canada

Comments document
(PDF 101KB)

International Copper Study Group

Following the announcement of the release of the MMSD Draft report, we have taken the opportunity to review the document in light of offering constructive comments. In reviewing the report, we took particular note of the following:

A number of statistical data on copper reserves, production, trade, usage and recycling are provided within the report.
A case study on the copper industry and its market is presented.
Besides affecting national copper industries in general, the draft report also identifies a number of issues to be addressed by national governments.
According to the draft report, governments should take the lead in setting standards to ensure sustainable development takes place at the national and local level.

Recognising that the draft report is of interest to all stakeholders, industry and member governments of the International Copper Study Group (ICSG), the ICSG Secretariat would like to share with you our observations and comments on the draft report. I have summarised these and you will find them in the attached Annex.

Taking into account the extensive scope and size of the draft report and that we were not involved in the course of the study, we would like to point out that we can only focus on some major issues. I hope our comments and suggestions are useful for you and congratulate you and your team on your efforts.

Comments document
(PDF 27KB)

Minerals Council of Australia

Comments document
(PDF 42KB)

Rio Tinto plc

Comments — April
(PDF 39KB)
Comments — March
(PDF 25KB)

Ministry of Energy and Mines, Peru

Comments document in Spanish (attached left) and English summary of comments below.

Chapter 16: Agenda for Change

On integrated plans for mine closure:
While they agree with the need to establish a development strategy that extends beyond the life cycle of a mine, the way information is presented in the report places overwhelming emphasis on mining as the only economic activity capable of generating future development opportunities.

On financial surety:
One of the suggested ways to achieve this is to compel companies to set aside funds in a separate account for mine closure. At regular intervals, they could deposit a fixed amount of money, such as a percentage of their sales for example. The life span of a mine and the projected costs of closure can be calculated from the outset of operations, which would enable companies to work out provisions for this annually. In the event of market fluctuations for example, mechanisms could be set-up to defer or extend the period of time when this would need to be paid. This provision could also be accompanied by setting-up a trust fund for mine closure. This amount would also be considered as tax deductable.

Abandoned mineral sites facility:
The proposal for sources of funding to rehabilitate abandoned mine legacies such as through taxes, surcharges, and the central bank's gold sales for example, are not feasible. Governments should instead introduce policies to allocate a share of the resources obtained by tax collection, profits of state-owned companies or money from privatisation. More importantly, is the need to prevent new legacies. In Peru there are compulsory programmes for environmental management for projects already in place, and EIAs for new operations.

Identifying gaps in capacity:
Stakeholders are able to propose ways of how resources in development projects should be invested, but development priorities should be determined at the country level in line with criteria of need, usefulness and urgency.

Comments document
(PDF 30KB)

Roger Moody, Mines and Communities Network, UK

On page 3-16 of your draft report, you present a reasonable summary of the London Declaration. However, it is incorrect to state that conference which gave rise to this Declaration "...was initiated to provide a forum for discussion among partners of Christian Aid."

All the participants were, in fact, partners of the former Minewatch, Partizans and/or Minewatch Asia-Pacific it was on this basis that they were invited. Christian Aid and Cafod funded the event and Christian Aid had a representative on the organising committee.

The source for your statement is given as '"The London Declaration", Christian Aid, London, 2001'. We have no knowledge of this publication and Christian Aid did not sign the Declaration, which you can view in its latest version on the Mines and Communities website (www.minesandcommunities.org).

Ted Downing, The University of Arizona, USA

Two points:

Notice that the issue of voluntary/involuntary is NOT brought forward (p12 in your ES, pp 7-25 thru 7-27, p 7-37!!!) This is a bogus issue. If people are displaced by mining it is involuntary before and after they move. Only if they are given the option of NOT moving at all would a decision to move be considered voluntary. Resettlement specialists have long ago trod this ground. In the end, getting entangled in this issue is really an irrelevant side issue (compared to what I have covered in this paper). The voluntary/involuntary issue is more related to feelings of self-justification for what many may consider an immoral decision. As I point out...if the displacement goal is set right in the first place (investment + compensation) and all risks are identified and mitigated, the end need not be so tragic. The argument at the bottom of page 7-38 about who should inform the community is a minor question...again focusing on how the mining company representative's feelings (avoidance of facing the situation) rather than the technical issues involved in MIDR. This should be tossed in the Thames. Critical issue is SETTING THE GOAL right and getting all the players to agree on the overall goal before the assessment is done by an independent party. Watch out for the conflict of interest issue (all sides, including government, companies and financiers).

Finally, I hope my argument convinces you to add MIDR in the Challenges to Specific Components of the Mining Sector (page 12-16). More damage is done to people than comes form security forces. Sir William Shakespeare figured this out a long time ago - which is why I let him have the first word in my report.

The World Bank, Mining Department

Comments document
(PDF 356KB)

Comments received, April 5-12

Adrian Henriques, UK

Here are my thoughts on Chapter 12.

Firstly, this is a professional piece, making many good points. I shall confine myself mainly to some big issues which I think are missed or under-played, together with a few more detailed points. I guess my main concern is that information is portrayed as a good in itself, which it may be, but in relation to sustainability, I think there is something else. Information needs to affect action, to make a difference, to be valuable. The chapter is right to put trust as the prime objective of delivering more information. But without appropriate action, based on that information, trust will evaporate.

I suspect there is also a need for information within the mining sector. How does information about final disposal/recycling reach and affect companies further up the value chain? You could say that the MMSD is itself partly an expression of this need. But there must be more which could be done. What is the long term vision for MMSD? Although the chapter does talk about smaller mining operations, I suspect the information challenges are rather different in this sphere. There may be a spectrum of information needs across the scale: family operations may require environmental information, slightly larger ones may require more information on social impacts, the largest companies clearly need to have and to provide the fullest range of information.

And on more detailed matters:

On p4 there is a paragraph beginning 'trust is sometimes said to be irrelevant to the process of reaching equitable decisions'. I find this rather an extraordinary point of view, I find it hard to see how equity can be reached in the absence of trust. Could more weight be given to the countervailing position?

On p5 it is stated that the only quantifiable statements that can be made with respect to information are statements about costs. This seems to me to be just wrong. There are a whole rage of sciences and technologies out there, from physics to market research which all deal in more or less quantified information. Or perhaps it is just badly worded.

The basic information section needs to mention that one of the most basic information needs is on how decisions are made. This relates to the point made several times later in the chapter that EIAs are rarely made public, and also to my general point about information needing to be acted upon.

On p8, the point could be made that different countries enjoy different cultures of litigation and therefore different attitudes to transparency. In the States most companies are chary of releasing information that they are not required by law to release.

The bullet on 'acknowledgement of leadership' on p9 suggests that there is a connection between reporting and being criticised; but as is pointed out later in the report, this is not usually the case at all. It may be the same thing which causes a company to report as causes them to be criticised.

P13 talks about the GRI; it may be wise to check the points made against the new version of the guidelines now released for public comment. The last bullet on business cases on p13 is rather weak; it does not really relate to business cases.

On p28, the first bullet suggests that a harmonised system for reporting would have to be voluntary; this is only true at the moment. A recommendation could be to explore whether and how an appropriate regulatory regime might work and be established.

John Reynolds, Australia

I would like to make a few comments. They come from one who is now in the "old" bracket, who, until 1998, had 55 years full time employment in metals, minerals and mining, the final 20 of which were dealing inter alia with the precursors to MMSD at corporate affairs management level. The comments below (at the risk of being a nit-picker) are confined to what a new reader would receive from a first ever exposure to the Executive Summary, and refer to the opening pages only.

I feel it is most important the introductory pages are very clear in their meaning and message. They should avoid modes of expression that cause the reader to pause and wonder what is meant or implied. It should also impart a confidence that the positions being expressed have been thoroughly examined.

The comments refer to "Part 1: A Framework for Change".

Page 2, Paragraph 1: Delete basic - mineral products fulfil a whole range of needs and "wants". Second sentence, should read - Mining is a contributor in poverty alleviation, and is playing a role in broader economic development. Dispersal is not clear, should it be disposal? It is not always perceived (rather than "clear") that mining always brings social and economic benefits. Either could be deleted. Comment: This and paragraph 2 include a little too much emphasis of mea culpa. None of the operators or "stakeholders" are lily-white, but we all want see improvements. Paragraph 2: For parts of the corporate world use businesses and industries. Delete tremendous. Line 5 - after standards insert environmental management and social responsibilities, also delete are suspect and insert have suggested (line 6 that some businesses). Line 7 - It is questionable whether so-called "stakeholders" are actually in the minerals sector. It raises the matter of consistent terminology, which is not apparent in this draft.

Page 3, Paragraph 1: First dot point, Use of the word transition implies that either the minerals sector or development in general, is in toto, at present unsustainable. Is this demonstrated? Second dot point - To a "first reader" it is not clear what is meant by the services, or the mineral supply chain and how they can be delivered. Paragraph 2: Does actors involved mean "stakeholders? There is need for a single mode of expression. The paragraph rightly states that "they" should have the opportunity to put forward their views. Have they done so and is it so reported in the draft? Paragraph 3: Line 2 - there is reference to interest groups. Are they stakeholders or actors also? The text is woolly on this. Paragraph 4: Line 3 - There is reference to actors having little or no engagement or even outright rejection to engage. It seems that they should therefore no longer be regarded as "actors" (or stakeholders or interest groups) in the MMSD context, but in some other descriptive category. Line 4 - Suggest insert style of before involvement. Paragraph 5: Line 1 - does surface mean expose? Paragraph 6: Line 1- suggest after challenges: insert the role, evolution and purpose of mineral markets, in order to place in full context the place of minerals in world society

Page 4, Paragraph 1: Last line - making choices - by whom - say so? Paragraph 2: Line 1 - delete see that insert identify how. Line 2 - after whole insert is able to (contribute to). Line 4 - delete if insert The (minerals sector is) essential. Line 5 - after development insert but. Line 6 - delete with insert and to adopt. Paragraph 3:
Second dot point - the word actors is again used, need for harmonisation. Third dot point - refers to all those involved (who are they?) Suggest reword to read ...all involved, to set priorities and ensure that action...

In later pages it is noted that the expression "Actors" is extensively used emphasising the need to clarify and unify the language.

Society of St Columban, Ireland. Prepared by Nostromo Research
also available at www.minesandcommunities.org/Charter/mmsd1.htm

Comments document
(PDF 63KB)

Chamber of Mines, South Africa

Comments document
(PDF 267KB)

Mary Stewart, University of Sydney, Australia

Comments document
(PDF 287KB)

Newmont Mining Corporation

Comments document
(PDF 210KB)

Phillip Crowson, Centre for Energy, Petroleum & Mineral Law & Policy, UK
additional comments

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(PDF KB)

Robert Ayres, INSEAD, France

Comments document
(PDF 36KB)

Freeport-McMoRan Copper & Gold Inc.

Comments document
(PDF 203KB)

International Alert

Comments document
(PDF 203KB)

Prof Anatoly Krivtsov, International Academy of Mineral Resources, Russia

Me and my colleagues from the International Academy of Mineral Resources , a non-governmental organization established 7 years ago in the conditions of new Russia, have reviewed with great interest the “MMSD Draft Report for Comment, 4 March 2002”.

We cannot understand why, but mineral resources of the FSU countries, especially Russia, somehow fell outside the attention of the Draft Report authors. We agree, in the whole, with the design and contents of the Draft Report. However, we believe that the Draft’s effect could be considerably higher if some more items (according to the “Energy and Material Flows” model ) are included into analysis, such as: energy supply to leading metals production; metal consumption in energy production, transmission and use; interrelationship in the system ”production and consumption of energy- production and consumption of metals - job creation - GDP.”

Such approaches are described, particularly, in publications by F.W.Wellmer, Head of Geological Survey of Germany. They are also considered in detail in the following books ( in Russian):

“National mineral security. Introduction to the problem” , by A.I.Krivtsov, B.I.Benevolsky, V.M.Minakov. Editors: A.E.Natalenko, I.F.Migachev. Moscow, TSNIGRI, 2000.

A.I.Krivtsov, “Mineral base at the turn of centuries - retrospectives and forecast”, Ed: I.F.Migachev, Moscow, GEOINFORMMARK, 1999.

A.I.Krivtsov, B.I.Benevolsky, S.S.Vartanyan, “Mineral base of precious and non-ferrous metals by 2025. The world and Russia”, Moscow, TSNIGRI, 1998.

If the managers of the MMSD Project are interested, the members of the International Academy of Mineral Resources could carry out some regional researches on the territory of the Former Soviet Union.

Dr Peter Hans Whitbread-Abrutat, Eden Project, UK

I really have a general comment. The frustration with the minerals industries is that while receiving much public animosity it is the public that ultimately derive greatest benefit from it. There is a need to educate and inform at the most basic level of
engagement the following aspects: what mining is; what it does; why it is important.

Once the public understand these basic concepts they will be more attuned to recognizing best practice. Again those industry players that perform best practice are not duly rewarded in terms of recognition and ultimately market share. I feel that there is therefore a strong necessity for the industry with members of the NGO sector to engage more with the public. There are ways to do this without preaching or spouting doom and gloom. Eden Project a charitable organisation devoted to communicating complex issues relating to sustainable development to the general
public is an incredibly successful venture in Cornwall UK. Organisations like this could be utilised more by the industrial players and the NGO sector. Or at least attempt new methods of public engagement.

William G Prast, Virotec International Limited, UK

Comments document
(PDF 251KB)

Comments received, March 29 - April 5

Norman Jennings, International Labour Office, Switzerland

Page 2-13. Figure 2.7 Employment in the Australian mining industry does not match the text below! Totla employment in mining was about 51,000 (2000) . In 1995 it was about 72,000. If you take the entire industry (coal, metal, quarries, exploration) the figure was about 100,000 in 1990 and 83,000 in 2000. The text has it more or less right.

I despair of much of the data I have read and know a bit about!

Comments document
(PDF 95KB)

Rachman Wiriosudarmo, Ecomine NL for Sustainable Mineral Development, Indonesisa

1. In general I found that the draft is a tremendous collection of the facts and problems of mining practices, but lacks larger scope of policy and strategy. Strategy at global, national and local levels are necessity for improving future mining performance toward sustainable development. The fact is, the Trans National Corporation has multi faces in terms of strategy at global, national and local levels. At the global level, they may show sustainable faces by adopting sustainable policies, but at the local level they keep a conservative and defensive strategy. I would suggest that IIED be more firm and courageous in taking the side of the people's interest rather than trying to be academically independent. The reason for this suggestion is the fact that the meaning of sustainable development is social justice, sustainability and the inclusiveness of mineral development. And that is the peoples interest. Facts and data will not be meaningful without IIED taking a position to penetrate deeper into the problems reflected by facts and data. I understand that one of IIED's policies is not to be subjective, but this principle cannot be extended too far. By putting sustainable development as an objective is subjective, the value of which will depend on what definition IIED is applying to this report. Although the draft report contains detailed facts, data and aspirations from various sources, they may not all be objective. It does not mean that I suggest that these subjective facts are of no value. On the contrary, the subjective information is very important in indicating what has happened behind it.

2. Correction: on page 15-19 (under Indonesia National Baseline Study) please delete academic title 'Dr' following my name, R Wiriosudarmo. Thank you.

Sue Struthers, Skapa Mining Services Ltd, UK

I would like to congratulate MMSD on the Draft Report, which I have finally managed to plough my way through ("ploughing" only because of the length, I actually found it very readable!) I feel that you have covered a huge amount of scope in the report, and the end result is a very balanced and thorough document. I have been teaching and lecturing on issues of Sustainable Development for several years, but I have never come across a more concise, straight forward, and yet complete description of SD! The document is a very important summary of the industry, and gives invaluable facts and figures that are useful to everyone. I feel it should become compulsory reading for mining students everywhere! Despite the reluctance of some stakeholders to contribute to your efforts, you still seem to have covered the issues from all angles. The report illustrates the concerns of most of the interest groups, both real and perceived, and also makes the point that perceived concerns are often just as important as real ones!

My only concern about the report, (and this is from a very personal viewpoint) is the very small, and dismissive, comment on recycling mine waste: "Mine wastes are occasionally seen as a resource and may be suitable as aggregates for road construction and building materials. There are proposals to use them for making concrete. However, their volume is so great it is hard to see more than a small fraction of them being used in this way. They should also be used with care, especially in the construction industry, as contaminants in the waste have sometimes caused long-term problems."

It seems hard that in a 500+ paged document, that that is all that can be contributed about the potential for large volume mine waste recycling! I firmly believe that the only way forward for the mining industry, in order to address many, if not all, of the major environmental and social issues highlighted in the Draft Report, is through the constructive utilisation of mine wastes. There is, and has been in the past, a huge amount of research and development work done on the potential constructive uses for waste rock and mine tailings materials. The opportunities are not only in road construction and building materials, though these avenues have been most successful so far. There are many projects looking at making productive 'topsoil' replacements and growth media out of mine tailings. Waste rock can be used for constructing embankments and ponds for agricultural activities; as sub-base for rail tracks, landing strips and foundations. Tailings are being used to mass produce bricks (as in the Shandong Gold Group in China), as well as coatings, ceramics, glasses and glazes. Where constructive use can be made of the large volume 'by-products' of metal mining, the industry can eliminate the long-term problems of tailings deposition and waste rock dumps - dust, ground- and surface water contamination, potential instability and failures, continuous and expensive monitoring and rehabilitation, and the risk of potential future liabilities. By utilising these materials in other downstream economic activities and industries, the socio-economic issues of mine closure can be alleviated, divisive income imbalances can be reduced, and greater community self-sufficiency and self-reliance encouraged. The utilisation of the whole of the excavated resource, means that a mining operation can instigate much broader, and sustainable, regional development, that will benefit many more people, have far less impact on the environment, and spread the financial benefits of mineral exploitation much further.

I am totally convinced that the constructive use of large volume mine wastes is the single most effective way of addressing many of the mine related issues that you have discussed in the Draft Report. Consequently, I believe that far more emphasis and effort should be placed on research into constructive utilisation of mine wastes, and more priority given to implementing innovative recycling technology. I think that maybe the Final Report could give a little more indication of the potential of 'seeing mine wastes as a resource.'

I sincerely hope that the result of all your efforts, this document and its recommendations, are taken up by the industry and specifically the GMI, and used to make significant progress in integrating mining with sustainable development. Congratulations once again.

Colin Filer, Research School of Pacific & Asian Studies, Australian National University (and MMSD Assurance Group member)

Comments document
(PDF 18KB)