EIA and Responsible Mining

Back in 2006, representatives of academic, non-governmental, business and other sectors formed the Initiative for Responsible Mining Assurance (IRMA) (http://www.responsiblemining.net/), which aims to establish a system ensuring the inherent development of responsible mining standards. The idea of the initiative is striving to guarantee the application of mining that is responsible towards both the environment and the public. This has to be individually verifiable, render equitable and equal allocation of profits within communities, and address potential negative impacts on the environment, public health, security and culture. IRMA intends to launch the standard for responsible mining in 2018, draft of which can be found on their website (http://www.responsiblemining.net/irma-standard/irma-standard-draft-v2.0/) and is open for comments and recommendations. The standard offers practical criteria for assessing the responsibility of mining to ensure quality assessment of transparency of revenues and expenditures from natural resources, protection of water, atmosphere quality and biodiversity, public health, cultural heritage and all components of the EIA.

EcoRight is following the developments around the new standard and based on that will develop approaches applicable in Armenia. Those approaches will be submitted to public authorities within the frameworks of the development of the Mining Strategy for Armenia and the Extractive Industries Transparency Initiative.

Environmental Impact Assessments (EIA) are a mechanism for the identification of potential negative influence on the environment because of certain economic activities. Mining wastes create more risks in this industry sector for public health and the diversification of the country’s economy, thus making public oversight a necessity. The EIA is a professional/expert process, through which private business and relevant state authorities should comprehensively assess all possible impacts of planned activities on natural components, including the atmosphere, water, land, biodiversity, as well as the impacts on public health, other business activities in the vicinity, and cultural heritage.

This is the mechanism that should be used in practice to assess the ratio of benefits and losses in specific mining projects. In Armenia, this process is carried out with such professional and methodological deficiencies, which provide enough grounds to demand that the government announces a moratorium for new mining projects until all those systemic deficiencies have been properly regulated. New mines are unacceptable in the country also because Armenia does not yet have a mining strategy. That is the fundamental document, which needs to be subjected to a strategic ecological assessment taking into account all socio-economic and cultural components stemming from the context of ecology.

The Republic of Armenia Law on Environmental Impact Assessment and Expertise defines the types of activities subject to EIA, EIA criteria and procedures. EcoRight has been involved in the process of development of this draft law since 2013; however, the final version of the draft was presented to the National Assembly with severe distortions. With the purpose of amending various provisions of that law, EcoRight and its partner organizations appealed to different factions in the parliament as well as international organizations asking to undertake measures towards correcting the distorted provisions in the draft. However, these efforts were only partially successful.

The EIA process should involve a wide range of residents of impacted communities, representatives of academia and civil rights groups in order to be able to assess all risks comprehensively and prevent unreasonable decisions by relevant authorities. This is the document that now lies at the basis of all mining permits, since the EIA is the only procedure that measures the disproportionate influences of mining projects on the environment. In the cases of harmful economic projects where private interests overtake the public good, the legitimacy and the factual basis of the EIA expert conclusion can be disputed through legal procedures.