Environmental Impact Assessment - Mining and the Environment: From Ore to Metal - page 78

Companies should expect that there will be differences of opinion between inter-
nal project personnel and external consultants. In particular, company personnel often
believe that adverse impacts are overstated in the EIA. This is natural. However, it is the
EIA practitioner's responsibility to be objective - to tell things the way they are and not
necessarily the way the proponent sees them. This makes for some interesting exchanges
between the company and the environmental consultant as the EIA is being reviewed,
prior to submittal. This process is benei cial for company and consultant alike. For the
company, it raises consciousness and awareness of the environmental issues. For the con-
sultant, it challenges the assessment process and may result in an improved assessment and/
or the formulation of better management measures. It is also inevitable that other stake-
holders will disagree with a variety of assessments in the EIA. This is a natural outcome
of the variety of view-points, perceptions, and prejudices among the stakeholders. The
EIA practitioner needs to be aware of all these view-points and to take them into account.
However they should also realize that it is impossible to produce an EIA that satisi es all
parties. Experienced EIA practitioners feel that they have an appropriately objective bal-
ance when they are criticized by the proponent for overstating adverse impacts while also
being criticized by NGOs for understating adverse impacts or overstating project benei ts.

Experienced EIA practitioners
feel that they have an
appropriately objective balance
when they are criticized by
the proponent for overstating
adverse impacts while also
being criticized by NGOs for
understating adverse impacts or
overstating project benefi ts.

Commence Early

It is important to examine environmental factors at an early stage in mine planning. This
'environmental scoping' exercise is discussed in greater detail in Chapter Eight. At a min-
imum, it is necessary to identify major environmental issues and concerns that have an
important inl uence on the evaluation of the mine. These may range from an issue that
is a primary concern of the host community to an issue that poses a legal barrier, such as
jeopardy of an endangered species; either case may be of sufi cient merit and importance
to affect the mine project's basic planning. Late identii cation of environmental or social
constraints is likely to delay the environmental assessment process. Accordingly, it is com-
mon practice, particularly in unusual projects or those in previously undeveloped regions,
to undertake a 'Fatal Flaw' evaluation, at a very early stage, even before any pre-feasibility
engineering studies are conducted. The purpose of such an evaluation is to identify the
presence of any 'show stoppers' or 'deal breakers' - issues of such overwhelming impor-
tance or concern that they could preclude development. It reduces but does not eliminate,
the risk of the project being stopped at a much later stage as a result of an inability to ade-
quately respond to emerging issues. Of course, what is a 'show stopper' to one company
may not be a deterrent to another, depending on their internal policies and past experi-
ences. For example, occupation of an ore body by artisanal miners, whether legal or other-
wise, may represent a fatal l aw for a large international company, already under i re from
NGOs for alleged human rights abuses, while a smaller, more entrepreneurial company
may feel coni dent of its ability to resolve such land use conl icts.
Early consideration of environmental issues can be expanded to include a detailed inven-
tory of the existing environmental components in the mine vicinity (e.g. air quality, water
quality, and communities), including environmental resources (e.g. wetlands, historic sites,
and endangered species). Such an inventory serves the dual purposes of providing improved
early environmental information to assist the mining company in selecting from proposed
project alternatives, and of providing the existing environmental baseline data set for the
subsequent EIA. Environmental inventories become outdated over time, decreasing their
usefulness for an EIA. The closer in time that an EIA follows environmental data collection,
the less potential there is for problems with data currency and validity.

Late identifi cation of
environmental or social
constraints is likely to delay
the environmental assessment
process.