To Teresa Ribera Spanish minister for the ecological transition and the demographic challenge &

Permanent Representatives of the member States of the Council of Europe

To the President of the European Commission & the College of Commissioners

via email

Dear President Metsola and Members of the ITRE Committee,

Dear Minister Ribera and Permanent Representatives of the member States of the Council of Europe,

Dear President von der Leyen and Commissioners,

The signatories of this letter are grassroots and civil society organizations, movements, recognized Indigenous Peoples in the European Union and beyond, local community groups, academics and experts. We have direct experience in assessing the true and often hidden costs of mining including its impacts on people, the environment, good governance and the rule of law.

Due to the serious shortcomings outlined below, we request the withdrawal of the Critical Raw Materials Act (CRMA). We reject the misleading policies at its base including its failure to understand the implications of corruption, the absence of communities’ Right to Say ‘No’ and of rights of nature as well as its legitimisation and support of manipulative “social acceptance” and mining certification schemes that breach fundamental citizens’ rights and research ethics.

Instead we demand environmental and climate policies that reduce raw materials demand, energy use and  faulty land management schemes. Increasing mining by breaching fundamental rights, even for the ‘environment’ or to ‘mitigate climate change’, will only worsen climate and ecological conditions and social conflict.

The Act does not address corruption, which is known to be endemic to mining

Across the world, undue influence of mining led to an erosion of the quality of governance; spreading corruption and accentuating local power asymmetries. Governments wrongly merge the interests of mining corporations with those of the general public. Meanwhile this forfeits real mitigation pathways for climate change and the environment.

The recent news in Portugal, where  several companies, high-ranking politicians, and public entities are being investigated for alleged corruption related to the attribution of two lithium concessions, led to the resignation of the Prime Minister António Costa. Savannah Resources and Lusorecursos, the owners of the two concessions, will no longer participate in the Raw Materials Week 2023 (RMW).^[i] The investigation has brought political uncertainty and instability to the country and illustrates that Europe is not immune to the all too present connection between mining and corruption. This is not an exception – across the EU there exist countless cases of corruption and misconduct related to mining, even if they have rarely been brought to justice or received due public attention.^[ii]

Purporting mining as a ‘climate solution’ and mining companies as ‘climate champions’, the CRMA will waterdown laws, fast track procedures and inject billions of taxpayers euros into speculative and reckless mining. For so-called ‘strategic’ raw materials (copper, lithium, nickel etc.), the CRMA foresees fast permitting by limiting public consultation periods and shortening the time citizens have for a fair trial to defend their rights.

This runs against human and environmental rights such as the right to public participation in decision making on environmental matters and the right to access justice. Other fundamental rights, including the right to housing, are breached in areas where new mines involve forced evictions, while eroding our food sovereignty and the rights of farmers, peasants and other people working in rural areas.

The CRMA will not only extend bad governance across Europe, but exacerbate it globally by allowing the designation of strategic projects outside of the EU, including on Indigenous lands. EU institutions have refused to modify the CRMA^[iii] to include legally binding Free Prior and Informed Consent mechanisms. This is in breach of international conventions on Indigenous Rights. The Sámi people of the Sápmi region in Norway, Sweden, Finland, and Russia are recognized Indigenous Peoples in the European Union, and mining causes irreparable damage to their way of life.^[iv] We need regulations that offer legally binding protection to Indigenous Nations and legalize the Right to Say ‘No’. We do not need tokenistic advisory roles for communities impacted by mining inside and outside the EU’s borders. 

A “Social license” to harm, destroy and violate European fundamental rights and ethics

There is nothing socially acceptable about the scramble for raw materials. Many of us are directly affected by environmental and social non-compliance of the extractive sector. We have never given any company the permission to extract or explore in our communities or to transform our lands into sacrifice zones in the name of perpetual economic growth.

We reject policy proposals that seek to manage resistance through “facilitat[ing] public acceptance” (CRMA) or by industry-coined procedures to gain a social license to operate (SLO). If not backed by Free, Prior and Informed Consent dialogue at community level, we consider “social licensing” and any related influence on public perceptions by public authorities or corporations, a procedural euphemism for social engineering and ‘soft’ counter-insurgency. They only serve to brush off legitimate objections to instances of corruption, or projects that fail to comply with environmental and labor laws. A subgroup on public acceptance that is part of the CRMA’s Critical Raw Materials Board is insufficient. It does not resolve the violation of citizens’ rights impacted by Strategic Projects.

The Commission’s goal of “[c]hanging public opposition to passive tolerance or active support” runs against European ideals of democratic participation.^[v] It will erode the public’s trust in the European project by diminishing efforts made toward a just and sustainable future for all. We refuse a law that promotes passive tolerance to socio-environmental harm, corruption and labor abuse, which existing public funding schemes are already reinforcing. The Horizon 2020 (2014-2020) and Horizon Europe (2021-2027) programmes contain at least 25 projects with a total budget of €181M which include deliverables that seek to organize public acceptance for extractive projects in member states and beyond.^[vi] These misleading publicly funded initiatives refuse scrutiny by the very public they intend to influence. There is a need for an inquiry into the Commission’s research requirement to “impact[ing] public awareness and acceptance and trust in mining operation.”^[vii] The signatories of this letter consider the Commission’s funding and the participation of public authorities’ in such applied research an illicit interference on the opinion of individuals, and a violation of article 11, section 1, of the Charter of Fundamental Rights of the European Union (CFR) and article 10, section 1, of the European Convention on Human Rights (ECHR). Furthermore, the ethics management and board of at least one Horizon Europe project does not fulfill the ethical standards set out for the Horizon Europe Framework Programme.^[viii] Thus, the signatories ask the Commission for an independent assessment of the 25 projects.

The EU invested millions of taxpayer euros into research on how to generate “social acceptability” for mining operations, some of which proved to be involved in criminal activities. For example, in 2016 three executives from the Cobre Las Cruces copper mine in Spain were sentenced to a year in prison and fined 293,000 euro for environmental crimes after polluting Seville’s aquifer with arsenic.^[ix] Since then the company has been repeatedly fined for damages to water bodies, yet it was awarded a 26,7 million euro subsidy and has benefited from half a dozen Research Projects under the Framework Programmes worth millions of euros.^[x]

Social acceptability efforts violate democratic regulations and due process. They generate misinformation, and obstruct transparency. They hinder the possibility of legal action against non-compliance with environmental, administrative or labor laws. And social acceptability efforts advance corruption.

Europe’s mining regulations are dangerously obsolete

With statements such as mining “in the EU is subject to the highest environmental and social standards worldwide,”^[xi] EU institutions like to assure citizens that its mining legislation is the most advanced in the world. This is false.

Tailing dams illegal in Brazil, Chile, China, Ecuador or Peru are being advanced as ‘best available techniques’ in Spain and Portugal.^[xii] For example, the Touro copper proposal in Spain plans an 81-meter-high dam just 200 meters upstream from the village of Arinteiro. While Brazil and Ecuador prohibit tailing dams less than 10 km upstream from potentially affected communities and China prohibits them at a distance of less than 1 km, EU legislation imposes no restrictions. In Spain, 99% of tailings dams are built following upstream design,^[xiii] the most dangerous construction method – banned in Brazil, Chile, Ecuador or Peru.

Industry-driven negligence combined with policy makers’ misjudgement of mining operations leads to  obsolete regulations and a reluctance to implement ‘Best Available Technologies’ (BAT). This is extremely dangerous. This even more so as new ‘low-cost’ mining projects seek to develop large mines with lower ore grades to mine conventional metal (e.g. copper) as well as minerals such as lithium. They will create waste facilities of unseen dimensions that in return come with significant risks. Mining lower ore grades doubled the last decade, while costs and quantities of mining waste increased exponentially.^[xiv]

Europe has seen too many major mine accidents.^[xv] “Never again,” said Margot Wallström, the EU Commissioner after the Baia Mare tailing dam failure. Yet the sheer scope and pace of new mines, plus the untested nature of the accelerated permitting regime can only lead to accidents. For example, the recently approved extension of the Rio Tinto tailings dam in western Andalucia,  Spain, allows the storage of over 360 million tons of highly toxic sludge. In comparison, the 1998 Aznalcóllar disaster involved the release of ‘only’ 6 million tons. We refuse to accept a law that we know will give rise to more accidents with incalculable consequences in terms of human lives and environmental damage.

We can’t mine our way out of a perpetual growth syndrome

European policymakers have bought into the delusion that more mining will mitigate ecological and climate catastrophe. Europe’s target is to mine in the next 30 years as much copper as has been mined in the past 7,000 years.^[xvi] It is to completely deplete known global reserves for nickel, cobalt, lithium and other minerals (under the premise that reserves will continue to expand indefinitely via deep-sea and space mining). Scientific consensus against deep sea mining has also shown the irreversible damage to ecosystems, potential toxic releases, biodiversity loss, and the unknown consequences on ocean health.^[xvii]

Yet, as ore grades dwindle^[xviii] (for example, average grades in copper mines has gone from 1.8% in 1930 to 0.5% today), newly proposed mines create greater environmental impacts^[xix], larger volumes of waste, larger energy demand and rising emissions, under the constraints of minimum low-cost safety standards. That is the opposite of ‘green.’

To meet Europe’s target, its mineral demand forecasts are enormous: For solar and wind technologies demand for lithium, dysprosium, cobalt, and neodymium are to be up to 600% in 2030 and up to 1500% in 2050 from 2018 levels. Batteries for electric vehicles and renewables will drive 2030 demand for lithium up by 1800% and cobalt by 500%, and drive 2050 demand up by almost 6000% and 1500%, respectively.^[xx] These numbers do not take into account so-called ‘smart technologies,´other individualized electric mobility devices (e.g. scooters, bikes, etc.), energy infrastructure (transformers, HVPLs, etc.) and, in the end, relies on significant data gaps.^[xxi]

According to Simon P. Michaux, of the Finnish Geological Survey (GTK) “a case can be made that not only is current mineral production not high enough to supply the projected quantity demand for metals, but current global reserves are not large enough to meet long term consumption targets.”^[xxii] All this happens alongside new additions of low-carbon energy sources which are being built alongside already existing fossil fuel and nuclear energy sources on the European energy grid. European environmental policy, moreover, is furthering energy market privatization and entrenching the existing trajectory of uncontrollable energy consumption.^[xxiii]European environmental and climate policy is deeply flawed and leading to worsening ecological conditions. We need legal reforms based on energy and material reduction, not a law that feeds into the hands of the mining lobby. 

EU treaties require that all EU decisions are taken as openly and as closely to the citizens as possible. The CRMA was intended “to collect evidence and views from a broad range of stakeholders and citizens.” But given that it was rushed through at great speed by DG GROW, the documents put to public consultation were only available in French, German, and English languages, excluding significant segments of Europe’s population.^[xxiv] This is a violation of our right to access to information and to participate in decision making in environmental matters enshrined by the Aarhus Convention to which the European Union is a signatory. We will take all legal steps to ensure redress because with the CRMA, EU institutions have again put the cart before the horse.^[xxv] We refuse another law that wants short term profit to the detriment of people and the planet. It is for all these legal and ethical violations that we request the withdrawal of the Critical Raw Materials Act (CRMA).

We look forward to reading your reply and remain

Yours sincerely,

Grupo de Geopolítica y Bienes Comunes, Buenos Aires, Argentina

“EcoLur” Informational NGO, Yerevan, Armenia

Armenian Environmental Front

Right Side Human Rights Defender NGO, Yerevan Armenia

Attac Austria, Austria

Degrowth Vienna, Austria

CATAPA vzw, Ghent, Belgium

Center for Civil Society Promotion/ Centar za promociju civilnog društva, Bosnia

Eko BiH network, BiH

Eko Forum Zenica, Bosnia 

Ekološko udruženje “OZRENSKI STUDENAC” Sočkovac

Centar za životnu sredinu/Center for Environment, Bosnia

Udruženje “Centar za mirovno obrazovanje” / Center for Peace Education, Bosnia 

Green Team, Bosnia 

NGG Park Prirode Trstionica i Boriva, Kakanj, Bosnia 

Udruženje građana Fojničani Maglaj, Bosnia 

Foundation Atelier for Community Transformation – ACT/ Fondacija Atelje za društvene promjene – ACT, Bosnia 

NGG “Stop izgradnji MHE na Kasindolskoj rijeci” Bosnia

Observatorio Plurinacional de Salares Andinos, Chile

Fundación Tantí, Chile

Fundación Chile Sin Ecocidio, Chile

Fundación Protege Los Molles, Chile

Tasaarengu Eesti Organisatsioon, Estonia

WeMove Europe, Europe

GEN Europe, Europe

Saimaa ilman kaivoksia ry, Finland

Ei kaivoksia Suomen käsivarteen ry, Finland

Ei kaivosta Pyhä-Luostolle, Finland

Kansalaisten kaivosvaltuuskunta – MiningWatch Finland ry, Finland

Kaivoskriittinen kansanliike, Finland

Sokli erämaana ry, Finland

Sompion Luonnonystävät ry (The Finnish Association for Nature Conservation – local association for Savukoski-Sodankylä areas), Finland

Ylitornion – Pellon Luonto ry (local group of The Finnish Association for Nature Conservation), Finland

Vuohču Sámiid Searvi rs, Finland

Osikonmäen kyläyhdistys ry, Finland

Kolkontaipaleen kyläyhdistys ry, Finland

The Global Extractivisms and Alternatives Initiative (EXALT), Finland

Sámi Bálgosat rs (Association of Saami Reindeer Herding Co-operatives), Finland

Rajat Lapin Kaivoksille ry (Limits to Mines in Lapland Registered Association), Finland

Ass. Risteco – La Ville qui Mange, France

Association of Ethical Shareholders Germany

Hellenic Mining Watch, Greece

Observatorio de Industrias Extractivas (OIEGT), Guatemala

aHang Platform, Hungary

Védegylet Egyesület/Protect the Future Association, Hungary

Clean Air Action Group, Hungary

Ökotárs-Hungarian Environmental Partnership Foundation, Hungary

International University College of Turin, Italy

Justice Peace and Integrity of Creation Commission Union of Superiors General and International Union of Superiors General, Italy
Associação Cultural Amigos da Serra da Estrela – ASE, Central Region, Portugal
Associação Montalegre Com Vida, North Region, Portugal

Centro de Ecologia, Recuperação e Vigilância de Animais Selvagens (CERVAS) / Associação ALDEIA, Central Region, Portugal

Movimento Seixoso-Vieiros: Lítio Não, North Region, Portugal

UDCB – Unidos em Defesa de Covas do Barroso, North Region, Portugal

Espaço A SACHOLA – Covas do Barroso, North Region, Portugal

Rede Minas Não, Portugal

Extinction Rebellion Guimarães, North Region, Portugal

Chaves Comunitária, North Region, Portugal

Grupo de Investigação Territorial (GIT), Portugal

Associação Povo e Natureza do Barroso – PNB, North Region, Portugal

AVE – Associação Vimaranense para a Ecologia, North Region, Portugal

Movimento SOS Serra d’Arga, North Region, Portugal

Movimento Contra Mineração Penalva do Castelo, Mangualde e Satão, Central Region, Portugal

Rede para o Decrescimento em Portugal, Portugal

SOS – Serra da Cabreira, North Region, Portugal

IRIS, Associação Nacional de Ambiente, Portugal

Sciaena – Oceano # Conservação # Sensibilização, Portugal

Movimento Não às Minas – Montalegre, North Region, Portugal

Movimento ContraMineração Beira Serra, Central Region, Portugal

Movimento Amarante diz não à exploração de lítio Seixoso-Vieiros, North Region, Portugal

FAPAS – Associação Portuguesa para a Conservação da Biodiversidade, Portugal

Grupo pela Preservação da Serra da Argemela (GPSA), Centro Region, Portugal

URZE – Associação Florestal da Encosta da Serra da Estrela, Portugal

Bravo Mundo – Citizens Movement for a Safer Future, Central Region, Portugal

Nao as Minas Beiras – Citizens Movement, Central Region, Portugal

MiningWatch Portugal, Portugal

Asociația pentru protejarea Munților Apuseni-Rovina, Vest Region, România

Independent Centre for the Development of Environmental Resources, Vest Region, Romania

Ecou Rovina Bucureșci, București – Ilfov Region, România

Mining Watch Romania, Romania

Roșia Montană Community, Centru Region, România

Cărturești Foundation, Bucharest, România

Street Delivery, Romania

Comunitatea Declic, România

Asociatia turistica sportiva civica si ecologista “Clubul de Cicloturism NAPOCA” (CCN) – România

Asociația HaicuBicla, București, România

Acción Océanos, Spain

Alconchel sin Minas, Extremadura, Spain

Amigos de la Tierra, Spain

Asociación Alarma Terra de Montes, Galicia, Spain

Asociación Cultural Valle el Saltador, Andalucía, Spain

Asociación de Defensa Ambiental Salvemos Cabana, Galicia, Spain

Asociación Tralapena, Galicia, Spain

Campiña Sur sin Megaminas, Extremadura, Spain

Ecologistas en Acción, Spain

Fundação Montescola, Galicia, Spain

No a la mina de Gilico, Murcia, Spain

No a la mina en la Sierra de Yemas, Castilla y León, Spain

Plataforma Bierzo Aire Limpio, Castilla y León, Spain

Plataforma Cívica Alcalaboza Viva, Andalucía, Spain

Plataforma Comarca de Olivenza sin Minas, Extremadura, Spain

Plataforma en Defensa da Ría de Muros e Noia – PLADEMAR, Spain

Plataforma Mina Touro – O Pino Non, Galicia, Spain

Plataforma de afectados por la minería de Teruel, Aragón, Spain

Plataforma de Afectados por Metales Pesados de la Sierra Minera, Murcia, Spain

Plataforma de afectados por las explotaciones mineras de Peña Zafra, Balonga y Quibas, Murcia, Spain

Plataforma No a la Mina de Cañaveral, Extremadura, Spain

Plataforma No a la Mina en el Valle del Corneja, Castilla y León, Spain

Plataforma Oro No, Principado de Asturias, Spain

Plataforma para la defensa del Valle de Lucainena, Andalucía, Spain

Plataforma Rural Sostenible, Castilla y León, Spain

Plataforma Salvemos Esparteros, Andalucía, Spain

Plataforma Salvemos la Montaña de Cáceres, Extremadura, Spain

Plataforma Salvemos las Villuercas, Cáceres, Spain

Plataforma Sí a la Tierra Viva, Castilla-La Mancha, Spain

Sierra de Gata Viva, Cáceres, Spain

Sindicato Labrego Galego, Galicia, Spain

SOS Suído-Seixo, Galicia, Spain

Marš sa Drine, Serbia

Udruženje za zaštitu životne sredine (AEP), Serbia

Mlavska vojska, Petrovac na Mlavi, Serbia

Čuvari Homolja, Žagubica, Serbia

Pokret Odbranimo šume Fruške gore, Fruška Gora, Serbia

Udruženje za zaštitu šuma, Novi Sad, Serbia

Ne dam, Ne dau, Majdanpek, Serbia

Borani se pitaju, Bor, Serbia

Extinction rebellion Srbija, Serbia

Kreni-Promeni, Serbia

PRVI PRVI NA SKALI, Kragujevac, Serbia

Earth Thrive Serbia/UK

Polekol, Serbia

Bravo! Novi Sad, Serbia

Kremnica nad zlato, Kremnica beyond gold, Slovakia

Urán Košice STOP, Slovakia

Društvo Sončni grič, Slovenia

Skiftet, Sweden

Kazdagi Association for The Protection of Natural and Cultural Assets, Türkiye

Climate Justice Coalition, Türkiye

Kazma Birak Campaign Coordination Committee, Türkiye

En Ecocide, Türkiye

Ukrainian Nature Conservation Group, Ukraine

Free Svydovets, Ukraine

The Corner House, United Kingdom

Fuel Poverty Action, United Kingdom

Socal Friends the World Social Forum, USA

Urgent Action Fund for Feminist Activism, USA

Prof. Bram Büscher, Wageningen University, Netherlands

Prof. dr Biljana Stojković, Faculty of Biology, Univerzitet u Beogradu, Belgrade, Serbia

Prof. dr Ljiljana Tomović, Faculty of Biology,, Univerzitet u Beogradu, Belgrade, Serbia

Prof. Dr. Bogdan Šolaja, Serbian Academy of Sciences and Arts, Belgrade, Serbia

Prof. Dr. Branimir Grgur, Faculty of Technology and Metallurgy University of Belgrade, Serbia

Prof. Dr. Giuseppe Mastruzzo, International University College of Turin, Italy

Prof. Dr. Lidija Djokic, University of Belgrade, Serbia

Prof. Dr. Miomir Kostic, University of Belgrade, Serbia (retired)

Prof. Dr. Ratko Ristić, University of Belgrade, Serbia

Prof. Filipe Calvão, Geneva Graduate Institute, Switzerland

Prof. Giuseppe Mastruzzo, International University College of Torino, Itália

Prof. Maja van der Velden, University of Oslo, Norway

Prof. Markus Kröger, University of Helsinki, Finland

Prof. Maya van der Velden,Universidade de Oslo, Norway

Prof. Ugo Mattei, University of Turin, Italy

Prof. Zoran Radovanović, Faculty of Medicine, Belgrade, Serbia (retired)

Prof. Christopher Chase-Dunn,  Distinguished Professor of the Graduate Division, University of California-Riverside, USA

Dr. Magdalena Taube, Macromedia University Berlin; co-founder, Berliner Gazette, Germany

Prof. Ana Vitória Alkmim, Interdisciplinary Centre of Social Sciences (CICS.NOVA), Lisbon, Portugal

Dr. (Agr. For. Sci.) Helvi Heinonen-Tanski, Finland

Dr. Adrian Lahoud, Royal College of Art, London, United Kingdom

Dr. Al Gedicks, University of Wisconsin-La Crosse, Wisconsin, USA

Dr. Alevgul H. Sorman, Basque Centre for Climate Change (BC3), Spain

Dr. Alexander Dunlap, Boston University, USA & University of Helsinki, Finland

Dr. Alison Laurie Neilson, Interdisciplinary Centre for Social Sciences, NOVA University, Lisbon, Portugal

Dr. Astrid Ulloa, Universidad Nacional de Colombia

Dr. Carlos Tornel, Independent Scholar, México

Dr. Claudio Cattaneo, Masaryk University, Brno

Dr. Diego Andreucci, University of Barcelona, Spain

Dr. Dragana Đorđević, ICT Metallurgy -, University of Belgrade, Serbia

Dr. Dražen B. Zimonjić, Member, Serbian Academy of Sciences and Arts, Belgrade, Serbia

Dr. Ecehan Balta, Independent Researcher, Turkey

Dr. Elliot Honeybun-Arnolda, University of East Anglia, United Kingdom

Dr. Eric Bettis, Wayne State University, United States

Dr. Filip Alexandrescu, Research Institute for Quality of Life, Romania

Dr. Filka Sekulova, Universitat Oberta de Catalunya, Spain

Dr. Gabriel Girigan, “Lucian Blaga” University of Sibiu, România

Dr. Godofredo Pereira, Royal College of Art, London, United Kingdom

Dr. Gustavo García-López, Center for Social Studies, University of Coimbra, Portugal

Dr. Hanne Cottyn, Ghent University, Belgium

Dr. Hannu L. Suominen, Marine Microbiologist, Finland

Dr. Hans Eickhoff, Interdisciplinary Centre of Social Sciences (CICS.NOVA), Lisbon, Portugal

Dr. Ioana Bunescu, “Lucian Blaga” University of Sibiu, Romania

Dr. Irina Velicu, Center for Social Studies, University of Coimbra, Portugal

Dr. Jari Natunen, PhD Biochemistry, chair of MiningWatch Finland

Dr. Jean Leon Boucher, Senior Researcher, The James Hutton Institute, Scotland

Dr. Joám Evans, Åbo Akademi University, Finland

Dr. Jonas Van Vossole, Ecology and Society Lab, Center for Social Studies, Coimbra University, Portugal

Dr. Jonathan Kishen Gamu, University of Sheffield, United Kingdom

Dr. Ksenija Hanacek, Autonomous University of Barcelona, Spain & University of Helsinki, Finland

Dr. Louise Guibrunet, National Autonomous University of Mexico, Mexico

Dr. Maarit Laihonen, University of Eastern Finland, Finland

Dr. Marcin Zaród, SWPS University Warsaw, Poland

Dr. Maria Elena Indelicato, Center for Social Studies, University of Coimbra, Portugal

Dr. Mariana Walter, UAB, Spain

Dr. Marianne Juntunen, PhD Biochemistry,  MSc Tech, Finland

Dr. Mark Levene, Emeritus fellow, University of Southampton, United Kingdom.

Dr. Marta Conde, Autonomous University of Barcelona, Spain

Dr. Mike Hannis, Bath Spa University, United Kingdom

Dr. Nenad M. Kostić, retired professor at Iowa State University &  TAMUC-Commerce, USA

Dr. Paul Hodge, University of Newcastle, Australia

Dr. Paula Sequeiros, Centre for Social Studies, University of Coimbra, Portugal

Dr. Renata Pacheco, University of Lisbon, Portugal.

Dr. Roberto Cantoni, Universitat Autònoma de Barcelona, Spain

Dr. Sheila Holz, Center for Social Studies, University of Coimbra, Portugal

Dr. Silvia Maeso, Centre for Social Studies, University of Coimbra, Portugal

Dr. Stefania Barca, University of Santiago de Compostela, Spain

Dr. Steven H. Emerman, Malach Consulting, USA

Dr. Susanna Myllylä, Associate Professor, University of Eastern Finland, Finland

Dr. Susanne Hofmann, Visiting Fellow, London School of Economics, United Kingdom

Dr. Tarja Richard, Director for Managing Authority, Finland

Dr. Valer Simion Cosma, ”Lucian Blaga” University of Sibiu, România

Dr. Laura Calvet Mir, Universitat Autònoma de Barcelona, Spain.

Dr. Beyza Üstün, Turkey

Dr. Will Lock, University of Sussex, United Kingdom

Dr. Johannes M. Waldmüller, University of Vienna and Climate Change Advisor, Brot für die Welt/Diakonie Austria

Dr. José María Vallet García, Finnish Geospatial Research Institute, National Land Survey of Finland

Alessandro Morosin, Assistant Professor of Sociology & Criminology, University of La Verne California, USA

Dr Svjetlana Nedimović, editor, Riječ i djelo, Bosnia and Herzegovina

Laura Calvet-Mir, PhD, Universitat Autònoma de Barcelona, Spain.

Irina Castro, Centre for Social Studies, Portugal

Josephine Becker, Researcher, Universidade de Vigo, Spain

V’cenza Cirefice, PhD researcher, Geography Department, University of Galway, Ireland

Krystian Woznicki, author, editor, co-founder, Berliner Gazette, Germany

Joana Sousa, PhD, researcher, Centre for Social Studies, Univ Coimbra, Portugal 

Joao Prates Ruivo, Associate Lecturer in Environmental Architecture, Royal College of Art, UK

Isabel Ferreira, PhD, researcher, Centre for Social Studies, University of Coimbra, Portugal 

Lúcia Fernandes, PhD, researcher, Centre for Social Studies, University of Coimbra, ««Portugal 

Antonio del Giudice, Associate Lecturer, School of Architecture, Royal College of Art, UK

Pablo Dominguez, Senior Researcher at the Centre National de la Recherche Scientifique, France.

PD Dr. Heike Hübener, University Gießen, Germany

Professor John Barry, Queen’s University Belfast

Professor Vesa Puuronen, University of Oulu, Finland

André Pereira, PhD candidate, University of Lisbon, Portugal

Caroline Seagle, PhD Candidate, Department of Anthropology, McGill University, Montreal, Canada

Ciarán Ó Briain, Independent Scholar / PhD Candidate, Ireland

Cristiano Pereira, PhD Candidate, ISCTE-IUL, Portugal

Elena Gálvez, PhD Candidate, University of Coimbra, Portugal

Ernesto Deus, PhD.,Centre for Social Studies, University of Coimbra, Portugal

Federico Demaria, Associate Professor in ecological economics, University of Barcelona, Spain

Guilherme Castelbranco de Guimarães Serôdio, ISCTE-IUL, Portugal

Helena Sabino Antunes, PhD Candidate, Universidade de Salamanca, Spain

Hestia Delibas, PhD candidate, Center for Social Studies, University of Coimbra, Portugal

İlksen Dincer Bas, End Ecocide Türkiye, Türkiye

Ioana Savin, postdoc researcher, Lucian Blaga University of Sibiu

Jesse Segura, PhD candidate, University Autonoma de Barcelona, Spain

Joana Sá Couto, PhD Candidate, University of Lisbon, Portugal.

Kaya Schwemmlein, PhD candidate, University of Lisbon, Portugal

Line Algoed, PhD Researcher, Vrije Universiteit Brussel, Belgium

M.Sc. Geotechnical Engineer, Peter W. Brandt, Finland

Maria João Horta Parreira, CICS.NOVA, FCSH-NOVA, Portugal

Mariana Riquito, PhD Candidate in Social Studies, University of Amsterdam, Netherlands

Michiel Köhne, Wageningen University, Netherlands

Mikuláš Černík, PhD candidate, Department of Environmental Studies, Masaryk University, Cz Rep

MSc Chemical Engineering, Leif Ramm-Schmidt, Finland

Niina Helistö, Surveyor, former mine supervisor, founder of Rajat Lapin kaivoksille ry, Finland

Pedro Fidalgo, PhD Candidate, Centre for Social Studies University of Coimbra, Portugal

Ramón Balcázar Morales, PhD Candidate in Rural Development, UAM Mexico

Rodolfo Pezzi, PhD candidate, Trinity College Dublin, Ireland

Ruta Śpiewak, Assistant Professor, Polish Academy of Sciences, Warsaw, Poland

Tiago Patatas, PhD Candidate in Architecture Research, Royal College of Art, United Kingdo

Vera Ferreira, PhD Candidate, University of Lisbon, Portugal

Constantina Theodorou, architect- PhD candidate NTUA, Greece

Giorgio Pirina, researcher, Ca’ Foscari University of Venice, Italy

Giada Coleandro, PhD candidate, University of Bologna

Luca Onesti, PHD candidate, University of Lisbon, Portugal 

Rubén Vezzoni, Doctoral Reseacher, University of Helsinki, Finland

Christina Pinell, M.Sc. (Tech), Finnish Geospatial Research Institute, National Land Survey of Finland.

ENDNOTES

^[i] Information supplied by DG GROW 09-11-2023. Already in a 2020 complaint statement on the Horizon 2020 project MIREU, the signatory “Não às Minas Montalegre” from Portugal had informed Commission’s DG GROW on the questionable business practices of Lusorecursos. With the recent corruption scandal in Portugal, the company was, including their facilitators Iberian Sustainable Mining Cluster (ISMC) and Cluster Portugal Mineral Resources (ACPMR), excluded from the Horizon Europe funding application “Li4Life”. Despite the Portuguese Public Prosecutors search warrant equally targeting the directors of the mining authority DGEG  on the grounds of “illegitimate benefits” for the involved companies, the Commission upholds its participation in the RMW.

^[ii] Examples include the 2018 Borba tragedy in Portugal, with 5 casualties, the arrest of public officials in connection to the Orivesi mine owned by Dragon Mining in Finland, or the ongoing prosecution of 16 mining officials in connection with the reopening of the Aznalcóllar mine in Spain. In Spain alone, the Iberian Mining Observatory (www.minob.org) has documented more than 30 cases of corruption and administrative misconduct connected to mines while the European Commission itself is facing an ongoing investigation by the European Ombudsman on the use of Horizon funds in the illegal operation of the San Finx mine.

^[iii] EEB https://eeb.org/critical-raw-materials-regulation-vote/

^[iv] Contrary to Norway, Germany, Spain, Luxembourg, Netherlands, and Denmark, no host member state has so far ratified the Indigenous and Tribal Peoples Convention (ILO 169). As part of the letter’s signatories the Sámi stress: the loss of lands impact reindeer herding, local economy, Sámi culture, health, and well-being. Sámi traditions and culture will vanish if reindeer herding disappears. The European project steered by the Commission must recognize and protect the rights of the indigenous Sámi people to their lands that they have traditionally owned, occupied, and used, including those to which they have had access for their subsistence and traditional activities.

^[v] European Commission’s 3rd EU Raw Materials Scoreboard

^[vi] AGEMERA, BIORECOVER, CROCODILE, ENICON, EXCEED, GREENPEG, illuMINEation, INFACT, ION4RAW, ISAAC, MADITRACE, MIREU, NEMO, NEXT, PACIFIC, RAWMINA, RIA CICERO, S34I, SecREEts, SEMACRET, SOLCRIMET, SUMEX, TARANTULA, VAMOS, VECTOR; references at https://docs.google.com/spreadsheets/d/1BKz2hMNSg1gwApu5D27u0Inv0mbE-yhWGMPphG3eyVc/edit?usp=sharing

^[vii] Of the 25 research consortia in question, 15 have, backed by the Commission’s managing agencies ERC-EA, EASME, and HaDEA, refused to make their Grant Agreements, and parts on how they intend to shape the public’s perception, available to interested civil society actors, invoking “commercial secrets” and “intellectual property” that allegedly outweigh the public’s interest (AGEMERA, BIORECOVER, EXCEED, GREENPEG, illuMINEation, MIREU, NEMO, NEXT, RAWMINA, SecREEts SEMACRET, SOLCRIMET, SUMEX, TARANTULA,VECTOR). // EASME Head of Raw Materials Sector Marcin Sadowski at the “Social Acceptance in the Raw Material Sector” workshop 2018: “projects funded under Horizon 2020 are expected to address […] impacting public awareness and acceptance and trust in mining operation.” // HaDEA project advisor Véronique Woulé Ebongué at Raw Materials Week 2019: “actions responding to 2018-2020 calls are requested to […] improve public awareness, acceptance and trust’.”

^[viii] For the Horizon Europe project VECTOR allegations including negligence of, are: local ethics evaluation, research, and good participatory practice with feedback given in the project’s host countries (Germany, Serbia, Ireland), as recommended by the mitigation requirements of the Global Code of Conduct for Research in Resource-Poor Settings (see §1, §2, §3, §4, §8, §9, §10). At least in Serbia, §21 was violated through a VECTOR member not disclosing the intent and scope of contacts made with local communities. The use of machine learning to identify favorable areas for extractive activities in Europe and the non-involvement of human rights experts and independent advisors may be in violation of the Guidance note on Potential misuse of research, as VECTOR’s activities involve minority and vulnerable groups and it develops social and behavioral profiling technologies that could be misused to stigmatize, discriminate against, harass or intimidate people. Last but not least, all 4 members of the VECTOR’s ethics management and advisory board are not free from conflict of interest in informing an interdisciplinary raw materials project on public acceptance and mining conflicts: At least two advisors have or still serve as corporate defenders in various high-profile fraud, bribery and corruption cases, e.g. for Eurasian Natural Resources Corporation (Kazakhstan, Africa), Rio Tinto (Simandou mine, Guinea), Alstom (Tunisia), and Atalaya Mining Plc (Spain). On one advisor’s own report and, apart from a work history with the VECTOR partner and mining consultancy Satarla Ltd, he was, in the early 2000s, “buying dynamite from a corner shop [in Potosi, Bolivia] to hand it as a present to artisanal silver miners”. 3rd advisor “offers to assist companies earn and retain […] approval from the communities” through his own advisory firm, having published on “Earning the Social License” for the Dingleton resettlement project (co-authorship with a Anglo American employee), a socio-environmental conflict around the South African Sishen opencast mine, owned by Kumba Iron Ore. The 4th member, long-term servant of the French military forces, including during the French counter-insurgency operations Serval and Barkhane in Mali, publishes on conflict mitigation and resolution operations, including how the armed conflict outcomes and use of technology in modern warfare can “be employed in other missions … such as pacification operations”, e.g. French Yellow Vests Protests. Sources available, please contact mineria@ecologistasenaccion.org.

^[ix] https://euobserver.com/green-economy/157619

^[x] These programs include  INFACT, NEMO, RAWMINA, INTMET and BioMOre, many of which carry a “social license” component.

^[xi] https://www.europarl.europa.eu/doceo/document/TA-9-2021-0468_EN.html

^[xii] For example, the Touro copper proposal in Spain plans an 81-meter-high dam just 200 meters upstream from the village of Arinteiro. While Brazil and Ecuador prohibit tailing dams less than 10 km upstream from potentially affected communities and China prohibits them at a distance of less than 1 km, EU legislation imposes no restrictions.

^[xiii] https://www.europarl.europa.eu/cmsdata/243324/Hearing%2002.12.2021%20testimony%20Emerman.pdf

^[xiv] The signatories consider mining waste, the extractive waste directive and related BAT norms as insufficient. Pressure due to fast-tracked permitting, and the reversal of evidence in favor of corporate misconduct in European regulations, including the CRMA, is worsening socioecological conditions in Europe and beyond. 

^[xv] Certej 1971; Aznalcóllar, 1998; Baia Mare and Baia Borşa, 2000; Aitik, 2000; Sasa, 2003; Malvési, 2004; Ajka, 2010; Talvivaara, 2012; Kostajnik, 2014; Kittilä/Suurikuusikko, 2015; Cobre Las Cruces, 2019; Kevitsa, 2023.

^[xvi] Pitron, G.; Pérez, J.-L. (2019). Le vert n’est pas vert! [film]. Paris: Arte France.

^[xvii] European Academies’ Science Advisory Council (EASAC), 2023. statement “Deep-Sea Mining: assessing evidence on future needs and environmental impacts”. https://easac.eu/publications/details/deep-sea-mining-assessing-evidence-on-future-needs-and-environmental-impacts

^[xviii] “Today, depending on the metal concerned, about three times as much material needs to be moved for the same ore extraction as a century ago, with concomitant increases in land disruption, groundwater implications and energy use”. International Resource Panel (2011). Decoupling natural resource use and environmental impacts from economic growth. Nairobi: UNEP. At: https://www.ourenergypolicy.org/wp-content/uploads/2014/07/decoupling.pdf

^[xix] In Romania, the proposed Rovina mine has 0.16% copper and it would be the second largest in Europe.

^[xx] Bolger, Meadhbh, Diego Marin, Adrien Tofighi-Niaki, and Louelle Seelmann. “‘Green Mining’ Is a Myth: The Case for Cutting EU Resource Consumption.” Brussels,: European Environmental Bureau Friends of the Earth Europe, 2021, p.14. https://friendsoftheearth.eu/wp-content/uploads/2021/09/Methodology-considerations-Annex-to-green-mining-is-a-myth.pdf.

^[xxi] Dunlap, Alexander. “The Green Economy as Counterinsurgency, or the Ontological Foundations for Permanent Ecological Catastrophe.” Environmental Policy and Science, 2023, 39–50.

^[xxii] Michaux, Simon P. “The Mining of Minerals and the Limits to Growth.” Geological Survey of Finland: Espoo, Finland, 2021, 1–72.; partially exposed by Simon Michaux to DG GROW on November 18th 2022

^[xxiii] Dunlap, Alexander. “Spreading ‘Green’ Infrastructural Harm: Mapping Conflicts and Socioecological Disruptions within the European Union’s Transnational Energy Grid.” Globalizations 20, no. 6 (2023): 907–31, https://doi.org/10.1080/14747731.2021.1996518.

^[xxiv] Objection submitted to the Commission’s DG GROW on 22nd November 2022 by MiningWatch Portugal

^[xxv] 10 years of EU’s failed biofuels policy has wiped out forests the size of the Netherlands – study – Transport & Environment (transportenvironment.org) https://www.transportenvironment.org/discover/10-years-of-eus-failed-biofuels-policy-has-wiped-out-forests-the-size-of-the-netherlands-study/

By Jovana Amidzic, Ana Kondic and Bojana Novakovic of Mars Sa Drine

January 20^th 2022 Nova S
Link to the original article

Urgent annulment of the Special Purpose Spatial Plan (PPPPN) Jadar is one of the best ways to ensure that Rio Tinto leaves Serbia. This does not mean making promises as part of the election campaign, but that those who are responsible for implementing the PPPPN, ie. the current Government, will immediately start the procedure of its annulment.

The spatial plan, which engraved Rio Tinto on the map of Serbia, was implemented in March 2020. The consequence of the plan is the conversion of land from agricultural to industrial, which drastically limits its use to the inhabitants of the Jadar valley’s 19,000 people, which would turn the fertile valley into an industrial zone that will be specially reserved for Rio Tinto.

What does this mean for the inhabitants of the Valley? The changes in the spatial plan are preparing the land for expropriation, where there is a violent confiscation of land and involuntary eviction of the population in the name of public interest. The change in the plan prevents new economic activities such as the development of tourism, shops and the development of the area. This means that landowners can no longer use the land in the same capacity as before, which is catastrophic for farmers because they think and invest long term.

In the meantime, the motivation for any agricultural activities is lost, because the inevitable result of all this is eviction. One of the consequences is the significant impoverishment of the region.

Farmers in Rosia Montana (Romania) who fought against the gold mine of the Canadian company Gable Resources faced the same problem. When the spatial plan was accepted, residents were no longer allowed to develop new economic activities.

Gradually, the shops were closed, the territory was quickly impoverished, and staying proved to be an almost impossible option. 

However, the farmers who decided to stay and fight the company by legal means, managed to win. Eugene David, a farmer, who was their leader, said at the time:

“My land guarantees my future and the future of my children. I could get a job at a company and then be fired after a year or two. My land can not fire me. She feeds me. Every time I meet a company, I ask them: what will you do if I refuse to leave? And they never respond. They have answers to complicated questions, but not simple ones. “

Will Serbia have the same success or will it shake hands with foreign investors for profit instead of protecting its citizens? One thing is for sure, if the PPPPN Jadar is not abolished by urgent procedure, the consequences will be catastrophic, not only for the environmental, but also for our people.

Driven by the recent protests, which threaten to significantly affect the outcome of the upcoming elections, our president and government representatives are trying to “distance themselves” from @RioTinto and transfer responsibility to the previous government. We must not forget that neither the trade agreement between Great Britain and Serbia from 2002, referred to by the General Director of Rio Tinto, nor the Mining Law from 2006, which Prime Minister @AnaBrnabić mentioned as the cause of the problem, had the greatest impact on this project. The biggest impact was the changes in the Mining Law from 2015, where lithium was consolidated as a “resource of strategic interest” and where expropriation in favor of private companies was enabled.

It’s needless to say that Vucic led the government in 2015 as prime minister. Vučić had the choice to reject the Rio Tinto project because it would involve mining lithium from a fertile and populated area. This meant that expropriation was possible, but illegal under the previous Mining Act. Instead of protecting the citizens, Vučić chose to revise the law in 2015 in order to adapt it to Rio Tinto.

If Brnabić and Vučić are really so different in relation to the previous government, now is the time to show it. The urgent abolition of the Jadar PPPPN and changes to the concept of strategic interest in the Mining Law must be implemented by those who initially implemented these changes, that is SNS. 

Ana Brnabic said that she thinks that the abolition of the PPPN plan is “a decision for the future, and I believe that it is smarter, better and fairer to make a decision by the political elite that will lead the country for the next four years.” She means – after the elections. Wouldn’t it be fairer for the current government to remove all the obstacles it has created, in order to give the citizens a future and a chance? 

Prime Minister of the Republic of Serbia

Nemanjina 11, 11000 Belgrade,

Belgrade, 01 October 2021

Dear Madam Prime Minister,

As organizers of conference “Project Jadar – what is known”, held in the Serbian Academy of Sciences and Arts (SASA) on May 6-7, 2021.  – based upon the analysis of data presented by participants, on-site discussions and additional data later presented by Government of Serbia and Rio Sava Exploration (main Contractor/Investor), a subsidiary of Rio Tinto Corporation, i.e., parties involved in negotiation over possible mining concession for exploitation of mineral Jadarit – we submitted a written Communication to the respective Ministers of the Ministry of Mining & Energy (two) and to the Ministry of Environmental Protection (one).  In both cases, and after a delay, we received (enclosed) replies not (only) from the addressed Ministries, but from the Contractor/Investor, Rio Sava Exploration.  

Being unable to establish contact with experts from the respective Ministries, responsible for providing critical evaluation of the submitted project, and for establishing bona fide “pros” and “cons” regarding the matter, we are, therefore, submitting this new Communication to You personally, with the intent to point out major irregularities, illogic narrative, flabbiness and neglect during the development of the “Project Jadar”, which may result in erroneous and dangerous management of water resources, mining waste and biodiversity, with likely long-lasting and detrimental consequences on human health in Radjevina and its surroundings.  

We are surprised that the Government has not made its experts available for professional discussion over certain issues.  That notwithstanding, our wish is to provide You and the respective governmental regulatory bodies with relevant fractography, and, by doing so, to contribute to a general and particular understanding of facts related to “Project Jadar”.  Therefore, please consider this Communication, and our previous submissions to the above-mentioned Ministries, as a testament of our will to professionally – and in good faith – help the Government of Serbia in making right and educated decision on the issue.  

Short analysis of facts known about the “Project Jadar” 

Rio Tinto (Rio Sava Exploration), the main Contractor/Investor and a partner to Government of Serbia in negotiations over mining concession for exploitation of mineral Jadarite, has demonstrated considerable superficiality and negligence in presenting the “Project Jadar” insofar.  The following are some of the facts pointed out in our earlier communications:

The design proposed by the Investor of the jadarite mine and its associated objects, presented in the Special Purpose Zoning Plan (SPZP) is neither compliant with the required conditions and (formal) estimations (which were obtained only after the fact), nor with the current statutes regulating water management and environmental protection.  The proposed solutions do not meet major requirements of the respective Water Management Law, with regard to establishing boundaries of water supply grounds, sanitary protection of water-supply sources, balance of technical water used in processing of ore, and the proposed waste-water treatment solutions including the release of effluents in the river Jadar. 

Dumping (deposition) of mining waste on the water supply grounds is wrong technical solution.  The Contractor/Investor still does not have veritable chemical analyses of compounds expected to be in mining waste, neither it has approved patent for their elimination.  The base for establishing future effects of any technology should be detailed analysis of the production process in semi-industrial scale.  It should be stressed, too, the Contractor/Investor does not have necessary experience in lithium extraction from the raw ore.  

The pressing issue is deposition of mining waste on water-supply grounds.  Two dumping grounds are planned; one within the mining/processing facility with the capacity of 5.5 million cubic meters of mining waste, and the other for processing waste, on the plateau between rivers Jadar and Likodra in Krupanj municipality, with surface area of 167ha, which is expected to grow up to the amount of 57 million tons over the period of 40 years.  There is a substantial error in the Special Purpose Zoning Plan, where the location of that second dumping ground is mistakenly described as being in the valley of Stavica river, and with technical proposal for building a barrier dam and auscultation wells there.  Without recognizing a mistake, and quoting Stavica’s known flooding propensity, the Investor proposes a third dumping ground (4A-North), to be located above mine itself, and close to the industrial/processing facility.  This “third” (erroneous) dumping ground does not meet ANY of the criteria used in designing such a facility, because its location is planned immediately above the mine, i.e., along the fault line with significant ground subsidence, in the basin of river Korenita – known for wide seasonal level variations – and in close proximity to existing human settlements.  All the above just adds to the confusion regarding waste dumping grounds, which appear to be the most limiting element in planning the mine.  This is in large part because there is no a comprehensive technical approach to possible breakdown of dumping grounds, the approach which should provide for the prevention of total degradation of the river Jadar, and the protection of both the Jadar, regional water-supply sources of Drina alluvium and, consequently, rivers Drina and Sava and water supply sources of villages, towns and cities situated downstream.  

 In addition to problems in planning listed above, over the course of the SASA Conference “Project Jadar – what is known” the public also learned that in river Jadar valley, in the planned Special Purpose Zone, both the grounds and the water are already polluted and that the underground water is not suitable for human consumption, neither – based upon some parameters – suitable for agricultural use.  This condition is, in large part, the consequence of leakage of spoil from the dumping ground of antimony mine “Stolice” during 2014 production season.  It should be noted that the proposed project “Jadar” just “adds insult to injury” without any attempt to remedy such a bleak condition, by claiming that exploitation and processing of Jadarite will not additionally aggravate the existing, already miserable state of both agricultural grounds and underground waters!

For a long time the investor has claimed that it held a patent for jadarite processing, thus misleading the public.  Only after several reprimands in media (and during the Conference) have the investor changed the word “patent” with “patent application”! As of September 20, 2021, that alleged application has not yet been approved and made public. In its statements/communications (received by us through Government’s Ministry of Mining & Energy) the Investor states that “company is ready, i.e., plans additional tests, for obtaining data to decisively establish whether the mining and processing waste contains arsenopyrite, or not – although earlier tests did not indicate its presence”.  The essence of this quotation, along with others in our communications to the above-mentioned Ministries, is that the Investor has not definitively established the chemical composition of the compounds/minerals in the jadarit ore and mining/processing waste – containing arsenic, although estimates for arsenic only go – over 40 years of exploitation – to about 6,000 tones in 57 million tones of waste.  The quoted amount of arsenic is calculated as the amount of elementary arsenic; the amount of waste carrying various chemical compounds containing arsenic, will be significantly higher.  That fact is instrumental for any estimate or anticipation of waste toxicity and its negative impact on biodiversity and human population. For details on the above, please see our earlier Communication to MM&E, enclosed to this letter.  

At this moment, the project “Jadar” is, from the standpoint of technology, insufficiently transparent.  As we stated earlier, the base for establishing future effects of any technology should be a detailed analysis of the production process in its full desired capacity, and the expected results.  At present, there is no firmly established material balance of the project as a whole.  It is imperative that all the project elements serving as a base for completing a comprehensive Study of Project’s Impact, be fully transparent.  Laws of the Republic of Serbia regulating this matter demand the statement from the Investor that the facility proposed to be built, meets the best available techniques in the field.  Also, there should be a document prepared, upon the analysis of a semi-industrial production facility, to address comprehensive control and prevention of pollution.  This is not mandated by Law, yet we consider it as necessary element in the process of planning.  Such a document should eliminate – and forbid – any possibility of releasing polluting compounds into natural recipients.  Given the size, scope and strategic importance of the proposed Project Jadar, the professional community, pundits, and general public should have an active role in designing and achieving the sustainable agreement with the Investor

We would like to focus your attention on necessary verification of the chosen industrial procedures – please refer to quotation ”Sustainability of lithium and boron exploitation can be assessed (only) after the development of the technological project, Environmental Impact Study of the Complex and related documents in the field of Integrated Pollution Control and Prevention” from the SASA “Project Jadar” conference (Prof. Dr. Željko Kamberović).  According to the estimates by experts in the field, additional testing of the whole technologic process of such extent and impact to environment, should involve 10-20,000 tons of ore concentrate.  

The need for environmental protection is being ignored

When it comes to environmental impact, it is of outmost importance to get as accurate assessment as possible of the effects, not only in the immediate vicinity of the proposed mine, but also in surrounding territories.  In early estimates of the mine’s environmental impact, there is nowhere to find the facts that within the area of the mining complex (1,850 ha to 2,300 ha) everything that constitutes the current natural environment (arable land, forest, orchards, infields, and yards) will be destroyed and the existing population relocated.  Given such a development, it appears rather absurd to deliberate and suggest “environmental protection” because, in reality, this is a plain destruction with unforeseen and ignored long-term negative consequences.  Although Investor’s representatives keep claiming that everything will be done in accordance with the highest ecologic standards, it remains unspecified to which of those “highest standards” they refer to? We do not hold a high hope that the incoming Feasibility Study will present any new data on prospective treatment of run-off waters from the mine’s waste heaps, i.e., waters in which the arsenic compounds were positively identified.  We, therefore, want to stress again that, based upon what has been presented insofar, it is highly unlikely that the Investor will prevent the release of toxic and dangerous compounds into the Macva’s underground water horizon, which is estimated to be the largest drinking water-supply source in whole of Serbia.  It is important to remember that the mining waste heaps will stay there for centuries, slowly releasing – if not decisively contained – toxic compounds and, thus, making the water of the whole region, toxic! It should be noted the Investor has already seriously compromised the integrity of the local environments, since some of its exploratory wells (boreholes) keep leaking toxic waters that destroyed agricultural crops on adjoining arable lands.  Opening of the proposed mine will only aggravate the problem by multiple orders of magnitude.  Therefore, we expect – with keen professional and scientific curiosity – the incoming Investor’s “Study on Environmental Impact of Project Jadar” in hope that some of our worst fears will, somehow, be rebutted by some new and yet unknown to public, arguments and solutions conspicuously missing from our exchanges with both the Ministry of Mining & Energy and Ministry of Environmental Protection.  Our insight into available public sources strongly indicate that the Investor does not have necessary experience and expertise in processing of lithium ore, which is why we demand the proof of their previous positive mining practice in extracting lithium carbonate from various lithium-containing ores.  

We would like to take this opportunity to elaborate on recent advances of technologies for energy storage, which are not based upon the use of lithium.  There is a growing interest of European Union with regard to use of so-called “green hydrogen”, generated through electrolysis of water using electricity from renewable energy sources.  The use of hydrogen as primary fuel for motor vehicles has become reality and practice throughout the world.  Germany itself plans to have 14 million passenger cars and up to 30% of all trucks powered by hydrogen or hydrogen-generated electricity by 2030.  (https://www.  agora-verkehrswende.  de/en/publications/towards-a-climate-neutral-germany-by-2045-summary/ ).  

In addition to sodium-ion batteries (Company: Faradion, CATL), which are quickly becoming an alternative to lithium-based batteries, a new generation of graphene batteries may, as well, be a convincing and effective alternative to lithium-ion devices and push the later out the market.  Whereas lithium-ion batteries have specific energy up to 150-200 Wh/kg, graphene batteries of equal size have much higher specific energy that go up to 1,000 Wh/kg.  In addition to operating within a wider temperature range (-5°C to +60°C), Samsung, Huawei and Panasonic graphene batteries charge 5-fold faster, have at least 50% higher storing capacity, 25% smaller carbon footprint and are about 50% lighter than their Li-Ion counterparts.  They also last much longer; as opposed to Li-ion batteries that can be fully charged for about 500 cycles, graphene ones last at least 1,500 cycles.  They are already used in mobile chargers (manufacturer: RealGraphene, USA).  International markets will soon see cell phones with graphene batteries (instead of Li-ion polymer), shortly to be followed with high-capacity graphene batteries for electric cars, where their better thermic conductivity will make them much more reliable in exploitation than their Li-ion competitors.  Low reliability of Li-ion batteries and some of their intrinsic shortcomings such as propensity for spontaneous self-ignition, are being some of their recent recalls.  https://media.  gm.  com/media/us/en/gm/home.  detail.  html/ content/Pages/news/us/en/2021/aug/0820-bolt.  html; https://www.  b92.  net/automobili/vesti.  php? yyyy=2021&mm=09&nav_id=1924302.  

Was the Project “Jadar” presented transparently to Serbian public, and is it of public interest (beneficial) for the Republic of Serbia?

The project “Jadar” is not being realized transparently, and in accordance with existing norms, procedures and standards concerning availability of critical information to general public, and public’s participation in the processes of planning and decision-making.  Special Purpose Zoning Plan for exploitation and processing of mineral Jadarite (project “Jadar”) approved by the Government of Serbia in March 2020, was the first publicly available document providing at least a partial insight into the real scope and possible consequences of project “Jadar” realization.  It was only after the SASA conference “Project Jadar – what is known”, held in May 2021, where the representatives of the Investor disclosed a fraction of exploration results, analyses, and proposed solutions, that the conclusion was reached regarding project’s numerous shortcomings and ambiguities and – as a consequence – unacceptable risks.  

Significant problem lies in the fact the Government of Serbia did not (as required by Law on Public Private Partnership and Concessions) establish a professional impartial committee made of independent experts, to follow the realization of the Project and participate in planning of exploratory actions, completion of a feasibility study, and in the processes of evaluation and justification of the Project as a whole.  Such a professional committee would be responsible for timely dissemination – to general public and interested professionals – of true and verifiable information regarding the Project, particularly about its positive aspects as well as about possible impact to environment and public health.  Instead of doing so, the Government of Serbia surrendered all of those planning and developmental tasks to the Investor, who, understandably so, adjusted and designed the Project in accordance to its business goals and interests.  

The investor claims to have at its disposal significant resources and top-notch consultant teams; that it has undertaken a wide scope examinations in the river Jadar valley since 2011, and that since December 2016. has worked continuously on completing planning and technical documentation.  However, within that time period, the Investor has not been able to complete – and present to the public – any earlier feasibility study with the long-term plans of jadarite exploitation, or a draft projects providing elements that would enable analysis and evaluation of the possible environmental impact.  Quite to the contrary, during all that time the Investor was providing information to the interested public, rather selectively and incompletely.  This may be the only project of this scope and importance, where significant and relevant technical problems are being debated almost exclusively through releases by the PR office of the Investor, and, sporadically, through newspaper articles and printed flyers.  

It should be emphasized that all exploratory results and other data concerning the environment and public health, must be publicly accessible and not be treated as the proprietary Investor’s possession.  It is, also, unacceptable that State Universities and research Institutes, which are doing exploration and analyses on behalf of the Investor, first sign nondisclosure agreements regarding all the data obtained in the process, and then seek special permission to make some of those data available to public.  

The plan for exploitation which is described in “Feasibility Study for Exploitation of Underground Deposits of Lithium and Boron” completed in 2020 by the Faculty of Geology and Mining in Belgrade, anticipates that, in the first phase of exploitation from 2023 to 2083, a total of 64 million tons of ore will be excavated, which is roughly 40% of the 158 million tons of established reserves.  The Rio Sava Exploration Company (the Investor), in that first phase, intends to use the most accessible deposits of highest quality and concentration whereas, paradoxically, funds needed for protection and development of environment are reduced to a bare minimum and, practically, excluded from the investment plans?! Such an approach will, undoubtedly, guarantee maximum efficacy of investment and high rate of returns, but will have detrimental effects on local human population.  This, for sure, is not the public interest claimed in recently adopted and approved Special Purpose Zonning Plan.  

Serious deliberations of the project “Jadar” should realize and consider the total costs and benefits of this undertaking and assess the profitability of the project for the State and not only for the Investor.  This means that the project “Jadar” should include capital investment into preservation and development of the environment, and into development of local economy, as compensation for exploited local resources.  Methodology for calculating such compensations is well known and widely used in all developed countries.  It appears that the Investor did an excellent job in learning our nation’s traditionally inappropriate and sloppy approach to environment, and that it is taking advantage of it.  We are, therefore, rather convinced that the Investor is imposing its will and interest upon the Government of Serbia by running the project in such a nontransparent way, by taking preparatory actions without meeting all of the conditions and obtaining necessary opinions and consents, without a critical recourse to Special Purpose Zoning Plan and by partial and incomplete disclosure of the production process details.  

Therefore, we the undersigned propose to the Government of Serbia to [1] establish and introduce a definition of hazards to environment, public health, arable land, biodiversity, waters of rivers Jadar, Sava and Danube, Macva as a whole, arsenic in waters and in the ground, etc., [2] make official assessment of all the damage that may result from the Project, [3] define and establish methodology by which pollution and damage to the environment is assessed, measured, and followed, [4] request and obtain a binding consent from the Investor for compensating all the damage resulting from the Project and [5] provide necessary financial instruments and collateral guaranties that will secure unconditional and unambiguous payments for any damage caused by the Investor.  

We, also, propose to the Government of Serbia that its experts to pay special attention to the credibility of the Investor, and to scrupulously, and to the detail, analyze any proposal by Rio Tinto Company (Rio Sava Exploration) concerning the technology to be used in the process, given all the examples presented above of Company’s unreliable practices.  

With that said, we remain, Dear Madam Prime Minister,

Sincerely Yours

Organizing Committee of SASA Conference “Project Jadar – What is known?”

Vladimir Stevanovic, full member of SASA

Bogdan Solaja, full member of SASA

Velimir Radmilovic, corresponding member of SASA

In collaboration with Veljko Dimitrijevic M.Eng., Dragana Djordjevic, Ph.D., and Prof. Dr. Ratko Ristic.