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.