Annex C. Further Analysis of the Sustainability of the Sand Mining Industry in Montserrat

The Guidelines have been written from the perspective of sand mining as a sustainable industry for Montserrat. This Annex explores some of the broader (and largely interlinked) issues around sand mining in Montserrat, examines some key aspects of the industry and related government approaches that require further clarification or development and makes some brief recommendations. The analysis in this Annex is based on broad consultation through the EIA and Guideline preparation process and the author’s 20 years experience working on mining and environmental / social issues. It is offered as a serious and considered contribution to sustainable development for Montserrat.

C.1 Consideration of ‘No Mining’ as a Valid Scenario

The Montserrat Mining and Quarrying Industry Study Final Report (May 2011) defines a ‘do nothing’ scenario (and several others), but does not explore a ‘no mining’ scenario (this is a significant omission; based on international good practice this scenario should be addressed as part of any EIA). This implies that there is an assumption that the industry MUST be profitable (for Montserrat as a whole) and sustainable in some form. However, this assumption does not appear to have been tested. There is also the possibility that sand mining is only profitable due to its present externalisation of environmental and social costs; if the measures noted in these Guidelines are fully implemented, will the industry remain profitable?

As a ‘new’ industry in Belham Valley, it is necessary to demonstrate that a sand mining industry where environmental, social and health and safety impacts are properly managed is able to make a significant and sustainable contribution to government revenue and the economy of Montserrat as a whole. More importantly, it must be demonstrated that the financial benefits of sand mining equal or exceed any losses in government revenue and the economy due to the impact of that mining on other economic activities. This issue has been addressed in detail in the EIA (e.g. the concern that tourism revenue will substantially decline if mining proceeds to the west of the Old Belham Bridge).

Recommendations

 – An independent economic study should be undertaken to define whether sand mining is viable and sustainable. Analysis should include different jetty locations (Isles Bay should be excluded, see Section C.2) and haul road routes and consider the capital and operational costs associated with jetty / road construction and maintenance and the cost of implementing the environmental, social and health and safety measures noted in these Guidelines. Through such a study it would be possible to quantify mining’s direct and indirect contributions to the Montserrat economy for different scenarios.

–  Subsequently, using the same scenarios, the impact of mining on other economic activities should be independently assessed. If there is no net benefit from mining, then a ‘no mining’ decision would require serious consideration.

C.2 Managing Environmental and Social Impacts of Sand Mining

Despite the development of environmental and social measures in these Guidelines, in reality, the scope for minimising environmental and particularly social impacts are limited; source reduction of noise and visual impacts are limited by the topography of the valley and the relative positions of the residential areas and the sand mining operations (at present). Similarly the opportunity to control dust through revegetation of worked out areas – an approach commonly used in the broader mining sector – are simply not technically or economically feasible in the context of Belham Valley.

Investments of time and money will be undone on an ongoing basis by lahars.

In the context of Belham Valley, mitigation measures will only able to deliver so much; given the nature of the sand mining operations it is certainly the case that there are not sufficient financial margins to ‘gold plate’ environmental management options and this is a further practical limit to minimising visual, noise, dust and other impacts highlighted in the EIA report. In effect, the principal mitigation measure is to maximise the distance between the mining activities and the potentially affected stakeholders. Clearly it is not possible to resettle the residents; there are no comparable locations and the financial cost of this approach would not be feasible. If the residents remain, the sand mining industry as presented in the EIA – even with the appropriate management measures in place – is not sustainable if taking place ‘too close’ to residential areas.

There is little or no scientific basis to date behind the selection of the boundary for the lower limit of mining. The Old Belham Bridge is a boundary of convenience and one that has sunk into the consciousness of the residents as ‘acceptable’, presumably through empirical day-to-day observation. However, to suggest a lower limit further west than this is to invite ongoing resistance from residents. From the miners perspective, it is unclear how much difference working above the Old Belham Bridge makes to their operations and profit margins; material to the east of the Bridge is not likely to be as well sorted (in terms of particle size) and may contain a higher proportion of coarse material but no study has been seen that quantifies the difference in quality of material between the upper and lower reaches of the valley.

Equally, whether there are scientific reports to support the development of a jetty at Isles Bay or not, the perceptions of the residents in Belham Valley are sufficiently entrenched that development of the jetty and a haul road through the lower Belham Valley will be consistently and robustly resisted. The Government can clearly force this option and press ahead with jetty construction; what it cannot do is ‘force’ the industry to become sustainable. Whether they are ‘right’ or not, ex-pat residents are in the position to finance legal and environmental support and undoubtedly have a number of options and approaches to obstructing mining in the lower Belham Valley and the construction of a jetty at Isles Bay. While ‘major’ mining companies can face down concerted stakeholder opposition, this does not appear realistic in this case (and even if it were that approach would be diametrically opposed to the concept of ‘sustainable’ mining).

Common sense dictates that a compromise position needs to be identified; the concept of sustainable mining requires that there is broad stakeholder support (or at the very least acceptance) as well as the purely technical, economic and environmental considerations. That is not and will not be the case if a jetty is constructed at Isles Bay, a haul road installed in the lower Belham Valley and mining is allowed to proceed to the west of Old Belham Bridge.

Separating residents and mining would create an enabling environment for growth (and hence revenue for the government). The hours of operation and days of operation could be extended if the mining and residents do not have a significant interface. This is relevant to both transport and processing and excavation, all of which will need to be constrained with respect to hours / days worked as this is an effective (and sometimes the only effective) measure for controlling the impact of noise and associated disturbance.

Separation of mining and residents will also have benefits for reduction of visual and dust related impacts, both of which were highlighted as significant issues in the EIA commissioned by the government.

Recommendations

– Permanent extraction of sand should be permitted only to the east of Old Belham Bridge. Temporary extraction downstream of the Old Belham Bridge river crossing should be permitted (a) at times where sand resources have been exhausted upstream of the crossing (e.g. extracted material has not been replenished by lahars) or (b) for maintenance or river management purposes, subject to agreement of the duration and location of any temporary extraction activities with the Ministry of the Environment and prior disclosure of plans to affected local resident groups in Belham Valley.

– Rule out Isles Bay as a potential jetty location and the option to build a haul road through lower Belham Valley.

– No further processing plants or stockpiles to be installed or planned for west of the Old Belham Bridge; ideally processing plants and stockpiles should be located outside of the valley.

– Compensate Shamrock to relocate its processing plant to east of Old Belham Bridge or a location outside Belham Valley (this assumes that the company had a legal right to put the plant in its current location). The most effective method of decreasing noise impact on the residential properties in Old Towne (and to some extent those on Isles Bay hill), would be to move Shamrock’s processing plant to another site further upstream from the Old Belham Bridge. Based on noise modelling reported in the EIA, this would substantially reduce noise impacts; however, as the plant precedes the development of the environmental and social Guidelines it is reasonable to compensate the operator to mitigate the costs incurred in moving the plant.

C.3 Jetty Location

There have been several studies on potential jetty locations, but it is unclear how the government’s decision-making has used or is using these studies. A number of valid comments and questions have been raised by Belham Valley residents with respect to previous studies on the jetty location, but it is also unclear how these have been considered in the decision-making process or whether these comments and questions have been passed back to the study authors to address and revert.

Recommendation

– Clarify the decision-making process with respect to jetty location and disclose all relevant information for review by stakeholders, including any responses to comments on previous studies.

C.4 EIA Issues

Under the existing Physical Planning Act and Subsidiary Legislation an application for development permission in respect of a development specified in the Third Schedule (which includes quarrying and other mining activities) must be accompanied by an EIA of the proposed development. The EIA must include the matters specified in the Fourth Schedule. The proposed Conservation and Environmental Management (Certificate of Environmental Approval) Regulations also give further detail on the minimum statutory standards for preparation of an EIA, the review process and public consultation on the EIA.

Despite this, an EIA for each mining operation does not appear to be available and the consultation and review processes for those that have been prepared appear to be limited.

Recommendation

– Ensure that an EIA has been prepared for each mining operation by an independent environment expert / consulting company; the expert must be independent and outside the review and permitting process to avoid actual or apparent conflicts of interest

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