This is a letter that villagers from Bagabag Island have sent in response to an email from the CEO of Nautilus Minerals, Inc., expressing their concerns about the proposed deep sea mining operation.
Dear Mr. Heydon:
On behalf of the villages of Bagabag Island, many thanks for your response dated Tuesday, August 14, 2007 to our concerns that the proposed deep sea mining operations will have on the oceans, our livelihoods, our health, and our way of life.
We understand that you have a license to only explore, conduct reconnaissance drilling, and do environmental surveys at this point. We agree that this creates a window for consultation with NGOs, fishermen, and other stakeholders. However, the window already appears to be half closed– you make reference to the fact that the EIS is already half completed.
We have several recommendations that will improve the process of preparing the EIS and ensure that the best available science is applied, that a shared understanding of the facts and potential impacts is created, and that people who depend on healthy ocean ecosystems have an informed voice in decision making processes that affect our lives:
1. That the stakeholder and community consultation process be truly participatory. The building of trust and of a common understanding of the facts and interpretation of the facts requires a good flow of information and transparency. The release of a fully developed EIS for public comment is usually not sufficient for these purposes. Therefore, the process that you suggest (“My suggested way forward is to stay interested and stay involved, let the science and the research take its course, and participate and comment on the EIS when it is available for public comment in early 2008”) may not be effective. Instead, we recommend the development of a series of workshops this fall, winter, spring of 2008 at which interim data and interpretations are shared and discussed. At specified intervals, EIS milestones would be subject to review by a stakeholder advisory committee in order to seek broader public input. These milestones would include: (a) scope of the EIS; (b) project options under consideration, including No Action; (c) potential threats and risks; (d) risk mitigation measures; (e) environmental, social, and economic impacts of each project option; and (f) selection of preferred option. A transparent government-led process with meaningful public participation for assessing the EIS and preferred alternative, approving and disapproving the project, and issuing rules would then ensue.
2. The EIS must estimate the geographic scope of the potential impacts of commercial mining at scale as accurately as possible. Your letter emphasizes the large distances between your exploration sites and coral reefs and fishing grounds. However, the scale and behavior of a 3-dimensional plume arising from deep sea mining is unknown to us. We believe that models of particle dispersion in the deep ocean (or from conveyance systems) and of various physical and biological mechanisms that can transport materials from the deep ocean to the photic zone or shallow water ecosystems are only accurate if sufficient long-term oceanographic data are available from each of the mining sites. Therefore, we believe that empirical tracer experiments with non-toxic tracers will be required to accurately estimate the potential impact area. Furthermore, because ocean circulation is highly variable, time course studies will probably be required to estimate the appropriate sampling rate and variability in order to generate statistically significant results.
As a matter of policy and to maximize social and economic benefits, it will be important for the EIS to consider the option of capturing nutrient-rich bottom water and using it for onshore aquaculture operations in order to remove nutrients and carbon dioxide and to return water temperature to near-ambient levels prior to discharge.
3. The EIS must review the full suite of potential impact mechanisms. In our view, these include, inter alia: local effects of removal of ore; mid-distance effects of heavy sediment plume; adsorption of metals onto fine particles; ingestion and transport by motile organisms; injection of nutrient-rich deep water into the photic zone or nearshore ecosystems; the impacts of high sediment levels resulting from slurry leakage which could limit light penetration in the photic zone; adherence of sediments to plankton, with potential effects on species diversity and productivity; conventional pollution associated with mining operations; introduction of exotic species; acoustic impacts, specifically on marine mammals.
4. The EIS must review the full suite of potential social and economic impacts. These may include, inter alia: impacts on offshore pelagic fisheries, inshore fisheries, ports, jobs, etc. In addition, because deep sea mining is a new industry, and your project is at the vanguard of this industry, you have an opportunity to demonstrate commitment to a new social contract between users of natural resources and people and communities in desperate need of economic development. We recommend that you consider a community grant program to allow the citizens of PNG to benefit directly from the wealth that would be released through your mining operations. These kinds of mechanisms, which would supplement conventional business taxes that flow into the national treasury, may be particularly appropriate in countries that have relatively poorly developed systems to achieve social and environmental goals. Specifically, we propose that a separate foundation be established at the start of the project which would have an initial endowment and then receive annually an agreed upon fixed amount or percentage of the revenue generated from the project. The foundation would be governed by an independent board and would be responsible for using foundation funds to monitor the social, economic and cultural impacts of the project and to provide community grants to ameliorate negative impacts of the project and generally improve the livelihood of communities impacted by the project.
5. That the EIS analyze the full range of management and project options, including a No Action alternative and measures to mitigate major threats identified in the EIS. These may include, inter alia: Performance bonds (held in trust to pay for mitigation of any unanticipated impacts), natural resource damage assessments, in situ mitigation measures, etc.
6. That the team of scientists preparing the EIS include not only deep sea biologists but physical oceanographers, geophysicists, anthropologists, marine economists, and marine ecologists in order to estimate the fullest possible suite of potential impacts.
7. That the research being fed into the EIS be reviewed by an objective panel of scientists not in the employ of Nautilus or its partners. Nautilus would consult with the Public Advisory Group and the PNG government on the establishment of an “Independent Scientific Review Panel” and its composition. The panel would review the scientific research reports informing the EIS and provide their views on those reports.
8. That there be no exploration and mining on or near Bagabag Island. “Our forefathers have stopped explorers from exploring our island of Bagabag for any mineral deposit. Likewise, we the current generation will stand on their words and maintain that there should never be any exploration or mining activity on and near the seas of Bagabag Island,” Kial Dumui sub-clan leader for Maragab clan for and on behalf of the people of Bagabag Island.
We appreciate the civil discourse that we have embarked on and look forward to a positive response to our recommendations. We stand ready to continue our dialogue in person, and to assist through (for example) provision of funding for scientists not in the employ of Nautilus or its partners to participate in the EIS process and by participating in a stakeholder advisory committee.
Yours sincerely,
Wenceslaus Magun
Western Pacific Campaigner
Sea Turtle Restoration Project
Port Moresby – Papua New Guinea
