IKN

UPDATE: This part is interesting, on pages 317 and 318. I mean, doesn’t it strike you as odd that this is a Feasibility Study and the Feas compilers are allowed to look at the company’s environmental application documents? Or how there’s a November 2016 clock ticking on the EIA and “some work has been initiated” on it?

Under the Broad Application System, mineral exploitation is licenced in three consecutive phases (Preliminary Licence (LP); Installation Licence (LI); Operating Licence (LO)) under the requirements stipulated in CONAMA Resolution No. 237/1997 and Federal Law LC n. 140/2011, as described below. These requirements are governed by the Brazilian Institute of Environment and Renewable Natural Resources – IBAMA, the State Environmental Agencies or the Municipality Authorities, according to the distribution of competences established by Law. To date, the licencing process for the Project has been under the jurisdiction of the Pará State Environmental Agency, SEMA.

Preliminary Licence (LP)

The first stage of licencing, wherein the licensing agency evaluates the location and design of the Project, confirms its environmental viability, and establishes the basic requirements for the next phases. An Environmental Impact Assessment (EIA/RIMA) was prepared (Brandt, 2012) and served as the basis of an LP issued for the Project by SEMA in February 2014. The Project has been the subject of some controversy and the LP has been the subject of several legal challenges by the MPF (Federal Public Prosecution Service of Brazil) since its issuance, however, remains in force. Conditions listed in the LP discuss a range of both required and recommended actions to be taken by Belo Sun. Within 1,095 days (until the end of November 2016), these must be completed or be under progress consistent with the development stages and timing of the Project. Overarching themes include:

▪ Further investigation of potential impacts to nearby Indigenous communities and landscape ecology;

▪ The development and implementation of programs aimed at supporting local people and communities;

▪ The development of environmental management plans, including those for water control, waste management and erosion and sediment control;

▪ Monitoring programs for socioeconomics, health, and flora and fauna; and

▪ Management programs for road safety, among others.

Belo Sun has established plans to fulfil the obligations of the LP and some work has been initiated. ERM has not evaluated the adequacy of these plans. 

Installation Licence

An Installation Licence (LI) is required in order to commence with the construction of the Project. At the time of writing the LI application is under development by Belo Sun and its consultants. The LI application must present details on the design of the proposed project and the environmental and social protection measures that will be implemented. Further, the LI application provides an update on the ongoing environmental and social studies required as part of the LP conditions. The Project has undergone changes since the completion of the EIA and the issuance of the LP.

The LI application updates the evaluation of potential environmental and social impacts based on the updated Project footprint. The LI application was not available for ERM review at the time of writing.