Please find below some thoughts on the new Social Impact Assessment (SIA) guidelines for mining companies (http://www.planning.nsw.gov.au/socialimpactassessment).
Definition of Social Impact: ‘Consequences experienced by people due to changes associated with a state significant resource project’ (Department of Planning & Environment: Social Impact Assessment Guideline). The Department’s definition of social impact (SIA guideline, part 1.1) is broad and includes impacts on physical and mental health, material prosperity and the aesthetics of our surrounds. Another way to think about social impact is as the human experience of environmental and economic impacts. A definition of the activities covered under ‘resource projects’ is also given (footnotes, p. 2), and includes: mining (minerals, including coal), petroleum production (oil and coal seam gas), and other extractive industry (basic geological resources such as sand, gravel, clay, rock). In all instances, the phases of extraction, processing, and ‘rehabilitation’ of the land are included in the definition of a ‘resource project’.
Economic Boons versus the Social Good: The Department of Planning & Environment lists ‘availability of labour’ (employment), ‘business and procurement opportunities’ and royalties paid to the NSW government under positive social impacts (SIA guideline, part 3.2.2). There is a rather glaring lack of synthesis in this equation. The presence of jobs and money alone is neither a social good nor a social evil: it is the human experience of these provisions (if indeed they reach industry-affected communities in any substantive way) that defines their social worth.
The NSW Minister for planning and Housing is also eager to equate economic benefit with social progress: “Anthony Roberts said examples of positive social impacts may include increased employment opportunities and support for local business and organisations…” – NSW Government Announces Social Impacts Assessment Guideline for Resource Projects (DPE, 2017). This is unsurprising given his priority of creating 150,000 new jobs over the term of the current government (stated on his website here).
Again, I take exception to the conflation of positive economic impacts with positive social impacts. While there are obvious correlations between employment, increased business transactions, and the overall prosperity of society, the provision of ‘jobs and growth’ only becomes a ‘positive social impact’ if it increases the collective happiness, or reduces the collective level of suffering in the community (local, regional, state, national or global). It matters what those jobs actually entail. It matters whether:
1. The work itself is fulfilling beyond the income it generates (or is menial, psychologically or physically degenerative)
2. The work itself produces anything of real value to society (or whether the costs or risks, be they environmental, ethical, aesthetic, or economic outweigh the value of the product or service)
3. The work is truly sustainable (or whether its temporary nature will create a ‘boom and bust scenario,’ for example when mined resources are depleted, their market value takes a sustained dive, or the physical mine/well/quarry infrastructure undergoes catastrophic failure)
4. The presence of the project and its company encourages cohesion within the community (or is deeply divisive, as the Dargues Gold Mine was to Major’s Creek)
5. The resource project facilitates a more equitable distribution of wealth (or creates vast imbalances)
6. The royalties generated are used for the greatest benefit of affected communities (or dispersed across the state such that no appreciable benefit befalls those communities, or the royalties are squandered – for example, on private infrastructure along the lines of Adani’s coal mine in Queensland)
7. Whether the project serves to bring civil society to a closer and more respectful relationship with the natural world, an appreciation for its beauty, and the greater material prosperity and richness of life found therein (or encourages an exploitative attitude towards the environment, which I would suggest finds a natural extension in interpersonal relationships of which society is composed)
8. Whether the project has a positive or neutral environmental impact (or causes an appreciable degradation of the local or global environment such that the decreased availability of clean water, clean air, fertile soil and liveable climates begins to tear at every fibre of the social fabric)…
In sum: ‘Jobs and growth’, without the guiding principles of human dignity and environmental respect, is the mantra of our ongoing self-destruction.
Even those endlessly touted economic benefits of industrial projects – employment and increased cash flow, need always to be called into question for long-term viability. Money generated by the increase in local transactions and patronage of local suppliers, contractors, and other businesses is unlikely to stay in the community, even until the work dries up. There is never any guarantee that profits generated by resource extraction stay in the geographical area, especially one that has become undesirable to live or raise children in. This is in addition to the long-term negative impacts of post-industrial landscapes to property value, agriculture and tourism, due to contamination of soil and water, deformity of the land, and reduction of biodiversity.
Motivation for the new Social Impact Assessment guidelines: For some within the Department of Planning & Environment (DPE), the introduction of a formal guideline for Social Impact Assessment (SIA) will represent a genuine attempt to create more comprehensive and meaningful criteria on which to assess the true merits of industrial projects. I would consider this a naive perspective. For pro-industry ministers of the ‘more jobs and endless growth’ persuasion, the SIA represents an opportunity to snatch the phrase ‘social impacts’ from public and NGO critics, and place it in the hands of industrial proponents as a justification for their (pre-determined) approval by state and federal planning authorities (NSWDPE, PAC, DE). From this perspective, the SIA could be seen as just another weapon in the industry-government campaign to better sell resource projects to the communities on which they impinge.
Application and Partiality of the SIA: The NSW Department of Planning & Environment claims that one of the guiding principles of the Social Impact Assessment (SIA) is ‘impartiality’: that it is to be “undertaken in a fair, unbiased manner and follows relevant ethical standards,” (SIA guidelines, part 1.3, table 2). But under the current guidelines, this is impossible.
The Social Impact Statement is to be incorporated into a company’s Environmental Impact Statement, or EIS (SIA guidelines, part 1.2). This renders it partial (pro-project), as it will be prepared by industry-hired consultants, whose main business is to secure mining approvals for their clients. It works like this: the mining company pays an ‘environmental consultant’ to prepare an Environmental Impact Statement (which they like to call an ‘Environmental Assessment’, which is more palatable). This consultant (for the Dargues Gold Mine, it is R.W. Corkery & Co) presents a glossy tome of selective data with a reductionist methodology and concludes that there will be ‘no significant impacts’ on any individual species or ecosystem or vital resource, and that ‘on balance’ with the often vague ‘community benefits’, all risks to the environment or human population are ‘acceptable’. So closely is the proponent involved in the production of the EIS that the company name and/or logo may appear prominently on the front cover of the document. That is about as far from impartial as it is possible to get.
Social Impact Assessments will simply be an extension of, or integration with, the various chapters of an Environmental Impact Assessment. The purpose of this document is not to investigate scientific or social truths, but to sell a project to communities and planning authorities. It will always argue that a project is environmentally benign (or worthy of the sacrifice), economically beneficial, and now – socially sound.
Institutional Bias: From the proponent’s perspective, the purpose of the Environmental Impact Statement (often under the euphemism, ‘environmental assessment’) is to satisfy bureaucratic criteria in order to secure an approval. In light of this, the supposed impartiality of the SIA is already fatally compromised. But in NSW, project assessment itself is also systemically biased in favour of the proponent (the mining company).
The NSW Department of Planning & Environment (DPE) ‘exhibits’ the Environmental Impact Assessment (several hundred pages of infomercial narcosis) to the public. The preferred time to release such a document seems to be during an election, the Olympic Games, or another time of mass distraction – or that could just be coincidence. The DPE invites comment via written submission to give the impression that democracy is being served. The public – including but not limited to local communities – respond with individually composed or pro-forma letters, by way of objection or support for the ‘project’ (mine, quarry, well, etc.). Rather than synthesise, respond to, or act upon the overarching will of communities and the broader public expressed in those submissions, the Department of Planning forwards public submissions directly to the mining company for response. The resulting ‘Response to Submissions’ (RTS) is then exhibited, giving the proponent the final word over the community.
Like the Environmental Impacts Assessment, the RTS is prepared by the company’s ‘environmental consultants’, who make it their business to quash public objection to the mine (as well as to counter the submissions of any NGO’s and peripheral government agencies who may have been critical of the project, such as the EPA, catchment authorities, and local councils). In sum, the proponent uses the RTS to belittle all concerns raised (environmental, social, economic), and either passively or overtly ridicule individual objectors whom they perceive to be of concern (principally doctors of science, authors, and other people of influence).
It is this latter document, the ‘Response to Submissions’, which the NSW Department of Planning systematically agrees with, and refers to in their determination to approve virtually any project that promises ‘jobs and growth’ in any form and no matter the consequences. In another token gesture of democratic process, a community consultative committee (CCC) is appointed to the project, wherein a handful of community representatives from neighbouring shires or towns meet directly with the proponent on a regular (e.g. quarterly basis). The meetings are essentially a face-to face extension of the ‘response to submissions’ process, whereby company representatives defend the project unequivocally, congratulate themselves on ‘best industry practice’ (whether demonstrated or not), and defer responsibility in the case of pollution events (either pre-emptively or in retrospect). As meetings are conducted without any scientific or legal adjudication, the company’s claims and retorts are generally the final word.
This well-oiled system means that the DPE can approve projects without ever engaging with, or responding to, the public directly. The company does it all for them.
Function of the SIA: My concern is that Social Impact Assessments will be deployed not as a means of increasing the stringency of project assessment, but as a means of (a) simply providing additional criteria for industrial proponents to pay lip service to in persuading the public to accept a mine or other extractive facility, whether in their own backyard or elsewhere in the country, (b) providing further industry-spun rhetoric for state and federal planning authorities to reference in justifying decisions already made (almost invariably project approvals), (c) of quashing communities who object on the grounds of actual social impact (with promises of ‘social benefit’, reduced principally or entirely to economics).
Possible Solutions: The best measure of social impact comes from the voice of the society to be affected. Not companies and their private ‘consultants’, government departments or their ministers.
Hundreds of individual ‘social impact statements’ (i.e. regular submissions) were produced by people from communities that stood to be affected by the Dargues Gold Mine, and these were summarily dismissed during its approval process and 3 subsequent expansions. If the Department of Planning gave due weight to written public submissions, and presentations delivered in person to the Planning Assessment Commission (rather than reflexively accepting every word produced by the mining company and its consultants) there would be no need for any separate Social Impact Assessment. Determination of this particular mining application would have been a simple refusal based on the overall negative social/environmental/economic impacts identified, and now to be faced, by surrounding & downstream communities.
An alternative to the present, industry-controlled system for Environmental Impact Statements would be to have these reports commissioned by the Environment Protection Authority or sub-entity with a mandate for environmental and community protection. If necessary, the EPA could task an ‘environmental consultant’ to prepare an EIS based on plans submitted by the proponent / mining company. At no stage should the proponent be allowed to direct or influence the preparation of the EIS, except to provide further information at the request of the EPA. The cost of this assessment should be borne by the proponent via indirect funding, meaning they pay a designated government agency, not the consultant producing the EIS.
The Department of Planning & Environment and its controversial decision-making body, the Planning Assessment Commission (PAC), need to undergo an institutional reform. This should be centred on the elimination of pro-industrial bias and a culture of unaccountability to the public (especially to communities affected by state-significant resource projects). This could begin with thorough screening of Department employees to remove the ex-mining & extractive industry fraternity from executive roles within project assessment and determination (including the so-called independent PAC).
The phrase ‘community consultation’ has been appropriated and hollowed out by industry-government rhetoric. ‘Consultation’ should imply meaningful engagement with the public, i.e. that communities affected by industrial projects actually have a say in the matter of if and how a mine or other project is developed. What we have today is not consultation but consolation, whereby the community and their designated representatives are told (via responses to written submissions and Community Consultative Committees) that their concerns are unfounded, that all impacts – environmental, social, and economic, will either be positive or ‘not significant’. Ongoing objection (post-approval) is dismissed and the stated will of the public ignored by proponents and planning authorities alike.
Projects with overall negative social licence (general objection) should be considered to promise negative social impact during any protracted consideration and following any approval by the Department of Planning. Degradation of mental health can and has already occurred in the Dargues sphere of impact. I am personally aware or several individuals living in Majors Creek or downstream who have suffered stress-related health effects caused by having to fear for the long-term quality and quantity of the water supply, soil quality, and other mine-related threats. In addition, their 5+ years of futile opposition to the mine has been utterly demoralising. It has left them feeling abandoned by the state and federal governments (principally the NSW Department of Planning & Environment, Planning Assessment Commission, and the Federal Department of Environment). In certain cases, individual community members cite persecution by the various companies who have owned the mining lease since 2011. The cumulative effect of these stressors – whether perceived, actual, or both – has lead to physical illness in some people. And the mine is not yet operational.
None of this would be revealed by a Social Impact Assessment for the next ‘Modification’ (expansion) of the Dargues Gold Mine, as under the new guidelines the SIA would be commissioned by the incumbent mining company themselves.