Literature Analysis
Empirical Literature review
The study of environmental and sustainable issues in the mining industry has gained importance
within the academic community during the last few years. There are several studies regarding the
extensive interest on this topic which explore strategies of companies on sustainable issues
(Sinding, 1999; Cowell et al., 1999; Warhurst and Noronha, 2000; Hilson and Murck, 2000;
Warhurst, 2001; Hilson and Nayee, 2002; Newbold, 2006; Suppen et al., 2006; Van Zyl, 2007;
Enríquez and Drummond, 2007; Mudd, 2010; Fonseca, 2010 and 2011; Dutta et al., 2012; Hassan
and Ibrahim, 2012). A major argument against the mining sector contributing to sustainable
development is that mineral resources are finite and non-renewable (Cowell et al., 1999) and
therefore the opportunities for future generations to access these resources are reduced (WCED,
1987). Moreover, the main environmental disasters that have increased public concern over the
last 40 years have mainly taken place in the mining and petroleum industries (Warhurst, 2001).
Ghose (2003) has analyzed the environmental management plans in the small-scale mining
industry in India. Evangelinos and Oku (2006) have examined the corporate environmental
management of Greek mining companies and the process of gaining permission to operate. Berkel
(2007) has defined an eco-efficiency framework for the Australian mining industry. Hilson and
Murck (2000) point out that the mining industry can contribute to sustainable development by
minimizing the environmental and social impacts throughout its lifecycle. Gibson (2000) suggests
that any negative effect should be immediately remediated, which would improve the reputation
of mining. And Barbara-Sánchez and Atienza-Sahuquillo (2010) suggest that environmental
strategies focusing on energy conservation, waste reduction, pollution prevention, recycling and
ecological product design lead to improvements in product quality, manufacturing cost reduction
and entrance into new markets. Similarly, Driussi and Jansz (2006) state that some specific
management practices such as environmental management systems, pollution prevention
technologies and environmental training may assist companies to improve their accountability in
relation to environmental issues.
Other authors have studied the connections between environmental degradation and conflict, and
have analyzed the relationships between environmental and social variables (resource scarcity,
population growth, resource abundance, democracy, and poverty). They concluded that those
countries undergoing important economic and political transitions (Esty et al., 1999), and those
with limited economic and political resources (Timura, 2001), are more prone to internal violent
conflicts. As Walton and Barnett (2008) state, environmental conflicts in developing countries are
basically the result of unequal distribution of outcomes arising from environmental degradation
and its related causes. Environmental issues have increasingly more influence on business
strategies and therefore, in strategic decision-making (Rugman and Verbeke, 2000). Companies
may seek only to comply with the law currently in force, or they may go further and adopt more
proactive environmental practices that allow for sustainable competitive improvements (BarbaSánchez and Atienza-Sahuquillo, 2010).
ENVIRONMENTAL CONFLICT
A notion of conflict is arguably at the core of political ecology. Since then, political ecologists
have continued to work on environment-related conflicts, broadening the scope of their enquiries
through the range of actors, contexts, motives and “objects” as well as types of conflicts
considered. Deploying a range of methods and conceptual frameworks, political ecologists are
united by their commitment to offering critical perspectives on often taken-for-granted processes.
Using multi-scalar, historically informed and culturally sensitive entitlement analyses, political
ecology aims to complicate – if not overturn – simplistic narratives of environmental conflicts
driven by “scarcity” or “greed”.
Environmental conflict can be broadly understood as a social conflict relating to the environment.
It can be a conflict over the environment, most notably in terms of access to and control over
environmental resources (Ribot and Peluso 2003). These so-called “resource conflicts” are defined
by Turner (2004: 863) as consisting of “social conflict (violent or nonviolent) associated with both
struggles to gain access to natural resources and struggles resulting from the use of natural
resources.” From a neo-Malthusian perspective, environmental conflicts also consist of conflicts
resulting from environmental processes – especially resource scarcity supposedly putting strains
on social relations – even if the conflict per se is not over those “scarce” environmental resources
(Dalby 2002). A variant to this scarcity-driven argument is the so-called “resource curse”,
according to which the exploitation of abundant resources in undiversified economic contexts
results in high levels of large revenues and resource dependence that would increase vulnerability
to conflicts by undermining the quality of institutions, exposing societies to economic shocks, and
exacerbating tensions over the distribution of resource rents and more generally the costs and
benefits of dominant resource sectors (Le Billon 2012).
Geology of the Asosa region
The major suture zone in the Southern Arabian–Nubian Shield has an oceanic affinity, containing
sutures of meta-sediments of deep-sea marine sedimentary origins (trench sediments), volcanic
rocks of calcalkaline (island-arc) origin and fragments of mafic to ultramafic rocks (ophiolites) of
oceanic crustal origin. The sutures of former oceanic areas that have accreted to form the Arabian–
Nubian Shield consist of linear schist belts, containing phyllitic to greenschist facies metasediments and meta-volcanics. The sutures in the accreted shield areas are the loci for major shear
zones that commonly host gold deposits. The regional structural set-up of the western Ethiopian
shield is shown by three phases of deformation-associated foliations, folding and lineation’s. The
Assosa region is represented by the Kuluck shear zone . The area is also characterized by syn- and
post-kinematic Neoproterozoic granitoid intrusions, Tertiary basalts and a lateritic cover
(extensive over basaltic lavas). Important gold mineralization zones are hosted within quartz veins,
schist units (amphibolite schist, quartz graphitic schist and quartzo-feldspathic sericite schist) and
granitic gneiss. The ANS mineralization is dominated by orogenic gold, tantalum, niobium,
tungsten, rare earth elements, Marble, uranium and tin.
in the north of the region. Granitic gneiss samples also show anomalous gold (4–11 ppm), as do
quartz feldspar biotite schist samples (3–9 ppm) and a quartz graphite schist sample (4 ppm).
Analyzed stream sediment and soil samples also contain anomalous gold concentrations (up to 88
ppm and 4 ppm respectively). The source of the gold is thought to be the subvolcanic intrusions
generated during subduction of oceanic crust at the trench, akin to mineralization in island-arc
systems that we see today in more recent epithermal and porphyry type gold systems. In the north
of the region, there is evidence for gold anomalies that correlate well with faults. These faults
represent ridges relating to shear zone activity. Orogenic gold in veins concentrate in areas of
transgressional shearing, strike-slip faulting and thrusting, as well as at margins and adjacent wall
rocks associated with plutons. This suggests a structural control on the distribution of gold in this
area. Goldbearing major faults of the ANS are interpreted to be the result of NW-directed
compression forming N-trending sinistral transgressional faults and NE-trending thrust faults.
Assosa lies within one such major north-trending sinistral deformation zone. The gold occurrences
typically developed between about 650 Ma and 615 Ma, with gold-bearing quartzcarbonate veins
commonly associated with late to post tectonic calc-alkaline diorite, granodiorite and granite
intrusions emplaced at the end of the Nabitah orogeny (680–650 Ma). There are also anomalous
zones at the edge of the basaltic plateau, which may relate to fluid development, migration and
entrapment between different lithological units. The widespread geochemical anomaly associated
with the mineralized schist units show that this is an extensive gold-bearing hydrothermal
mineralizing system, supported by anomalous Cu, Fe, Ag, As, Se and Mo geochemistry. Due to
the commonly observed coupled occurrence, the mobility of gold may also be controlled by the
paragenesis of sulphides and other secondary minerals.
Developing the ASM sector
Ethiopia’s long history of artisanal mining spans three millennia. The gold deposits in Ethiopia’s
rivers, for example, have been exploited for thousands of years by small scale miners. Today,
artisanal and small scale mining (ASM) happens all around the country and still plays an extremely
important role in Ethiopia. However, much artisanal mining activity remains informal, and
historically the sector has not benefitted from much formal support or regulation from the
Government. Developing and formalising the Artisanal and Small-Scale Mining sector has
become a high priority both for Ethiopia’s Homegrown Reform Agenda and for the Ministry of
Mines and Petroleum (MoMP). Significant reforms are underway to modernize artisanal and small
scale mining, and transform it into a sustainable livelihood for its practitioners. These reforms will
encourage responsible, inclusive small enterprises to engage safely and legally in the mining
sector, and collaborate productively with large-scale mining enterprises. The reforms aim to
increase ASM’s overall contribution to the Ethiopian economy, increase revenue collection, and
create jobs. They also aim to make Ethiopia an increasingly attractive jurisdiction for large-scale
investment and contribute to Ethiopia’s sustainable development(Artisanal and Small Scale
Mining (ASM) in Ethiopia - MoMP).
Ethiopia’s Artisanal, Special Small-Scale Mining National Strategy
In order to accomplish these goals, Ethiopia has recently put in place a comprehensive Artisanal,
Special Small-Scale Mining National Strategy. Its primary objective is to formalize the artisanal
mining sector and promote responsible, inclusive and productive operations that contribute to
sustainable development. In order to achieve this, the Government of Ethiopia has adopted a
coordinated approach to deliver on the following key objectives:
1. Strengthen ASM governance so that it is an attractive and conducive jurisdiction for
investment as part of the formal economy. Three aspects of good governance need to be
strengthened; namely, law and regulation, structural management, and geosciences data.
2. Increase efficiency, productivity and competitiveness of local mineral producers at ASM
level. This incorporates promoting access to capital, access to technology, and access to
skilled labour.
3. Enhance value addition and maximise earnings by ensuring access to local processing
facilities and markets and developing supplier and diversified businesses.
4. Foster an environmentally and socially responsible ASM sector that complies with
appropriate environmental, community, health and safety standards.
5. Promote two important issues that crosscut in each of the other four objectives; namely,
women’s fair participation and beneficiation in ASM and utilisation of indigenous
knowledge.
However, As artisanal mining increasingly requires digging or tunnelling, the environmental
impact of artisanal mining is also on the increase. Unfortunately, few ASM miners are aware of
the harmful effects of mining, which can cause deforestation (excessive tree felling), soil erosion
and land degradation. In general, artisanal miners do not take any rehabilitative or restorative
measures to ameliorate the environmental impacts caused by mining. The MoMP has taken steps
to lessen the environmental impact of artisanal mining by providing a set of guidelines for artisanal
miners, local communities surrounding artisanal mining sites and licensing authorities.
Mining Legislation
As a result of the political change that took place in 1991, a new economic policy has been
introduced in the country. In the mining sector, the government has promulgated a new Mining
Proclamation and Mining Income Tax Proclamation to encourage the participation of private
capital in mineral prospecting, exploration and development activities. The new Mining and
Mining Income Tax Proclamations were issued in June 1993. The Mining Regulations came into
effect in April 1994. The Mining Proclamation No. 52/1993 and the Mining Income Tax
Proclamation No. 53/1993 were amended in favor of investors in 1996. New proclamation is
introduced in order to facilitate the market aspects of mining ‘Transaction of precious Minerals
proclamation No…651’/2001.
The Mining Operations Proclamation No. 678/2010 is further amended by Proclamation No.
1213/2020 which has come into effect as of 14th July 2020. This amendment has added two more
situations in which no license may be granted or held in addition to the existing three, which are
listed out by Article 11 (3) of Proclamation No. 678/2010. The new additions are: a non-citizen of
Ethiopia will not be granted a license where such a person wishes to engage in “construction
minerals excluding those used as raw materials and dimension stones such as sand, aggregate,
selected materials, and others”. Similarly, a foreign investor who would like to engage in any
placer mining operations is prohibited from obtaining or holding a license except where such a
foreign investor “engage in large scale placer mining in partnership with a domestic investor
holding a minimum of 25% share”.
The amendment has deleted Article 51 of Proclamation No. 678/2010, which deals with “Rights
and Obligations of the Holder of a Certificate of Professional Competence” and has replaced it
with new provisions. Accordingly, the amended Article 51 (1) allows any Ethiopians or Foreign
Nationals of Ethiopian Origin to engage in the provision of consultancy services in the mining
sector, where they obtain the required competence certificate from the Ministry of Mines and
Petroleum. Articles 51 (2) and (3) of the amendment allows any person (irrespective of their
nationality) to engage in the mining sector for the provision of “technical services such as drilling,
laboratory or residue stockpile separating services” and in the provision of “technical services in
fieldwork such as health, camping, and catering services.”
Finally, Article 82 of the amendment has added one provision in which it is provided so as “a
mining license or mining agreement issued to a foreign investor or concluded with a foreign
investor to mine construction minerals excluding those used as raw material and dimension stones
such as sand, aggregate, selected materials, and others, including placer mining operation prior
to the coming into effect of this [amendment] Proclamation to continue in force for the remaining
period of their validity”. After the end of their validity period whether these licenses or the mining
agreement will be renewed for a further period or not is to be treated as per the terms and conditions
of Proclamation No. 1213/2020.
Economic benefits
Generally the mining sector in Ethiopia generates revenue from sales, taxes, royalty as well as
generates foreign currency earnings and also saving of hard currency in substituting the imported
mineral related inputs of the country. The mining service sector activities are also contributing for
employment opportunity. In Ethiopia, over 80% of the population is engaged on Agriculture and
related activities. The major export of the country also comes from the Agricultural sector. Even
though the country is believed to have wide mineral potential, the contribution of the mining sector
to the national economy has so far reached a maximum of 6%. The federal government has been
collecting Royalty amount 48.5 Million Birr (4.4 Million USD) from the large scale production of
gold every year for the last three years. The regional administration also collects Royalty from the
small scale and artisanal production of precious minerals, industrial and construction materials.
The total amount of Royalty collected by each region (nine regional states and two cities
Administration) is in few tens of millions of Birr (up to three million US dollars). The amount of
foreign currency earning is About 135 Million dollars every year for the last recent years from the
sales of export of minerals such as gold, tantalite concentrate platinum, decorative dimension
stones and gemstones. This export earning contributes up to 7-10 % of the total export foreign
currency earnings of the country. According to information from the Ministry of finance and
Economic development the contribution of the mining sector to the GDP before 1990’s was less
than one percent; however, there is statistical worked out data from this ministry that the mining
sector contributed 5.8% and 5.5% during the fiscal year 2007/8 and 2008/2009, respectively.
(Ministry of Mines, 2009).
Social Benefits
Mineral sector employment opportunity is becoming significant for the local communities where
there are mineral development activities in their near by areas, as well as for skilled and semi
skilled citizens. The total estimated direct employment of skilled and unskilled human resource in
the mineral sector is in hundreds of thousands of people of the country. This employment record
is revealed in construction and industrial minerals quarries, open pit and underground gold mine,
production of salts from brines and rock salts and the gemstone mining that the distribution of such
activities are found all over the country. The formal artisanal mining activity also reduces the
poverty level of millions daily life including 30 to 40 percent of the women participation. Roads,
electric power from national grid and telecommunication infrastructures have been developed
and/or upgraded due to the development of Gold, tantalum, salt and other major mining projects
in different parts of the country. Different level of health service centers, schools as well as airstrips
were built by the developers of the mine that provides service to the local community as well as
the employees of the mining community. To some extent there is start to train local communities
to engage in other form of business such as plantation of coffee and other trees, introducing
agricultural activities (irrigation) where there had no such type of lifestyle in the area, small
entrepreneurs engagement mainly providing services such as hotel, mini- markets, stationeries, etc
to the Community, etc. (Ministry of Mines, 2009).
Reforming the mining sector
The Government of Ethiopia has set out a clear “Pathway to Prosperity” through its newest HomeGrown Economic Reform Agenda, enabling Ethiopia to reach the status of a middle-income
country by 2030. Considerable progress has already been made. Double digit growth and over sixfold increase per capita during 2004-18 led to a 15 percentage points decline in the rate of poverty
in Ethiopia (poverty headcount ratio of 39% of the population in 2004 to 24% of the population in
2018). A vital part of this ambitious agenda for the country is encouraging private sector
investment, streamlining bureaucratic and regulatory procedures, updating policies, and building
institutional capacity. This is especially true of the mining sector, which is a priority area for the
reforms. Specific reforms for the mining sector that are currently underway are: Formalize and
support artisanal and small-scale mining; Formalize and support artisanal and small-scale mining;
Review gold pricing to reduce incentives for contraband trade; Address political and legal issues
with local communities and incentivizing miners to engage and invest in local
communities; Address technical and institutional barriers against large-scale mining projects; and
Develop policies and institutional capacities to create a sustainable and inclusive mining sector
with strengthened geological information and diversified product base with industrial input focus.
Environmental impact assessment law
Following the provisions of the environment policy, the Ethiopian government introduced the
Environmental Impact Assessment Proclamation (Proclamation № 299 of 2002). The
proclamation requires an EIA process for any planned development project or public policy which
is likely to have a negative impact on the environment. With regard to development projects, the
proclamation stipulates that no person shall commence implementation of a proposed project
identified by directive as requiring EIA without first passing through environmental impact
assessment process and obtaining authorization from the competent environmental agency (Art.
3(1)). In line with this, project proponents must undertake EIA and submit the report to the
concerned environmental body, and, when implementing the project, fulfill the terms and
conditions of the EIA authorization given to them (Art. 7). Moreover, the proclamation allows for
the imposition of a fine between fifty-thousand and one hundred thousand birr on any project
owner who commences implementation of a project without obtaining authorization from
environmental agencies or who makes false presentation in the environmental impact assessment
study report (Art. 18). Furthermore, the proclamation obliges licensing institutions, prior to issuing
investment permits or operation license to projects, to ensure that the relevant environmental
bodies have authorized the implementation of the projects (Art. 3). In addition, it requires such
licensing institutions to suspend or cancel the permit or license they have issued for projects where
the concerned environmental
Policy Framework for EIA
Until 1997, Ethiopia did not have a comprehensive environment policy as such. The
Environmental Policy of Ethiopia was issued in1997 to provide overall guidance in the
conservation and sustainable utilization of the country’s environmental resources in general. The
overall
objective
of
the
environmental
policy
is
to promote the sustainable social and economic development of the country through, inter alia,
sustainable management and utilization of the natural resources of the country. Among the specific
objectives the environmental policy seeks to achieve are ensuring the conservation, development
and sustainable use of essential ecological processes and life support systems, biological diversity
and renewable natural resources; and the empowerment and participation of the people in
environmental management. The environmental policy lays the foundation for environmental
impact
assessment
in
the
country.
the
environment policy stipulates the country’s policies regarding EIA.
It provides for the enactment of a law which requires that an appropriate EIA and environmental
audits be undertaken on private and state development projects; and the development of detailed
technical guidelines that direct the undertaking of EIA and environmental audit in the various
sectors. Furthermore, the environmental policy determines the scope and key elements of the EIA
process. It states that EIA should consider not only physical and biological impacts, but also
address social, socio-economic, political and cultural conditions; and those environmental audits
should be undertaken at specified intervals during project implementation to ensure compliance
with terms of EIA authorization. It also state that environmental impact statements should always
include mitigation plans for environmental management problems and contingency plans incase
of accidents; and that the EIA procedure should provide for an independent review and public
comment on environmental impact statements before they are considered by decision-makers.
While the environment policy provided the policy basis of EIA process in the country, it has one
major limitation: it does not subject public instruments to the EIA requirement, Damtie, M. (2008).
Occupational health and safety
Small-scale mining is an important part of the social and economic infrastructure in many
developing countries and should be accorded sufficient attention to ensure its continued
contribution to local and national well-being. This contribution will not be fully realized until more
attention is paid to improving the occupational health and safety of mineworkers and their
communities. In several countries in Africa, Asia and Latin America, the small-scale production
of gold and gemstones ranks in the top five of national production, yet small-scale mining is largely
ignored as far as safety, health and the environment are concerned. Indeed, prevention measures
for accidents or occupational safety, if they exist, are minimal and rarely enforced. Small-scale
mining has a poor reputation for safety, but there is little data to support or rebut claims that it is
inherently unsafe with high levels of fatal and disabling accidents. Rather, problems relating to
occupational health are more serious and pervasive, touching all who work in and around smallscale mining and processing operations, and their families. As with most aspects of small-scale
mining, occupational safety and health and environmental issues at the mine, at the processing
plant and in the community are closely linked. Because the same people are often involved in both
small-scale mining and processing, safety and health issues in these two parts of the mineral
production process will be discussed together. Overshadowing them both, however, is the question
of community health in the vicinity of smallscale mines, the poor state of which is frequently
directly linked to the mining and processing activities. It is not possible to do other than highlight
here this important issue as part of the overall social fabric of regions that are affected by smallscale mining.
Mines and mining in Benishangul Gumuz
Gold is produced in all the three zone administrations of Benishangul-Gumuz regional state.
Except for Pawe woreda, the remaining 19 woredas are all gold producing. The areas that border
Sudan and South Sudan, which include 9 of these 19 woredas, are where gold mining and trade
in gold are actively taking place.
Few people who pan for alluvial gold do so for more than six months at a time. Because the work
is repetitive and only brings slow returns, it does not hold the attention of miners for long. Critical
shortages and shortcomings of mining sites further deter long stays. For seasonal miners,
agricultural seasons determined the time they can invest in mining. The physical and social
structures of the mining operation also play a role, and this is where changes in present practices
can be observed compared to studies conducted until the early 2010s. Two sites were visited in
February 2020, Melahu in Sherkole woreda and Dulshatalo in Kurmuk woreda, and observations
and accompanying interviews offer deeper insight into these practices. Similar to the mining sites
in the Qeissan area, the two mining areas were located in poorly accessible areas without paved
roads or telecommunication networks; electricity is only provided by generators. In Melahu,
mining operations were subsequently largely manual. It was common for shafts of 40 m to be hand
dug, with only a few miners having access to jackhammers that are powered by the generators.82
Transport was even more difficult than in Qeissan, given the absence of motorized vehicles and
even pack animals; for example, a miner in Dulshatalo described how they must carry crushed
gold ore on their shoulders for 40 minutes to reach the mills.83 But the existence of shafts also
indicates a change in the social structure of mining sites. Sherkole woreda, for instance, is highly
specialized in gold mining, with no significant farming activities in its 19 kebeles and children
dropping out of school to enter into mining activities.84 With an overall population of about
25,000, each of the 19 administrative units has its own gold producer cooperative, licensed at the
regional level by the mining agency, with a concession of 2 hectares of land for exploration and
production.85 But family- and cooperative-based panning with the broad participation of women,
children and elders has begun to give way to individual miners or groups of men digging shafts.
Where there was only alluvial gold before, relatively easy to wash, depleting findings shifted the
work to underground mines, a much more physically demanding task . Families washing gold
together at the river are thus increasingly replaced by male-dominated mining sites. At the same
time, no economic alternative arose for families thus disadvantaged and, as a consequence, not just
the dependence on gold mining but also women’s dependence on income produced by males can
be expected to increase The cooperatives were also intended to regulate operational details, such
as the use of chemicals. When mercury was introduced around the mid-2000s, its use was only
permitted for licensed cooperatives; it still remains illegal for individual artisanal miners to use
chemicals in the washing process.86 Effectively, this cannot be enforced, however, due to a lack
of monitoring capacities.87 The practice may have an even worse environmental impact than in
the Sudanese mining areas, as much of the gold washing takes place in running water, such as
Tumet river in Melahu, a tributary of the Blue Nile.88 In fact, a goldwasher in Melahu stated that
they acquired mercury from Sudan, thereby bypassing regulatory systems in Ethiopia.89
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Keili-et-al-March-2021-Policy-brief.pdf