Roundtable Discussion; The Future of Mineral Sands. Watch the video here.
Also leaves,
Savannah Resources - Mina do Barroso - Portugal
Lusorecursos - Romano - Portugal
United Lithium - Bergby Lake - Sweden & Kietyonmaki - Finland
Keliber - Rapasaari & Syväjärvi - Finland
Zinnwald Lithium - Sadisdorf - Germany
Etc etc
https://www.google.com/url?sa=t&source=web&rct=j&url=https://www2.bgs.ac.uk/mineralsuk/download/global_critical_metal_deposit_maps/G2122_052_V4CMYK.pdf&ved=2ahUKEwiupb3Issf6AhUTRkEAHTF8AHMQFnoECBcQAQ&usg=AOvVaw1hTPRh7Zk4DEdQ45J9lHPg
You miss the point Borocay, EMH have declared,
"To improve transparency, European Metals has introduced a platform which provides quarterly ESG updates. The platform outlines our ongoing progress using a variety of metrics and indicators which the Company can be objectively measured and compared against."
Nothing to do with socialsuite platform rather EMH falling behind on reporting. There's also the EIA progress which is tbc so can't comment on Environmental aspect of ESG as we haven't got the details.
What ESG credentials?
We're already behind on the quarterly reporting which hasn't been updated since March and EIA is yet to be submitted.
https://esg.socialsuitehq.com/public-esg-report/european-metals-
Article 16 Paragraph 6
The DIA is issued by the EIA authority within the deadline 50 days from the date on which the period established under paragraph 3 ends, or from the date on which the tenderer present the reformulated elements of the project, if this occur before.
Worth noting that the Assessment Committee are appointed by APA "the licensing authority will forward the process to the EIA authority that will appoint an Assessment Committee." Also as per Article 16 "In view of the CA's opinion (Assessment Committee), the EIA Authority (APA) must consider, in conjunction with the proponent (SAV), the possible need to modify the project...)
From an EIA point of view there are 3 outcomes as per Decree Law No. 152-B2017, Favorable, Conditional or Unfavorable based on a weighted assessment (Article 18). The fact that we never received an Unfavorable decision and are now working with APA implies that the Assessment Committee are steering us toward Conditional Approval.
The frustration here is that SAV have exposed yet another issue with Decree Law No. 152-B2017 as the periods within for decisions are all quoted in days with exception of Article 16 quoted as 'six months'. I fully expect that to be revised to 180 days in the next revision.
I have a strong belief that SAV's experience with this process has contributed to the Governments decision to review the applicable laws.
MajorOak, another possible offtaker is Aurora Lithium as they are developing a refinery in Setubal, Portugal. Their target feedstock is Spodumene concentrate putting Atlantic in a good position in terms of ESG with material shipped port to port vs Australian product for example.
For context Aurora Lithium is a JV between Galp and Northvolt and they're leading a project called LiRef with EIT inc. Savannah Resources, Keliber, United Lithium and European Lithium all of which are Spodumene plays.
VW is a significant shareholder of Northvolt so the wider Iberian value chain could see Atlantic Spodumene making it's way through the process to VW Valencia gigafactory onward to VW groups multiple car factories in Spain/Portugal.
It will be more than Cinovec, potentially 11 projects as per Maros Sefcovic comment "For example, if all 11 potentially viable lithium projects in the EU become operational, they could produce some 38% of the expected lithium demand by 2030."
Given this is state aid the list of common interest projects will be published as was the previous iteration for batteries which included multiple players inc. BMW, Umicore, BASF etc.
https://ec.europa.eu/commission/presscorner/detail/en/ip_19_6705
Question is which 11?
Cinovec, Vulcan, Infinity and Savannah were on the list being pushed by the EBA.
https://www.weare121.com/121mininginvestment-london/client/european-battery-alliance/
We then have Zinnwald, Keliber, European Lithium, Lusorecursos, Cornish, Salisdorf? Any other names?
- Consultation on the PDA for Aurora Lithium's refinery closed yesterday. A muted response in comparison to SAV's EIA with only 38 public participations vs our 166. Aurora's full EIA will be submitted in due course.
- The 76th meeting of the Aarhus convention began yesterday. Again no sign of the case against APA moving forward.
- The EIA decision for Lusorecursos mine and refinery has been pending for 127 days. It appears that again the legal framework for approvals have failed.. again.
- Consultation on the simplification of EIA procedures closes this Friday which aims to resolve the approval issues. Once again the local anti mining troops rally to fight in whatever way they can though one of their usual candidates has this view;
"I have no doubt that the diploma will pass. Following the normal legislative course, it will have to be ratified by the President of the Republic, who can send the diploma for consideration by the Constitutional Court. Marcelo will not do so, because he does not want conflict with the Government and does not want to be associated with anything that could “hamstring” the application of PRR funds."
https://paginaum.pt/2022/09/12/simplex-ambiental-um-embuste-a-caminho/
Linkedin curiosities;
- Fortescue appear to be building a team in Portugal. Exploration Manager and HSE Supervisor amongst the roles being filled since March 2022.
- Investment Director of FOSUN International ($126 billion of assets) asked an SRK consulting employee if they where working with SAV. The SRK consultant replied with a zipped mouth emoji. He now works for Aurora Lithium as VP Sourcing.
My take on the current situation is that the Portuguese Government are looking to tighten up the legal/procedural/approvals processes in advanced of the broader release of lithium tender sites. Given the uptick in activity from Aurora, Fortescue and apparent interest or at least awareness by FOSUN, it could be implied that work is progressing in tandem i.e. private companies have been given the nod to mobilise in preparation for tender.
Will any of this effect SAV? no idea, wake me up when September ends.
https://ec.europa.eu/commission/presscorner/detail/en/SPEECH_22_5484
Ladies and gentlemen,
With raw materials becoming the world's most sought-after commodities due to their fundamental role across our economies and societies, we must throw all our weight into secure and sustainable access of raw materials.
Yes, it is an economically complex, politically challenging, and socially sensitive task, requiring us to leave our comfort zone.
But there is no alternative. No time to waste. And no go-it-alone approach.
This huge of a task can only be achieved through an European response, joint efforts and cooperation, involving Member States, industry, environmental groups, financial institutions, and other stakeholders.
Now I'm looking forward to hear what the Czech Republic has in store in this area.
Thank you.
Points to note from the PDA submitted by Aurora;
- Quadrante have produced the PDA for Aurora, the same company undertaking SAVs decarbonisation study (RNS 03/03/22). It's reasonable to assume Quadrante will be using data from both mine and refinery to produce a wholistic decarbonisation strategy.
- Aurora DFS is in progress. The PDA was produced in May - July this year so they're moving relatively quickly, benefit of being backed by a multi billion JV perhaps as cash won't be an issue.
- Aurora EIA to be submitted H1 2023 with a target for approval by Q4 2023. There are no transboundary issues given the coastal location.
- Construction is targeted for 24/25 with the site operational by 2026.
- The investment will be circa 700m
- The plant is tailored for refining of spodumene concentrate and re-processing of lower grade lithium products.
Given the above it seems the timescales for both SAV and Aurora have aligned to hit 2026 and we're using the same consultants in the process for ESG elements. Implied that SAV are taking direction from a bigger player?
Portuguese Gov are separately addressing the EIA procedural issues with consultation closing in just over 2 weeks time. I think it's safe to assume the lithium tender will follow once they've implemented their reform.
Aurora Lithium (Galp/Northvolt JV) lithium refinery in setubal has entered into public consultation for 'EIA proposed scope definition'.
Consultation ends 13/09/22.
https://participa.pt/pt/consulta/pda-do-eia-da-unidade-industrial-de-conversao-do-litio
Sid, look up the Multiannual Financial Framework 2021-2027 and NextGenerationEU (NGEU). There's circa €420 billion allocation between the two for raw materials and environment and a fair chunk of the NGEU will be grant funding. I'm not too familiar with the Czech proposal but the Portuguese one is currently open for bids now, Savannah Resources and GALP have put forward a consortium application with a project total of around €950m
Blonde-ad, EIA status is published in below link. If you download and translate the document under 'Conclusions of the investigative procedure' it details the work required, there's a lot of work to be done, public consultation and transboundary assessment still to get through.
https://portal.cenia.cz/eiasea/detail/EIA_MZP506?lang=cs
This is Europe fingers, we first need to audit the process, get a report on how well we're (not) doing then go back to the EU for further discussion on possible measures to improve the process...
"The European Court of Auditors is launching an audit to find out whether the European Commission has been effective in developing a globally competitive and sustainable value chain for batteries in the EU and whether the projects supported in the Member States maximised the impact of EU funding."
Wolfster, water consumption is definitely in the plan. I'm fairly sure I've seen comments on recycling water within the plant and I'm certain there's details of providing water storage for community use, in particular for the fire service to help with emergency response times.
We can only hope IB! Couple of other related events in September;
- Portuguese Governments consultation for the "Simplification of licenses and procedures for companies in the environmental area" closes 16th September
- Seventy-sixth meeting of the Aarhus Convention Compliance Committee ends on 16th September
External sources has always been the first priority. Below extract from the European Battery Alliance documents;
1. Secure access to raw materials from resource-rich countries outside the EU.
2. Facilitate the expansion/creation of European sources of raw materials.
3. Secure access to secondary raw materials through recycling in a circular economy of batteries.
Well well well, after reading the ministers statement on the changes to the decree law it seems to me SAV have been very closely linked to the reform.
1. Tacit Approval;
"in terms of EIA, it is determined that the deadlines for tacit approval are counted from the moment of receipt of the impact study environment and not from the moment of the "duly instructed" request, which, in practice, allowed the period to only begin when the Public Administration understood it"
"it is determined that a tacit deferral is formed with the mere expiration of the term and that it is formed when there has not been a decision notified to the interested party."
This was always a huge question mark for me as the law clearly stated tacit approval within 100 days. Very happy to see this one personally as it's never quite made sense thus far.
2. Request for new information;
"a system is established to prevent entities responsible for carrying out administrative procedures to make use of procedural expedients to suspend the deadlines for decision... it is determined that these entities can only request for once new documents, clarifications, complementary elements or information to the interested party."
"whenever these entities request new documents, clarifications, additional elements or information, the deadline for decision is not suspended, as long as the individual responds by sending the documents, clarifications, additional elements or information within ten days."
Ring any bells? After the 2020/21 requests for new information we're now supplying a further round...
3. Failure to Decide on time;
"in order to ensure that the administrative procedures remain within the legal deadlines and to prevent them from being stopped during an excessive period of time to wait for opinions not issued in a timely manner... it is determined that opinions issued after the deadline provided for by law are null and void"
To add context this is to ensure "authorizations and other administrative procedures is not itself an obstacle to the adoption of more environmentally friendly behavior", in other words stop messing around and make decisions so Portugal can progress with the expansion of the green economy inc. battery value chain.
4. Questionnaire;
"consider the opportunity cost associated with the time the procedures take administrative processes are stopped (that is, the average duration of the licensing processes, given the to the various stops motivated by requests for additional information, waiting for opinions, etc.), as well as the fact that, in practice, it is often not possible to effectively benefit from the figure of the tacit deferral"
The reform closes with a request for companies to comment on the proposal. I would hope the above extract will be receiving a thorough response from SAV (email to Dale is in the post).
Link if interested though you will need to translate,
https://www.consultalex.gov.pt/ConsultaPublica_
First information I've seen in some time to suggest the Portuguese authorities are pressing on with the tender sites.
Fortescue still have interest in Portugal per their latest annual report so it's interesting to see the state not only seeking further opinion on those sites but also implementing legislation which reduces the weight of local opinion. This will surely be an effort to allow the state to promote projects of national significance i.e. battery value chain.
"According to the statement, the extraordinary session of AM “took place with a single topic under analysis , following a new request for an opinion by the Directorate-General for Energy and Geology, as had happened in 2019, regarding the intention expressed by company Fortescue Portugal Unipessoal Lda., regarding the prospection and research of materials such as gold, copper, tin, wolfram or lithium ”.
Despite the two unfavorable opinions against possible exploitation , Jorge Custódio, mayor of Pampilhosa da Serra, recalled, quoted in the note, the new legislation – published in 2021, which regulates the issuance of opinions by municipalities – indicates that if the request is made by a private company “the opinion of the City Council is binding ”.
But, if the request is made by the State, “the opinion of the Chamber is already considered non-binding ”, stressed Jorge Custódio."
https://observador.pt/2022/07/12/assembleia-municipal-da-pampilhosa-da-serra-unanime-contra-prospecao-de-litio/