Submission to the Swedish Government, translation.1 Sep 2021 08:52
I'm surprised nobody has translated this submission, for info -
Government Ministry of Trade and Industry
Opinion in case no. N2017 / 04553 / FÖF, Jokkmokk Iron Mines AB regarding the application for a processing concession for area Kallak no. 1 in Jokkmokk municipality, Norrbotten county
Jokkmokk Iron Mines (hereinafter JIMAB or the company) has been given the opportunity to submit any comments to the Ministry of Trade and Industry due to the technical assessment provided by ICOMOS and IUCN. As a representative of JIMAB, I may state the following.
As can be seen from the documents in the case, the closest distance from the planned mine to Laponia is 34 km by bird. The Swedish Environmental Protection Agency and the Swedish National Heritage Board have also stated that the mining operations in Kallak will not have any direct impact on Laponia.
It is completely out of the question, and an unreasonable view, that the mine itself can have any direct effect on the world heritage. Mining operations will not be possible to perceive within Laponia.
The potential increase in traffic on existing roads or railways will also not be of such a magnitude as a result of the mining activity that it may lead to an indirect impact of significance for Laponia, which in itself are issues that will be examined in another context.
In their technical assessment, ICOMOS and the IUCN point out that the impact from the mine could still have effects on the reindeer husbandry locally, which could indirectly affect the values ??in Laponia in a more significant way.
However, the prepared environmental impact assessment and in-depth impact assessment regarding the impact on Laponia show that the mine, with the protection measures and compensatory measures planned, will have a limited impact on the reindeer husbandry. In this context, it should be taken into account that the planned mine with operating facilities will use 0.5 percent of Jåhkågaska Tjellde's 2,640 km2 winter grazing area. The investigation describes the potential impact in a complete and correct way. The basis is sufficient to now decide on a processing concession.
The fact that there are two existing mines that are significantly closer to Laponia than the current mine also confirms that it is possible to conduct mining operations outside Laponia without harming the world heritage sites. It is clear, and to some extent understandable, that ICOMOS and IUCN do not have knowledge of how the Swedish environmental assessment system is structured and the fact that conditions on precautionary measures, protective measures and compensatory measures to protect the reindeer industry are issues addressed at a later stage of the environmental assessment process. They also seem to ignore the fact that reindeer and mining industries already coexist in several places in Sweden and that there are good conditions for such coexistence, not least through well-balanced protection measures