MAC: Mines and Communities

SD Unsustained: A critique of the MMSD project

Published by MAC on 2002-04-17

Sustainable Development Unsustained: A critique of the MMSD project

Prepared for the Society of St Columban by Nostromo Research

London, April 17 2002

In one of those tales which used to be called "moralities" - and may have originated in India or Sri Lanka - a posse of philosophers gathers in a cave. Each invites the other, just by touch, to examine the object in the centre of the darkness, then say what it is. Touching a leg, one of the wise men promptly declares it an ancient mango tree. Another, fondling the trunk, is convinced he's located a python. A third - who's reached for an ear - loudly announces discovery of a new variety of lily pad. And so it goes on. Not one of our Wise Men takes either the time, or has the insight, to identify the animal for what it really is - a bloody big white elephant.

Just as this critique was being finished, the Mining Journal published comments on the MMSD report from one of mining's most eloquent aficionados. [Philip Crowson's letter, published in the Mining Journal of April 12 2002, was co-signed by David Henderson of the Westminster Business School, London].

Philip Crowson works for the Centre for Energy, Petroleum and Mining Law Policy (CEPMLP) at the University of Dundee, Scotland. For several years he was Rio Tinto's chief economist and is the author of a large number of works on metals markets, pricing, and mine viability. Crowson was the only mining industry representative of any note to intervene at the UN conference on the environment and development (UNCED) in 1992. Here he argued that patterns of mineral discovery, along with improved extractive technologies, would always yield new supplies of essential metals; those who claimed sources were running scarce due to the profligacy of the industry had got it hopelessly wrong. He has since modified his views, but is certainly no friend of liberal mining critics.

Little surprise, then, that he has now trashed MMSD as the "flawed outcome of a flawed process". He finds its introductory pages "…no more than a recycling of currently fashionable ideas and phrases, preceded by an alarmist sketch of the world today and laced with some crudely misleading economic history." Crowson cannot stand the idea that the MMSD team has now "dignified" NGOs as "civil society". He deplores the "working assumption" that miners would need a "license to operate" through "multistakeholder engagement" before they can lift a sod of other peoples soil. "Disproportionate weight is given to [the arguments of] participants other than national governments, while the problems that may arise from accommodating interest groups such as NGOs and local communities are not squarely faced". If implemented, the MMSD's current recommendations would be "less effective, not more, in contributing to the general welfare".

It's worth quoting Crowson's arguments for several reasons.

First, he undoubtedly represents the views of many executives in his industry. But these are opinions they will be reluctant, if not foolhardy, to publicly divulge at this time. The prime reason for Rio Tinto, AAC, Western Mining and six other companies launching their Global Mining Initiative (GMI) three years ago, was that their credibiilty had sunk to an all-time low. Opposition - specifically from communities on or around exploration and mining sites - had reached an all-time high. This had not only lengthened - sometimes to breaking point - the lead times between conceiving a project and constructing an actual mine. It had also contributed in the previous few years to a reduction in institutional funding for some projects and in particular for exploration.

This is not the place to go into detail on how the architects of the GMI saw the MMSD process encapsulating their own agenda. But the choice of the International Institute for Environment and Development (IIED) in London, as the project initiator, was no accident. It was certainly not just because this NGO knew lots about "development" but almost nothing about mining, and could therefore be relied on to be "neutral": Rio Tinto's hand (or more accurately those of its chairman Robert Wilson) can be seen, not only throughout the process, but well before its official launch. During the late nineties, Rio Tinto had been the first big miner to attempt to engineer "engagement" with its critics, part of the avowed object being to winnow out those agencies and NGOs with whom the company could work from those they needed to marginalise. The chosen process was a series of social and environmental forums (and at least one closed meeting with a few leading development agencies), held in London and Australia. Richard Sandbrook and other colleagues at IIED collaborated with Rio Tinto to try and refine these forums, making them acceptable to a broad band of British NGOs. But the experiment died when the forums were boycotted by almost every knowledgeable critic of the company. Soon afterwards, Rio Tinto enlisted the World Business Council for Sustainable Development (WBCSD) to formally recruit the IIED as head of the Mining, Minerals and Sustainable Development project. (The WBCSD's own progenitor was the Business Council for Sustainable Development, set up at the UNCED conference of 1992, partly to dislodge the UN Center on Transnational Corporations).

At this year's (2002) Rio Tinto annual general meeting, Wilson formally welcomed the concluding stages of the MMSD project, commended the draft report as a job well done, and promised an eager industry response to it at the GMI meeting, to be held in Toronto during May.

He could do little else, since the entire exercise has not only relied overwhelmingly on finance from the industry, but also on data and contacts from within mining circles and some NGOs which already had forms of engagement underway with companies. If industry were to reject the MMSD process at this late stage - let alone in language resembling Philip Crowson's - the other key "actors" on which its viability depends (notably institutional funders, government Export Credit Agencies (ECAs), investment banks, the World Bank and UN agencies) might be more inclined to look for solutions to mining's "hard line" NGO critics. The growing fear of conventional mining companies is that they now really do face the sunset of their years; that, however much they clamour for the opening up of new areas, they won't get the finance to turn a deposit into a working mine. This is why their spokesmen have sought so strenuously to identify, in the public mind, mineral extraction and processing with generic sustainability. That the MMSD itself accepts the equation, virtually without debate, is its greatest single flaw.

So the GMI will not throw the MMSD per se out with all its bilge water. Company executives can quote any of its "findings" with self-satisfaction and self-congratulation. What mining CEO would dispute MMSD's claim that "[mining] companies can help strengthen society's ability to solve environmental problems of all kinds (sic)"? (As the German philosopher, Hans Magnus Enzensberger, pointed out three decades ago, this is the compensatory role which extractive multinationals - he instanced Royal Dutch/Shell - have been carving-out for themselves since the rest of us discovered they were seriously polluting the planet). However, MMSD has refined this formula even further: one example being its spurious claim that an inventory of flora in West Papua (which it calls "New Guinea") "would [not] have been created (sic) if not for the support of PT Freeport Indonesia" [MMSD Daft Report, London, Chapter 10, page 40]

A goodly chunk of the report's Chapter 10 discusses who should bear the responsibility for clearing-up past or abandoned wastes. Clearly the industry cannot do so and remain economically viable. MMSD is in no doubt that the rest of us will have to bear these costs (if they're met at all) since "we" have reaped the rewards of falling metal prices - presumably in fast cars, microwaves, deep freezers - over many years. ("Those who benefited from failure to internalise environmental costs in the past were, in economies based on competition, past consumers who got lower prices for what they consumed" [Chapter 10, page 23]) This type of market-based "solution" gratifies capitalism's apologists no end, while completely failing to redress the structural inequalities that the poor have inherited over many generations.

The second reason Crowson's views should not be peremptorily dismissed is that, in short compass, they cut to the quick of the myth that sustainable development - as defined by Brundtland and embellished by UN development agencies and "civil society" - is compatible with current modes of mineral exploration, excavation, processing and waste disposal. If MMSD had acknowledged from the outset that mining, as opposed to minerals usage, was incompatible with sustainable development, it would have risked being left - if not without a project, then certainly without corporate sponsors.

But others could then have taken up the much more coherent and comprehensible task of identifying those mining methods which are clearly unacceptable, as well as ones which could be open to negotiation. Before bounding uncritically into "multi-stakeholder" forums, they could also have critically analysed the goals of different modes of engagement and exchange. Above all - and from project conception - they should have been able to identify the crucial designers of the process: local communities, workers, small-scale miners and women.

The MMSD spectacularly flunked these issues. Above all it drew Indigenous community representatives into its process only towards the end, having spectacularly ignored them at the outset.

The only truly practical environmental recommendation it now comes up with is that riverine disposal of tailings should be banned [Chapter 10, page 27]. (It's reasonable to speculate that, unless BHP - now BHPBilliton - had renounced the practice thanks to the costly expensive disaster of its Ok Tedi, mine in Papua New Guinea, MMSD might not have ventured even this modest proposal).

The report completely fudges what, for a growing number of Asian-Pacific Indigenous communities, is the equally harmful practice of deep sea tailings disposal, and simply parrots the industry's position: "[T]here is little agreement or evidence about [STDs] long-term effects…In some circumstances deep-sea mine disposal might be an option deserving serious consideration - when the mineral deposits are on islands that have little spare land, when available space is at risk of flooding or when the stability of land disposal facilities is uncertain because of high rainfall or seismicity".

In addressing other dubious extractive techniques - SX-EW, heap leaching, and HPAL (High Pressure Acid leaching) - the MMSD is equally complacent. For example, HPAL is commended for its lower capital and operating costs and superior metal recovery which "may have a significant effect on the location and nature of nickel mining in the future" [Chapter 6, page 29]. There is absolutely no recognition that - as recently dramatised in Mindoro, the Philippines - this "new location" factor may sound the death knell for some traditional farming or fishing communities.

Are these lacunae (some critics may call them betrayals) the result of pandering to individual companies or consultants (including those on the MMSD's Assurance Group)? Perhaps. More likely they derive from implicit, yet untested, assumptions lying at the core of MMSD. One is that new technologies, by ostensibly reducing some unsustainable inputs (notably energy and land), must be allowed much more field experimentation before they are written off - even if they sacrifice specific community and environmental values. A second is that greenfield projects are implicitly less dirty and dangerous than brownfield ones (even when revived and overhauled). A third is that small and medium sized companies are inevitably greater socio-environmental vandals than the likes of Rio Tinto, BHPBilliton, Anglo American, Freeport, Phelps Dodge or Coal India Ltd. Not only are these assumptions highly suspect, they are nowhere tested to instruction in the report.

We therefore find MMSD endorsing some of mining's worst endeavours, while waving the banner of "best practice". Its report, as it stands, is one which captains of the industry will welcome for what it licences, disregard for what it challenges in their basic thinking, and hold up - all five hundred pages - as an earnest of their readiness to consider (while not actually implementing) fundamental changes.

It is not really surprising that Philip Crowson should attack MMSD in terms strikingly similar to ones employed by those who have learned to mistrust almost every promise made by mining companies in recent years. Ironically, both parties to this longstanding conflict have got what they expected from the MMSD process: confirmation that it was and is "fatally flawed". It was a project neither of them really wanted but for diametrically opposite reasons. Regrettably, now that MMSD reaches obsolescence, those who may suffer worst loss of influence are the groups which did go along with its ill-conceived premises and parameters - such as around 150 Indigenous persons, several major NGOs (including WWF and Conservation International), a roll-call of disparate "experts" and some trade union bodies.

Sprinkled through the report are references to numerous multilateral initiatives. It's difficult to tell what individual weight MMSD gives to these. However, eight "candidates" for a Declaration on Mining, Minerals and Sustainable Development are listed. Except for the ILO and the UN Rio Declaration of 1992, all of them are corporately led or influenced. [Chapter 16, page 10]

Of perhaps more concern, however, is the report's recommendation for the formation of new bodies and new initiatives. When the MMSD first outlined its agenda critics warned it would be drawn inexorably into approving a greater role for "actors" which had failed to comprehend Sustainable Development, specifically as defined and implemented by rural and Indigenous communities. Where would the World Bank/IMF end up in the rank of MMSD proposals? After all the Bank has played the major role in undermining sovereign state regulation of the industry through imposition of Structural Adjustment Programmes (SAPs). For more than two decades it had savaged many protective national mining codes in favour of increased foreign penetration, influence and resources plunder. The MMSD ignores all this disturbing history. (At one point it gratuitously dismisses all opponents of "globalization" as if they were confined wholly to the North). Nor does it anywhere critique the World Bank's recent proposals to dilute its already weak guidelines on Indigenous Peoples.

Having defined the Bank's permitting process as the global standard for other funders to follow [Chapter 6, page 34], it is hardly surprising that profound doubts about the Bank's integrity, objectivity and procedural capacity, play no part in the report. The Bank's current EIR (Extractive Industries Review) is mentioned, but those strident criticisms of it, made recently by a raft of environmental and human rights NGOs, receive no acknowledgment.

What of the United Nations? Many consider this the second multilateral development agency to have blotted its copybook by snuggling up (through Kofi Annan's Global Compact) to multinationals with appalling reputations. Some claim that the UNEP has also compromised its integrity (for example, by sealing a deal with Rio Tinto). But MMSD greets the Global Compact without reservation; the UNEP Declaration (on sustainable development practices) is also commended [Chapter 3, page 14].

Having said that, we don't find MMSD unequivocally recommending that these two agencies should lead the mining industry towards sustainable development. Some observers will view this with concern: they still place faith in the reform of the World Bank and its vetting procedures, or are attracted by the concept of an Ombudsman (such as already employed by the World Bank-IFC-MIGA, or working for the Australian development agency, Oxfam-CAA). There are also some who believe the UN can be brought back from the brink of hopeless surrender to corporate influence. But even those who don't have confidence in the World Bank or the UN should be concerned at the "scatter gun" effect of setting-up new bodies as recommended by the MMSD. Won't this deter, rather than encourage, radical analysis of the roles of extractive multinationals? Would these groups not be forced to compromise their function as "standard setters" by reducing their demands to the lowest common denominator ? Surely, the greater the number of new initiatives, the less likely that any of them will be accepted as a regulatory body with the capacity to investigate and police the violations of an enforceable code?

And here is perhaps the final irony in Philip Crowson's damning of the MMSD. He complains that the project has wilfully undervalued the role of governments compared with that of "other participants". Crowson doubtless sees "stable" governments as the natural ally of corporate mineral expansion; his own organisation (the CEPMLP) has been at the forefront of forging such relationships. Yet the point is one which even his most implacable critics can partially concede. They would argue that it is only governments - however ill-equipped, insensitive and sometimes downright destructive they have proved with regard to safeguarding the rights of their own peoples - which can protect against the industry's worst violations. However, the draft report spends more time elaborating on the weaknesses of governments, than it does asking what can be done to strengthen democracy and substitute the voluntarism beloved of the companies for the mandatory role which elected officials should fulfil.

The mining industry and the World Bank/IMF have been able to write many of their own rules, of entry into land, tax breaks, and other concessions, for around a hundred nation states. To continue along this route suits the industry to a tee, because the process already weakened much opposition to mining in several nominal democracies (such as Papua New Guinea, pressured by BHP and Rio Tinto; or the USA's OPIC agency succumbing to the threats of Freeport). Governments have been corrupted (notably in west and central Africa, but also in the North) and forced to privatize crucial state assets (as in Peru, Brazil or Zambia). Increasingly they have become over-dependant on fickle private financing, or been exposed to tariff dissolution (as in India). Instead of dissecting and exposing these malign new factors, or proposing radical antidotes, the MMSD pitches the role (and rules) of state mining governance at the level of a miscellany of all the other "actors". Ostensibly the report places a high priority on honest, open and democratic administration. It is therefore all the more remiss when it fails to comprehend the history or present dangers of corporate influence on lawmakers and politicians.

The MMSD timetable has, from the start, been primarily determined and constrained by the mining industry. The forthcoming Toronto GMI-ICMM conference in May will succeed the official demise of MMSD and see official lift-off for the International Council on Mining and Metals (though this has been in existence for some months already and has itself absorbed the International Council on Mining and the Environment). Whatever miners and the ICMM do with the report - and they, above all others, will be able to "cherry pick" it - both the report's occasional objective analyses and its rare condemnations of current practice are fated to be ignored or dismissed. (Guess who's coming to dinner to personally launch the final MMSD report in London? None other than Robert Wilson, Rio Tinto chair, founder of the GMI and vice-chair of the ICMM).

MMSD views of the GMI and the WSSD

"The Toronto Conference [of GMI] could be a place for establishing priorities not just for industry or government, but for a wide range of actors…It could set some guidelines for processes directed at specific issues…It could define the next steps. Beyond Toronto the World Summit for Sustainable Development (WSSD) will be an important upcoming opportunity…[It] is unlikely to achieve any definitive resolution of issues but can be an important step in setting a framework for driving the debate forward faster and better". [Chapter 16, page 29]

Sustaining whom?

It's actually worse than that. For, if you can bear to read the entire report, it becomes clear that academic objectivity has itself been jettisoned. MMSD spokespeople may even acknowledge this profound weakness - while protesting it's due to the fact that many of mining's most experienced critics damned the MMSD from the outset. But this argument doesn't stand up. None of these critics, or community representatives, rejected the need in principle to critically examine mining's central tenets. What was deplored was the way the MMSD was pre-scripted by the industry itself. And it has indeed been a self-fulfilling prophecy. Widely-accepted definitions of sustainable development are grossly distorted to suit what mining companies can accept.

"Applying the concept of sustainable development to the minerals sector does not mean making one mine after another sustainable", claims the report - adding gratuitously "whatever that may mean" [Chapter 1, page 13]. Surely it really means that MMSD cannot demonstrate a single convincing example of a mine that has been unequivocally welcomed by the landholders, served their explicit needs, contributed to regional or national sustainable development goals - while at the same time averting the loss of socio-cultural, ecological, gender and age-based values that, by definition, are non-tradable?

The rot sets in when MMSD asserts that "the idea of 'capital' lies at the heart of sustainable development" [Chapter 1, page 7]. Although the report quickly explains that this concept "goes well beyond the common idea of financial capital" while there is "an emerging consensus that there are in fact some 'non-negotiable' or non-tradable types of capital" [Chapter 1, page 8], in practice MMSD places no absolute prohibition on the sequestration of any place for (or method of) mineral extraction.

One of its most disconcerting, if convoluted, arguments is that IUCN and World Heritage protected status for mineral-rich areas should now be "negotiable" with the mining industry, as well as with inhabitants and national governments. Should this surprise us? Not at all. For MMSD's own version of "Sustainable Development Principles" stresses, inter alia, the necessity to "maximize rents" through "efficient use of all resources natural and otherwise". Governments are enjoined to "encourage free enterprise" - albeit "within a system of clear and fair rules". And, instead of stringent application of the precautionary principle (to which it pays lip service elsewhere) MMSD would have mining companies merely "exercising prudence where impacts are unknown or uncertain" [Chapter 1, page 14].

At the heart of MMSD's final set of proposals is the "Community Sustainable Development Plan (CSDP) " [Chapter 9, pages 45-46]. At first sight this sounds progressive - if somewhat predictable and pedestrian. However, the design of such plans is principally assigned to companies. Even though they are supposed not to "lead" the process, in the event of "inadequate" government they are invited to adopt the main implementing role.

As for industry-wide "codes of conduct" (or principles) MMSD has given less thought to these than might have been predicted. Perhaps this is due to the bewildering proliferation of such blueprints over recent years; MMSD views all existing codes as incomplete or problematic. It doesn't prevent the project from citing (obviously with approval) individual corporate examples of codes, such as Freeport and Rio Tinto's on human rights observance in Papua [Chapter 8, page 28]. Nor has it stopped the group from proposing yet another - dubbed the Commitment to a Sustainable Development Code". And here there is no equivocation: the task of developing the code will be firmly in the hands of the ICMM [Chapter 16, page 8]. It will lead to an "expanded-Code system" (sic) by which companies should seek "certification or verification." [Chapter 16, page 9]

There was a fear that mine certification would be used by MMSD to bulwarking the power of the UNEP or World Bank to broker a definitive new set of rules. Existing World Bank standards - its operational guidelines and safeguard policies - are indeed approved as "the norm for the industry" [Chapter 16, page 18]. The Bank is also projected as a possible forum for drafting a broad set of operational guidelines. At another point, we're told that Best practice guidelines could "perhaps" be marshaled under UNEP [Chapter 10, page 28]. MMSD is clearly grasping for a figleaf to cover the huge gap it has discovered between a wagonload of good intentions and structural weaknesses or resistance to implement them.

The report does refer (uncritically) to the Forest Stewardship Council' s brand of certification, and there is passing reference to the World Commission of Dams. Neither of these is made much of in the report. At one early point it is stated that such a process would apply to specific projects rather than companies. But by the end we're left in little doubt that certification is intended as a "company wide" process. However, rather than incisively investigating all impacts of a company's activities, certifiers would primarily assess its commitment to the code. Nowhere does the MMSD dispute the bona fides of the consultants and auditors which vet company operations, although these have been called into question on many occasions (see for example "Into the Unknown Regions: the hazards of STD", SSC and International Books, London and Utrecht 2001)

The view on NGOs

We're told that NGOs (mostly lumped together in the same basket and unidentified, except for those which collaborate with industry) often exaggerate, make dubious claims of damage and lack transparency. Hardly any concrete examples are provided.

While profuse in its praise of some NGO activities, MMSD cannot refrain from reflecting the widespread, but ignorant view expressed by mining executives (notably Robert Wilson in a recent speech), that they exploit "information about issues arising halfway around the world and of which the organization has no direct knowledge". Having set up this straw dog, the report proceeds to kick it. NGOs must "demonstrate that they have considered the values and views of other stakeholders", while "proposed solutions will be more readily accepted if they come from a process that has clearly considered trade offs" [Chapter 16 page 23]. Ah yes, those chimerical "trade-offs" again!

Indigenous Peoples

"Mines and minerals provide an important source of livelihoods that support whole communities and natural economies" declares MMSD at the start of its report [Introduction, pages 11-14]. It's a recurring refrain, but always without adequate backing. When the project addresses gold mining, it becomes almost impossible to distinguish MMSD's view from that of the industry's own self- promotional World Gold Council (WGC) [Chapter 5, page 24] (In fact, MMSD makes claims which even the WGC might balk at).

We're told that "[a] reduction in gold mining would impact the millions of rural poor whose livelihoods are dependent on gold mining". Apparently Mali, Peru (sic) and South Africa are "gold dependent" economics, while the "economic security of people in South Africa and the Middle east, who hold their wealth in gold", will be jeopardized by any fall in the price of this precious metal [Chapter 5, page 25]. (What, they possess no oil, no forest products, no tourism, no agriculture, no fishing, no shipping, no service industries…?) The references here are of course to corporate gold exploitation which must be saved at any cost. In contrast, the future of artisanal small-scale mining (ASM) is left in some doubt. Although fairly substantial recognition is given to the contribution of small scale enterprises to global production of gold, gems and tungsten and to the alleviation of rural poverty, "most ASM activities will - and should (sic) - disappear naturally if progress towards Sustainable Development is made, since alternative more attractive employment options for small-scale miners will become available" [Chapter 13, page 4]. Once again, sustainable development is being entrusted to (if not equated with)- the tender mercies of companies and other bodies, rather than the self-activity and cooperative organization of farmers, rural poor, and Indigenous Peoples themselves.

Given its implicit assumption that mines can - and in most situations will - engender development, it is little wonder that Indigenous Peoples mostly receive a rough ride, at the hands of MMSD. While the roles of women, mineworkers, and small-scale miners are given at least some insightful attention, that of Indigenous Peoples is not. The report uses a definition of "Indigenous" which isn't written by a First Nation or aboriginal group [Chapter 7 page 14]. It doesn't even mention the crucial correlation between the location of Indigenous territories or claimed land, and the minerals rushes of recent years. Some disturbing assertions are allowed to pass completely unsupported. For example, "Land and compensation issues are powerful campaign material and lend themselves well to manipulation designed to achieve political actions that ignore the realities of a local situation". Or again: "Mineral development can create new communities and bring wealth to those already in existence" [Chapter 9, page 3].

At a few junctures the MMSD purports to recognise Indigenous Peoples as the absolute determinants of access to their resources [Chapter 7, page 12]. But at other points, their struggles are wilfully distorted. Says MMSD: "[C]oncerns about 'loss of land' are often more correctly expressed as concerns about the convenience of access, proximity (sic) or loss of investment in the improvement of a particular piece of land, such as tilling (sic) or fertilizing" [Chapter 7, Page 18]. "In much of India", we are told, "…it is hard to see how a significant minerals industry could be built without some resettlement…There are, as so often is the case, trade-offs, " [Chapter 7, page 37]. The statement is all the more reprehensible, given the degree to which forced removals of tribal and dalit communities - either towards landlessness or onto barren lands - has been the common currency of almost all mining in India.

Similarly, while the "right" to give free, prior fully-informed consent to a mining project is thrown into the general pot, few examples are provided of what this should mean in practice. Nor is there any acknowledgment that these principles are currently blatantly ignored at almost every mining project on the planet.

Although the report reflects the proposal (coming out of its two workshops on indigenous peoples) for an international indigenous organization to "monitor the elaboration of international standards as developed during the MMSD process and ensure the effective participation of indigenous peoples in standard setting" [Chapter 9, page 41], there is no insight into how this body will function, who will organise it, who will actually fund it ("Government donors and the international community should support the establishment of this organization" [Chapter 16, page 25] is hardly a prescription), to whom it will be responsible and, above all, what powers it will possess to stop damage being done.

It is as if the past two decades of the UN's International Working Group on Indigenous Peoples /Populations (or the willful attempt by certain mining companies to infiltrate and distort the process) had never transpired.


MMSD has ignored or glossed over many critical issues:

Agenda for change?

According to the MMSD' draft report, its "agenda for change" derives from three tasks: "surfacing" (sic) ideas and information; offering the opportunity to test those ideas with diverse, knowledgeable audiences; and providing a "snapshot" of "where this evolution of ideas stands (sic) and what conclusions can be drawn ".

MMSD claims to have "reviewed existing knowledge" but this is manifestly untrue, since a large number of community-based studies are omitted, along with evidence submitted to tribunals, public hearings, and courts over several years; not to mention voluminous profiles of individual mining companies and critiques of materials use, mining technology et al.

It also says it has "assimilated" suggestions submitted to the project by "many organisations and individuals". On the contrary, far from surfacing, many of these proposals have been left to swim (or sink) in a sea of words.

Hardly surprisingly, the research conducted by staff of the IIED along with accounts of four regional processes, are fairly accessible, but the twelve country baseline studies and the more than 100 expert studies boasted by the project leaders are not.

While the diverse structure for "testing" ideas submitted to MMSD is unexceptional and in theory reasonably open, in practice it has proved for many people confusing to navigate or inaccessible (with its over-reliance on electronic communication, the failure to translate a mass of documentation into Spanish or Chinese and hastiness in preparing some of its input procedures).

Two fundamental flaws in the testing process are barely acknowledged in the MMSD draft report. The first is the carefully considered boycotting of the entire process by many of mining's key critics - above all, community representatives and well-established NGOs. This has undermined the group's claim to global representivity, and in particular the veracity of its regional scooping processes.

Second, the draft report itself was presented on March 4th 2002, with a deadline for all comments by April 17th - thus providing barely six weeks to read a discourse of more than 500 pages and comment on its content. The IIED team will then assimilate and consolidate such comments in just two weeks. - an impossible task if criticisms are to be taken at all seriously. Clearly they will not be.


They called throughout the land for comments on their Endeavors
Miraculously in fourteen days MMSD created its final report.
Thirty days later it quit the earth.
And there was much rejoicing in the mining houses
Because they had got what they wanted all along.

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