According to Greenland's Ministry of Nature and Government, the Australian mining company Greenland Minerals Ltd. (GML), owner of the large Kvanefjeld rare earth elements and uranium mining project, has systematically undermined Greenland's environmental standards. In addition to misinforming the authorities, GML has failed to comply with requests and instructions to correct and supplement its environmental impact assessment (EIA) draft reports.
In a decision aimed at GML's Managing Director, John Mair, and co-signed by Greenland's Prime Minister, Kim Kielsen, and the Department of Nature and Environment's Permanent Secretary, Mette Skarregaard Pedersen, the Greenlandic government has rejected a complaint by GML about the length of the EIA review process, which is now in its fourth year.1
In the decision, it is established that GML frequently contacted high-ranking civil servants and ministers who have no competence within the EIA review process and that these contacts sought to undermine the authority of Greenland's Environmental Agency for Mineral Resources Activities (EAMRA). The government finds that this behaviour is unacceptable and requests GML to abstain from this practice.
Increasing international interest
A reason for GML's disregard of Greenland's environmental legislation could be increasing international focus on the mining project. Greenland is estimated to hold 38.5 million tons of rare earth oxides, while total reserves for the rest of the world stand at 120 million tons. In addition to containing the second biggest uranium deposit (according to GML)2 and by far the largest thorium deposits, the Ilimaussaq-complex, of which Kvanefjeld is a part, has the second largest deposits of rare earth elements in the world.
Lately, Kvanefjeld has not only been the object of interest from the Chinese government, but also from the Trump administration. Both have signaled that they want the mining project to move forward. Earlier this year, the Chinese company Chinese National Nuclear Company, CNNC (formerly the Chinese Ministry of Nuclear Industry, which built the first Chinese atomic bomb and hydrogen bomb), formed a joint investment company with another Chinese company, Shenghe Resources Holding, which is the biggest shareholder in GML. Many expect that the Chinese could take over the mining project, if GML is granted a mining license.
Furthermore, the U.S. Geological Survey has carried out explorations in the area and recently the American ambassador to Denmark visited Narsaq – the town located only 6 km from the projected mining site – accompanied by energy experts from the U.S. State Department. According to some sources, GML may even have been involved in the process that led to the Trump administration's offer to buy Greenland.3
Lack of documentation
It is expected that the government's rebuttal of GML will prolong the EIA process for some time. GML submitted its application for a mining license to EAMRA in June together with its fourth EIA draft report.4 The three previous drafts had all been rejected because of lack of documentation. The same month, a Memorandum of Understanding between the Greenland and U.S. governments to explore minerals in Southern Greenland was signed.5
Nonetheless, the timing of the submission was surprising, considering that EAMRA had identified a series of issues that had not been sufficiently addressed by the mining company. Among other things, GML is criticised for not providing a comprehensive assessment of the earthquake risk in the region, final results of tests of toxic elements during extraction and processing, final radiological estimates and results of investigations of impacts of radioactive minerals, and for failing to describe the alternatives regarding management of tailings and the shutdown of the tailings facility.6
Kvanefjeld's negative environmental impact
For years, the Kvanefjeld project has also been criticized by Greenlandic and Danish NGOs and green groups for not living up to Greenland's environmental standards. Despite the fact that Greenland is not a signatory to the Aarhus Convention and attempts from GML to block their access, they have continuously been able to publish the mining company's EIA draft reports.7 The consensus is that none of the reports address the concerns of the local population, NGOs, politicians and international environmental and health experts.
Considering that there is no real difference between the latest and earlier EIA draft reports, criticism of the mining project largely remains the same. In 2017, at the request of the NGOs and green groups, Jan Willem Storm van Leeuwen, an expert in technology assessment and life cycle analyses of energy systems in the Netherlands, published an analysis of GML's first draft report8, which is still valid.
Among other things, he concludes that extracting the full resources from Kvanefjeld would generate a tailings volume about ten times larger than in the current design of the mining project. Because the ores also contain thorium in concentrations 3-10 times higher than uranium, the radioactivity of the tailings would be 3-10 times higher than might be expected based on the presence of uranium alone.
The storage of the tailings in the tailings facility in the Taseq basin would generate health hazards due to unavoidable events, even if the dams would behave as planned. This risk would grow with time, the more so after the final closure phase when inspections and maintenance might come to an end.
In addition to authorized discharges, also unintentional, but unavoidable discharges might be expected caused by leaks, spills, seepages and accidents. In the course of years, a vast area around the mine would become contaminated by radioactive and non-radioactive materials from the mine, many of which may be highly toxic. People living in the contaminated area would be chronically exposed to radioactive and other toxic species via drinking water, food and air.
Seafood would become contaminated as well, due to the substantial discharges of wastes into the coastal sea. Bioaccumulation of radionuclides and nonradioactive chemicals in the food chain may also become a serious problem.
Furthermore, according to van Leeuwen, the quality of the uranium ores at the Kvanefjeld is very near the energy cliff, due to the low grade and the mineralogy of the ore. This means that a nuclear energy system using uranium from this ore, measured from cradle to grave, is an energy sink and does not deliver useful energy to the world.
Unlikely to meet environmental and climate requirements
J.W. Storm van Leeuwen's estimates are compounded by more recent assessments. In 2018, the NGOs and green groups involved in the Kvanefjeld campaign asked for an expert opinion on the embankment structures in Kvanefjeld's tailings facility by an independent Austrian expert, heading an engineering office, which among other things deals with the assessment of the stability of dam structures.
After reviewing GML's EIA draft reports, including the latest, and their approximately 70 background documents, he concluded that he could not give an opinion, because there was no plan for or description of the embankment structures. Thus, the project could not be precisely defined and the risks of the project reliably identified9. The lack of documentation has been confirmed by EAMRA as well as Greenland's Ministry of Nature and Environment.
Furthermore, the mining project not only violates the Mineral Resources Act's environmental requirements, but also its climate protection requirements, because it significantly increases Greenland's total CO2 emissions.10 Initially, the CO2 emissions were expected to increase from currently almost 10 tons CO2 per capita yearly to 16 tons ‒ i.e. more than 60 percent ‒ in the operational period, which could be centuries, considering the size of the uranium deposit. In the latest, EIA report, however, the increase is set at 43 percent, from almost 10 tons CO2 per capita to almost 14 tons per year. Nonetheless, it is projects like Kvanefjeld that are perceived to have prevented the Greenlandic government from adopting the Paris Agreement and other international climate agreements.
Threatening the Kujataa UNESCO world heritage site
The Kujataa world heritage site11, which was inscribed on UNESCO's world heritage list in 2017, could also be a nail in the coffin for the Kvanefjeld mining project. The site ‒ a sub-arctic farming landscape ‒ is located very close to the mining area. The property consists of five components, which represent key elements of the Norse Greenlandic and modern Inuit farming cultures.
There have already been calls to put Kujataa on the World Heritage Convention's danger list. Kujataa's unique farming traditions have been a determining factor in designating it as world heritage. However, the Danish Risø National Laboratory has estimated that up to a thousand tons of radioactive dust might be released annually from the open pit mine12. A lot of it will be carried by heavy arctic sea winds across the region, where it will affect among others agricultural activities. Currently, the World Heritage Centre is monitoring the site closely and has asked for additional information from the Greenlandic and Danish authorities.13
As of now, the World Heritage Committee has a no-mining-policy, and in addition to a no-go policy (no mining on the site) there are efforts to adopt a no-impact policy – no mining which could have an environmental impact on the site.
Also, a campaign has been launched to make the Kujataa world heritage site include the Erik Aappalaartup Nunaa Peninsula itself, where Kvanefjeld is located. One of the participants is Alliance for Nature, an Austrian NGO specializing in defending existing and identifying potential new world heritage sites.
So, what is on the cards? There is no denying that popular sentiments towards the Kvanefjeld project have changed. People in Greenland are not eager to see their mineral resources taken over by China and the U.S. The latest incident involving GML makes it unlikely that any decision on a mining license will be made this year. Furthermore, GML's lack of ability to produce an EIA report that meets the environmental and climate requirements of Greenland's Mineral Resources Act could ultimately stop the mining project in its tracks or at least delay it indefinitely.
1. Naalakkersuisut's decision on GML's complaint against EAMRA. (2019, September 6).
See also: GML's complaint to EAMRA. (2019, April 4).
2. GMEL, Kvanefjeld Presentation, Greenland Day PDAC Toronto, p. 4. (2014, March 3).
3. Trump Might Want to Buy Greenland But His Nemesis, China, Is There Before Him. (2019, August 19). Forbes. http://kortlink.dk/forbes/22rfp
4. Kvanefjeld Project. Environmental Impact Assessment. (2019, June). Greenland Minerals & Energy A/S.
5. Joint U.S.–Greenland technical engagement through a new MOU on mineral sector governance. (2019, June 6).
See also: US enticed by Greenland's rare earth resources. (2019, August 20). Financial Times. https://www.ft.com/content/f418bb86-bdb2-11e9-89e2-41e555e96722
6. Kuannersuit ‒ Greenland Minerals har ansøgt om udvindingstilladelse. (2019, July 25). Kalaallit Nunaata Radioa. https://knr.gl/da/nyheder/greenland-minerals-har-ansøgt-om-udvindingsti...
7. All the draft reports can be found at NOAH Friends of the Earth Denmark's uranium website: http://www.noah.dk/urangruppe
8. Jan Willem Storm van Leeuwen. (2015, October). Mining at Kvanefjeld. Comments on: Kvanefjeld Project. Environmental Impact Assessment, Greenland Mineral and Energy Limited Draft, prepared by Orbicon A/S.
9. Kuannersuit: Holdbarheden af dæmningen er ukendt. (2019, April 28). Sermitsiaq.
10. The Kvanefjeld project does not meet Greenland's Mineral Resources Act's environmental and climate requirements. (2017, March 10). NGO Press release. http://kortlink.dk/noah/twef
11. Kujataa Greenland: Norse and Inuit Farming at the Edge of the Ice Cap. (2017, July). UNESCO.
12. Kim Pilegaard. (1990, September). Preliminary environmental impact statement for the Kvanefjeld uranium mine. Risø National Laboratory. p. 44. http://kortlink.dk/dtu/k5vh
13. Communication from UNESCO World Heritage Centre to NOAH Friends of the Earth (2019, October 1).