TIDMBEM
RNS Number : 9267I
Beowulf Mining PLC
17 December 2020
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constitute inside information as stipulated under the Market Abuse
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17 December 2020
Beowulf Mining plc
("Beowulf" or the "Company")
Letter to the Swedish Government regarding the Kallak Iron Ore
Project and Unesco consultation
Beowulf (AIM: BEM; Spotlight: BEO), the mineral exploration and
development company, announces that Kurt Budge, CEO, has written to
the Swedish Government regarding the Kallak Iron Ore Project and
Unesco consultation.
A copy of the letter is shown below:
To:
Mr P Stagnell
Regeringen
(Näringsdepartementet)
Sent by email
15 December 2020
Dear Mr Stagnell,
Re: Unesco consultation regarding the Kallak Iron Ore Project
("Kallak")
I write on behalf of Jokkmokk Iron Mines AB ("JIMAB") regarding
the Unesco review process by ICOMOS International ("ICOMOS") and
IUCN of the planned Kallak mine and the conservation of the World
Heritage Property 'Laponian Area' or Laponia. JIMAB is a wholly
owned subsidiary of Beowulf Mining plc.
To ensure Unesco has the best possible knowledge of the
circumstances in the case for establishing a sustainable mining
operation at Kallak, we hereby provide you and Unesco with some
further information.
We understand that Unesco has recently received a copy of the
Heritage Impact Assessment ("HIA") for Kallak which was completed
and submitted to Bergsstaten (the "Mining Inspectorate") in April
2017.
We would like to make some clarifications due to previous
communication in the case and hope these are helpful to Unesco. We
request that a copy of this letter is forwarded to Dr Mechtild
Rössler at Unesco's Culture Sector, World Heritage Centre.
Timeline, previous consultation and comments
In October 2015, the Mining Inspectorate recommended to the
Government that the Exploitation Concession for Kallak be awarded.
Länsstyrelsen Norrbotten (the "CAB") had previously supported the
economic case for Kallak.
Comments were received from ICOMOS and IUCN in February 2016,
and from Naturvårdsverket ("NV") and Riksantivarieämbetet ("RAÄ")
in March 2017. NV and RAÄ confirmed that Kallak would have no
direct impact on Laponia.
The Company appointed independent consultants to conduct a HIA
and this was completed in April 2017. The previous comments were
therefore made before a HIA had been carried out. The HIA was
submitted to the Mining Inspectorate and for more than 3.5 years
the Company has not received any feedback on it from NV, RAÄ, or
any other party. The HIA remains valid.
Operational Guidelines of the World Heritage Convention and
their relevance to this case
We would like to clarify that the planned mine is not located
within Laponia. Section 172 of the Operational Guidelines for the
Implementation of the World Heritage Convention (the "Guidelines"),
referred to in correspondence between Näringsdepartementet and
Unesco, states:
"The World Heritage Committee invites the States Parties to the
Convention to inform the Committee, through the Secretariat, of
their intention to undertake or to authorize in an area protected
under the Convention major restorations or new constructions which
may affect the Outstanding Universal Value of the property. Notice
should be given as soon as possible (for instance, before drafting
basic documents for specific projects) and before making any
decisions that would be difficult to reverse, so that the Committee
may assist in seeking appropriate solutions to ensure that the
Outstanding Universal Value of the property is fully
preserved."
Since the planned mine is not located within Laponia, the States
Parties, in this case the Government, are not expected to inform
the World Heritage Committee.
Furthermore, the planned mine at Kallak covers an area of 13.6
square kilometres and not 80 square kilometres, as IUCN stated in
2016. Laponia covers 9,400 square kilometres. The planned mine is
0.14% in comparison to the area covered by Laponia.
The closest point from the planned mine to Laponia is 33.8
kilometres. The reindeer migration route from the planned mine to
Laponia is approximately 45 kilometres long.
The location and the size of the mine in relation to Laponia is
shown in the map below.
Please follow the link:
https://beowulfmining.com/wp-content/uploads/2020/12/20201217-Kallak-Proximity-to-Laponia-.pdf
The area of Laponia is by far the largest of the World Heritages
sites in Sweden. Unesco asked for a clarification of the boundaries
of Laponia and other World Heritages sites in 2017. After the
clarification was made by Sweden, Unesco had no further questions
regarding the boundaries (WHC-17/4.COM/8D).
A buffer zone around Laponia has never been considered
necessary. As Section 99 of the Guidelines points out, the
boundaries should be drawn to incorporate all the attributes that
convey the Outstanding Universal Value and to ensure the integrity
and/or authenticity of the property.
Unesco has never questioned the fact that no buffer zone exists.
An objective assessment of the area would conclude that the area is
large enough to meet the criteria set by Unesco for World Heritage
sites.
In addition, Kallak is not included in any Management System for
Laponia as described in Section 111 of the Guidelines. Using the
Guidelines terminology, it is neither 'in' Laponia nor within a
buffer zone, as none exists.
Also, it would seem unreasonable to suggest that Kallak is a
'proposed intervention'. There is no definition in the Guidelines
for what constitutes a 'proposed intervention'. The only definition
that the Company has found is as follows:
"An intervention is any action, other than demolition or
destruction, that results in a physical change to an element of a
historic place." Source: Definition from the Standards and
Guidelines for the Conservation of Historic Places in Canada.
As the planned mine is not within Laponia, nor in in its
immediate vicinity, it is apparent that the mine's development will
not result in such a 'physical change' of Laponia as stated in
Section 111 of the Guidelines.
With reference to the Guidelines, it is apparent that a HIA for
the development of Kallak is not required. Voluntarily, in response
to the comments made by ICOMOS and IUCN in 2016 and NV and RAÄ in
2017, the Company engaged independent consultants to produce a
HIA.
The HIA was submitted to the Mining Inspectorate in April 2017
and for more than 3.5 years the Company has not received any
feedback on it from NV, RAÄ, or any other party. The HIA remains
valid.
Environmental Permitting
When it comes to the transports from a future mine, which could
cause indirect effects on Laponia, it is important to point out the
following facts.
The Exploitation Concession, which is in question, only gives
the Company the right to exploit the mining area. The environmental
conditions for the planned operation will be set in a later
permitting process by the Environmental Court, in accordance with
the Environmental Code.
The transport solution from the mine to the Inlandsbanan railway
has not been finalised, but is likely to follow existing routes and
will be designed and engineered to minimise environmental impacts.
The impacts of transport and necessary measures to eliminate,
reduce, mitigate and compensate for such impacts will be developed
in partnership with the community, including reindeer herders.
It is worth noting that the Inlandsbanan railway is looking to
build its business and considers Kallak as a future customer. The
railway would enable production from Kallak to travel either north
or south. Both JIMAB and the Inlandsbanan are seeking to implement
fossil-free transport solutions in their plans. The development of
the railway, as a sustainable means of transport, will benefit
Jokkmokk and the region.
Given that transport is addressed by the Environmental Court and
does not form part of the decision making process for an
Exploitation Concession, it is premature and outside the norm for
it to be raised as an issue at this time and in this case.
Despite the above, in November 2014, the Company eliminated the
Jelka-Rimakåbbå transport corridor from its plans, responding to
the concerns of the CAB about possible impacts on reindeer herding.
No further specific comments regarding transport have been received
during the last six years.
The coexistence of mining and reindeer herding
Reindeer herding is not a static activity and the importance of
any specific area varies from year to year. Reindeer migrate over
an area, so their presence on and around Kallak is days in the year
and not permanent. The Company has been careful in its analyses to
consider the proposed mine's potential impacts on Jåhkågaska
tjiellde's ("Jåhkågaska") reindeer herding activities in their
totality.
As the Company moves forward with the project, we will work more
closely with Jåhkågaska, to learn from their annual reindeer
herding management plan ("renbruksplan"), such that we can plan
together our mutual activities. Kallak represents only about 0.5
per cent of Jåhkågaska's available pasture lands, and Jåhkågaska's
4,500 reindeer make up less than ten per cent of the total number
of reindeer that are present in Laponia over some part of the
year.
It is an established fact that there are solutions for how to
manage the competing land requirements of mining operations (and
other industrial activities) and reindeer herding.
With regards to migration, for example, reindeer can be moved
around an obstacle, such as a mine, using specific fenced
corridors, Eco ducts or even trucks. A highly relevant practical
case can be found in LKAB-Kiruna-Abisko National Park area. Abisko
is like Laponia, a protected area which is used by reindeer
herders. The reindeer herders at Abisko are maintaining their
traditional activities, whilst sharing their winter pasture with
the industrial activities present around Kiruna and
Svappavaara.
There is no example in Sweden of a reindeer herding coop
becoming unsustainable because of mining, while there are many
examples of reindeer herding and mining coexisting.
Concluding statements
The Company voluntarily prepared a HIA, despite the Guidelines
suggesting one is not required in this case, to give confidence to
stakeholders in the Kallak project that a mining operation can be
developed in a responsible and sustainable manner, and in
partnership with the community.
The Company maintains that its application is comprehensive and,
as stated previously, the future development of Kallak will be
appropriately controlled by the Environmental Court.
To get to this point in time, the Company has been working on
the project for over 14 years, since the first exploration licence
was granted in 2006, and has invested SEK 80 million, defining an
iron ore resource that could feed the Country's ambitions to
manufacture high quality fossil-free steel.
The Kallak project could transform the economic future of
Jokkmokk municipality, creating over 550 jobs for decades to come,
and create much needed diversification in the local economy,
ensuring the sustainability of public services and infrastructure
in the municipality on which the inhabitants employed in other
sectors, such as tourism and reindeer herding, rely.
Through no fault of its own, we hope Unesco understands the
unacceptable delay to a decision being taken on the Company's
Kallak application and that any assessment of the facts, in
accordance with the Guidelines, can be swiftly concluded. We remain
open to assisting Unesco, as required.
Kind regards,
Kurt Budge, CEO & Director Beowulf Mining plc
Copy:
Ms Carin Lundberg, Regeringen Näringsdepartementet
Sven Otto Littorin, Chairman & Director, Beowulf Mining
plc
Magnus Fröberg, Advokat, Fröberg & Lundholm Advokatbyrå
AB
Enquiries:
Beowulf Mining plc
Kurt Budge, Chief Executive Tel: +44 (0) 20 3771 6993
Officer
SP Angel Corporate Finance
LLP
(Nominated Adviser & Broker)
Ewan Leggat / Stuart Gledhill Tel: +44 (0) 20 3470 0470
/
Blytheweigh
Tim Blythe / Megan Ray Tel: +44 (0) 20 7138 3204
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