ATM reaction to DENR statement on small-scale mining

ATM Statement | May 9, 2023

Alyansa Tigil Mina (ATM) is skeptical of the DENR effort to study the integration of a “big brother-small brother” strategy within the social development and management programs (SDMP) of large mining companies.

While the intent is laudable, we anticipate problematic policy and implementation implications.

First, the SDMP was designed to benefit the communities hosting and affected by mining operations. If the SDMP were to be used to benefit small-scale miners, this in effect takes away financial resources that was originally intended for affected-communities and local governments. Identifying and prioritizing a specific sector, e.g. the small-scale miners, works only to benefit a few and is a form of favoritism, while the broader whole community collectively feels the impacts of the mining project.

Second, because small-scale mining is not allowed within the tenement of a large-scale mining operations, we can only assume that this strategy will be implemented with a large-scale miner putting its SDMP funds to support a small-scale mining project that is outside of its mining tenement. So we ask, why should SDMP funds be used for the benefit of a group that are living or working outside of the affected or impacted areas of the large-scale mining project?

Third, we remind the DENR that it has not completed the registration of all small-scale mining activities throughout the country. Will this strategy be limited to areas officially declared and categorized as “Minahang Bayan”? There are many illegal and unmonitored SSM activities that are not officially Minahang Bayans, will they be covered as well?

This situation may mean the “universe” of SSM workers that can be reached by this strategy is a small set, since DENR can’t reliably identify where all the SSM workers are. It also means that DENR will have to immensely improve the information about SSM who can be targeted to engage. So, the important elements of who are the SSM workers, where are they and what do they need remain unanswered.

Finally, this strategy appears to be a “passing-the-buck” move of DENR. DENR must first show and prove that they have a clear direction on supporting and regulating SSM in the country, which is clearly mandated by RA 7076 or the Peoples Small-scale Mining Act. Amendments to both the Philippine Mining Act or RA 7942 and RA 7076 itself, might be necessary before the government asks the large-scale miners to “share” the SDMP.