Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized (ASM) Standards Developing Forest- Small-Scale Mining Smart Artisanal and Suggested Citation: Developing Forest-Smart Artisanal and Small-Scale Mining (ASM) Standards, World Bank, 2021 © 2021 International Bank for Reconstruction and Development / The World Bank 1818 H Street NW Washington DC 20433 Telephone: 202-473-1000 Internet: www.worldbank.org This work is a product of the staff of The World Bank with external contributions. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent. 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Design: Michael Bunnya Kalanzi (MeBK) Cover photos: https://pixabay.com/es/photos/colombia-tierra-negra-monta%c3%b1as-4881384/ https://pixabay.com/es/photos/minas-monta%c3%b1as-geolog%c3%ada-naturaleza-7029193/ https://pixabay.com/es/photos/salinas-maras-per%c3%ba-cuzco-sal-5691615/ Developing Forest- Smart Artisanal and Small-Scale Mining (ASM) Standards Prepared for the World Bank by Levin Sources, the Alliance for Responsible Mining, and Fauna & Flora International FOREST-SMART MINING - ASM i ABOUT THIS REPORT This final report of the project Developing Forest-Smart Artisanal and Small-Scale Mining Standards/Guidance provides an overview of the project’s purpose, scope, methodology, and process; a condensed compilation of the project’s work products; general recommendations for adoption in global and national processes, and a complete compilation of the bolt-on FS-ASM Standard as annex 1. Four additional annexes set out feasibility studies for piloting the bolt-on FS-ASM Standard in Colombia, Peru, Ghana, and Liberia. Authors: This report was written by Felix Hruschka, Estelle Levin-Nally, Blanca Racionero-Gómez, Natalia Uribe, Chris Smith, and Jonathan Stacey, with contributions from Chloe Jacot, Martin Kaonga, Ruby Stocklin-Weinberg, Anna Barker, Alan Martin, Neil Harby, Susan Keane, Marcin Piersiak, and other external reviewers. The country annexes are based on work by local partners Yaw Bitrum (Solidaridad), Chie Murakami (Diamonds for Peace), Monique Liverpool and Beneta Ackah (Petra Mining), and Diana González, Cristian Cifuentes, Jheyson Valdivira, and Victor Hugo Pachas (ARM). Acknowledgments: The authors would like to thank Daniele La Porta, John Drexhage, and Idriss Deffry for their guidance and oversight over the course of the project, all the members of the Global Advisory Panel, miners, and national stakeholders, who gave so generously of their time, pro bono. Disclaimer: This report was prepared from sources and data Levin Sources, the Alliance for Responsible Mining (ARM), and Fauna & Flora International (FFI) believe to be reliable at the time of writing, but Levin Sources, ARM, and FFI make no representation as to its accuracy or completeness. The report is provided for informational purposes and is not to be construed as providing endorsements, representations, or warranties of any kind whatsoever. The authors accept no liability for any consequences whatsoever of pursuing any of the recommendations provided in this report, either singularly or altogether. Opinions and information provided are made as of the date of the report issue and subject to change without notice. This work was performed under World Bank contract number 7197336. Levin Sources is a consultancy and social venture that moves more raw materials through systems where good governance and better business are the norm. We are a core team of strategists, researchers, project managers, educators, and communicators with multidisciplinary abilities and collective expert knowledge in sustainable supply chains, extractives, minerals science & engineering, biodiversity and conservation, human rights and vulnerable groups, responsible business conduct and good governance. We are trusted by the full diversity of players in the minerals system, from Fortune 500 companies and small and medium enterprises to industry associations and certification bodies to nongovernmental organizations and civil society to governments in fragile states and in G-20 economies. Alliance For Responsible Mining is a not-for-profit organization, established in Colombia in 2004. It is a leading global expert on artisanal and small-scale mining (ASM) that aims at facilitating the empowerment of artisanal and small-scale miners, their organization, and the adoption of good practices, promoting favorable environments for the inclusion of ASM in the formal economy. Fauna & Flora International is the world’s longest established international conservation body and a registered charity, which works to conserve threatened species and ecosystems across 40 countries worldwide. FFI saves species from extinction and habitats from destruction while improving the livelihoods of local people. Our vision is a sustainable future for the planet, where biodiversity is effectively conserved by the people who live closest to it, supported by the global community. All text and images Levin Sources, ARM, and FFI © For more information, visit www.levinsources.com, www.responsiblemines.org, and www.fauna-flora.org. ii FOREST-SMART MINING - ASM TABLE OF CONTENTS Abbreviations and Acronyms........................................................................................................................................................................................vi Forward..........................................................................................................................................................................................................................................vii Executive Summary............................................................................................................................................................................................................ viii 1. Introduction............................................................................................................................................2 1.1 Objective, Purpose, and Vision......................................................................................................................................................................2 1.2 Methodology...........................................................................................................................................................................................................4 1.2.1 Drafting the Bolt-On FS-ASM Standard.....................................................................................................................................5 1.2.2 Strategies for Uptake of the Bolt-On FS-ASM Standard..................................................................................................5 1.2.3 Feasibility Studies....................................................................................................................................................................................5 1.2.4 Summary of Deliverables Submitted..........................................................................................................................................6 2 Bolt-On FS-ASM Standard (PCI and Guidelines)...............................................................................8 2.1 Standard Development Process Applied...............................................................................................................................................8 2.2 Rationale and Conceptual Design of the Standard.........................................................................................................................9 2.2.1 General Considerations.......................................................................................................................................................................9 2.2.2 Characteristics and Scope of the FS-ASM Standard..........................................................................................................9 2.2.3 Key Concepts for Principles, Criteria, Indicators, and Guidelines............................................................................10 2.3 Consultation Process........................................................................................................................................................................................13 2.4 Forest-Smart ASM Standard (FS-ASM Standard).............................................................................................................................15 3 Feasibility of Adoption of the Bolt-On FS-ASM Standard in Global Processes.........................18 3.1 Strategies for Standard Setters...................................................................................................................................................................18 3.1.1 GemFair .....................................................................................................................................................................................................18 3.1.2 Fairtrade.....................................................................................................................................................................................................20 3.1.3 Fairmined..................................................................................................................................................................................................22 3.1.4 CRAFT..........................................................................................................................................................................................................24 3.1.5 planetGOLD Phase 2 (GOLD+).....................................................................................................................................................26 3.1.6 LBMA............................................................................................................................................................................................................29 3.2 Other Standard-Setter Processes..............................................................................................................................................................30 4 Feasibility of Adoption of the Bolt-On FS-ASM Standard in Local Processes...........................32 4.1 Selection of Pilot Countries and Pilot Sites........................................................................................................................................32 4.2 Feasibility Studies for Piloting the FS-ASM Standard...................................................................................................................34 4.2.1 Methodology..........................................................................................................................................................................................34 4.2.2 Colombia...................................................................................................................................................................................................35 4.2.3 Peru...............................................................................................................................................................................................................41 4.2.4 Ghana..........................................................................................................................................................................................................47 4.2.5 Liberia..........................................................................................................................................................................................................53 5 Partnership, Leverage, and Funding Opportunities......................................................................60 5.1 Partnership and Leverages...........................................................................................................................................................................60 5.2 Funding....................................................................................................................................................................................................................62 5.2.1 Philanthropic Foundations.............................................................................................................................................................62 5.2.2 Public Funders........................................................................................................................................................................................63 FOREST-SMART MINING - ASM iii 5.2.3 Industry and Multistakeholder Initiatives..............................................................................................................................64 5.2.4 Civil Society..............................................................................................................................................................................................64 5.2.5 Carbon Finance.....................................................................................................................................................................................65 5.2.6 Potential Funding Packaging for Strategic Collaborative Development of FS ASM at Scale................66 6 General Conclusions & Recommendations.....................................................................................68 6.1 Adoption of FS ASM in Global Processes............................................................................................................................................68 6.2 Adoption of FS ASM in National Processes........................................................................................................................................70 References.....................................................................................................................................................74 Appendixes....................................................................................................................................................78 Appendix A: ISEAL Credibility Principles versus FS-ASM Standard Development Methodology...............................78 Appendix B: Summary of Standard Strategies............................................................................................................................................81 iv FOREST-SMART MINING - ASM Figures Figure 1.1 Main Areas of Work Taken to Achieve the Project Objectives........................................................................................4 Figure 2.1 Forest-Smart ASM: The Principle Triangle.................................................................................................................................11 Figure 2.2 Consultation Points with the Global Advisory Panel........................................................................................................13 Figure 4.1 Forest Cover of Candidate Countries..........................................................................................................................................33 Figure 4.2 ASOCASAN Alluvial Mine Site, Colombia.................................................................................................................................36 Figure 4.3 Summary of Gap Assessment Results of FS-ASM Requirement Sections B.5.1–B.5.4 in Colombia......37 Figure 4.4 GIS Analysis of Forest Resources and Deforestation in the Proximity of the Colombian FS-ASM Pilot Site and Its Buffer Areas (2 km, 5 km)..............................................................................................................................39 Figure 4.5 Sequence of Major Activities, Colombia...................................................................................................................................41 Figure 4.6 A CMO Mine Site and Waste Rock Dumps, Peru..................................................................................................................42 Figure 4.7 Summary of Gap Assessment Results of FS-ASM Requirement Sections B.5.1–B.5.4 in Peru.................43 Figure 4.8 GIS Analysis of Forest Resources and Deforestation in the Proximity of the Peruvian FS ASM Pilot Site and Its Buffer Areas (2 km, 5 km).........................................................................................................................................44 Figure 4.9 Requirements of the Peruvian Mining Regulations versus Requirements of the FS-ASM Standard .46 Figure 4.10 Alluvial Open-Pit Mining Operation of Key Empire Resources in Ghana and Google Earth View of Adjacent Operations.............................................................................................................................................................................48 Figure 4.11 GIS Analysis of Forest Resources and Deforestation in the Proximity of the Ghanaian FS ASM Pilot Site and Its Buffer Areas (2 km, 5 km)..............................................................................................................................51 Figure 4.12 Sequence of Major Activities, Ghana..........................................................................................................................................53 Figure 4.13 Diamond Mine Pits in the Weasua Community Area, Liberia......................................................................................54 Figure 4.14 GIS Analysis of Forest Resources and Deforestation in the Proximity of the Liberian FS ASM Pilot Site and Its Buffer Areas (2 km, 5 km).........................................................................................................................................57 Figure 4.15 Sequence of Major Activities, Liberia..........................................................................................................................................59 Tables Table 1.1 Fulfillment of Objectives 1–3...................................................................................................................................................................2 Table 1.2 Summary of Project Deliverables..........................................................................................................................................................6 Table 2.1 Global Advisory Panel Members and Observers......................................................................................................................14 Table 4.1 Pilot Country Selection.............................................................................................................................................................................33 Table 4.2 Pilot Site Selection.......................................................................................................................................................................................34 FOREST-SMART MINING - ASM v ACRONYMS AND ABBREVIATIONS ARM Alliance for Responsible Mining ASGM artisanal and small-scale gold mining ASM artisanal and small-scale mining ASOCASAN a community council in Colombia CCBS Climate, Community, and Biodiversity Standards CCCMC China Chamber of Commerce of Metals, Minerals & Chemicals Importers & Exporters CMO Comunidad Minera de Ollachea DDG Due Diligence Guidance EGP Environmental Governance Programme (of UNDP) ERP emission reductions program ESG environmental, social, and governance FCPF Forest Carbon Partnership Facility FFI Fauna & Flora International FREL forest reference emission level FRM Frugal Rehabilitation Methodology FS forest-smart FSM forest-smart mining GAP Global Advisory Panel GCRFP Ghana Cocoa REDD+ Forest Program GDL Good Delivery List GEF Global Environment Facility HIA hotspot intervention area LSM large-scale mining MRV measurement, reporting, and verification NDC Nationally Determined Contribution NFMS national forest monitoring system NGO nongovernmental organization NRDC Natural Resources Defense Council OECD Organisation for Economic Co-operation and Development PCI principles, criteria, and indicators Reducing Emissions from Deforestation and forest Degradation and sustainable manage- REDD+ ment of forests and enhancement of forest carbon stocks RGG Responsible Gold Guidance (of the LBMA) SIS safeguards information system UNDP United Nations Development Programme UNEP United Nations Environment Programme UNFCCC United Nations Framework Convention on Climate Change UNIDO United Nations Industrial Development Organization VCS Verified Carbon Standard WECMACOS Weasua Clan Mining & Agricultural Cooperative Society (Liberia) All dollars are U.S. dollars unless otherwise indicated. vi FOREST-SMART MINING - ASM FORWARD “Well-managed forests have the potential to reduce poverty, improve land productivity, create diverse and alternative livelihoods, contribute to a healthy local and global environment, and sustain biodiversity and ecosystem services”(World Bank. 2019a). Deforestation and forest degradation are the second innovative contribution by assessing and developing leading cause of global warming. Forest loss disrupts Forest Carbon guidance and tools for the artisanal ecosystem services, depletes biodiversity, and ulti- and small-scale mining sector, including Forest-Smart mately undermines the fulfillment of basic human Principles, Criteria & Indicators (FSM PCI) into existing rights. The mining sector is the fourth largest driver of ASM standards and certification systems, and to deforestation after agriculture, wood production, and support their implementation by identifying REDD+ urban development. It is responsible for 7 percent of and environmental/Climate funding opportunities and deforestation in tropical and subtropical forests, and develop roadmaps for pilot sites. mining’s presence in forests is significant and growing both for large-scale mining (LSM) and artisanal and The existence of a standard for forest-smart ASM will small-scale mining (ASM) (“Levin Sources and FFI 2020). empower miners and local support organizations (for example, nongovernmental organizations, responsible To tackle the threat that mining poses to forests, the mining and sourcing initiatives, governments, public- World Bank conceived forest-smart mining as part private partnerships) to create the conditions that ensure of their Climate-Smart Mining Initiative, which was ASM impacts on forests are mitigated and forest values launched in 2019. Forest-smart mining (FSM) is mining are better protected. This ability to better manage the that “acknowledges and understands the relationship risks ASM poses to forests and forest values is essential for between forests and other land uses such as socio- protecting the human rights of local communities and economic uses and ecosystem services, and actively Indigenous Peoples. seeks to reduce loss or damage to those uses, and in some cases, promote a net gain for them” World Bank. It will also ensure that artisanal and small-scale miners 2019a. can access responsible financial and consumer markets, to support their formalization and avoid them being The international policy environment is putting greater pushed further into the illicit economy. Indeed, the attention on forests and is beginning to demand improved consolidation of voluntary supply chain due diligence environmental performance. For instance, very recently, efforts into mandatory laws for environmental and the COP26 Global Forest Finance Pledges highlighted human rights due diligence by downstream markets growing global ambition to halt deforestation. Although risks generating permanent exclusion and further it is to be seen concretely how these funds will be distri- marginalization of these miners. buted and used in the mining sector, these pledges are both a threat and an opportunity to ASM and their On the one hand, the miners will have to demonstrate stakeholders, especially regulators. The growing financial that they are putting in place measures to mitigate and political capital in forest preservation might put ASM their impacts on forests in a process of continuous into conflict with those defending forest interests. improvement; on the other hand, it is problematic if downstream actors expect some of the most marginalized Unless we find a way to introduce FSM practices into ASM members of their supply chains to absorb the costs operations, the tightening of due diligence requirements associated with this—it is a shared responsibility. poses a risk, once again, to exclude artisanal miners from responsible global supply chains if they are unable to Finally, an effective Forest-Smart ASM Standard has demonstrate responsible business conduct in relation the potential to make use of carbon markets as a to managing environmental, social, and governance mechanism for project finance for forest-smart ASM risks, including human rights risks. The exclusion of ASM initiatives, by providing project developers with a tool would imply a further isolation and marginalization of to monitor and assess progress toward healthier forests ASM into irresponsible and exploitative supply chains with greater biomass above and below ground relative and business relationships, so minimizing the potential of to baseline, which will store and sequester carbon ASM to redeem families from poverty and perpetuating from the atmosphere thanks to the efforts of more poverty in ASM communities. environmentally conscious and active artisanal and small-scale miners. It is this project’s objective to provide a significant and FOREST-SMART MINING - ASM vii EXECUTIVE SUMMARY The World Bank’s attention to the impacts of ASM on • To design a process to include FSM guidelines and PCI forests began in 2010 when the PROFOR Trust Fund in existing ASM standards and certification systems, as financed the WWF and Levin Source’s ASM-PACE well as targeted government policies and legislation; program “ELL and WWF. 2012. in order to understand • Processes to apply Forest-Smart ASM standards and the impacts artisanal and small-scale mining was having certification systems are developed in selected pilot on the world’s protected areas and critical ecosystems. sites. Feasibility studies are conducted and detailed This included a rapid global review and detailed roadmaps and budgeted workplans are developed” research in globally significant forest landscape types in (World Bank 2020). Gabon, Liberia, and Madagascar, with matched funding supporting additional research in the Democratic This final report provides an overview of the project’s Republic of Congo, Ecuador, and Sierra Leone. This work purpose, scope, methodology, and processes, and a was instrumental to raise awareness of the fact that ASM compilation of the project’s findings, recommendations, is happening in high-value forests and documented the and products. The authors acknowledge with gratitude ways in which it impacts the environment, including the valuable inputs from the Global Advisory Panel, forests. contributing to the conceptualization, development, and validation of the main deliverable, the Forest-Smart In 2017, the World Bank began work on forest-smart Artisanal and Small-Scale Mining Standard (FS-ASM mining as a unique concept as part of its Climate- Standard and Guidelines), produced as annex 1 to this Smart Mining program, building upon the successes report. The report provides general recommendations of prior work on forest-smart agriculture. The PROFOR for the adoption of the FS-ASM Standard in global and Trust Fund financed three related studies on ASM, LSM, national processes. In addition, there is a suite of road and offsets, implemented by a consortium of Levin maps, workplans, and budgets for ground-validating the Sources (as lead), Fauna & Flora International, and the standard in the pilot sites in Colombia, Peru, Ghana, and Swedish Geological Survey (SGAB) in cooperation with Liberia. Freshfields Consulting, which concluded in 2019 with the publication of three reports as well as an executive The report is structured as follows: summary (“World Bank. 2019a, 2019b, 2019c, 2019e) ). These reports sought to identify good and bad FSM Chapter 1 presents the objective, purpose, and vision of practices in the mining sector, to extract lessons learned the project, as well as the methodology on how the bolt- and define the key principles for diverse stakeholders on on FS-ASM Standard was drafted. how to be forest smart. These studies were presented at numerous international forums, with the official launch Chapter 2 describes the rationale and conceptual of the studies at Chatham House, London, and at the design of the bolt-on FS-ASM Standard in detail. World Bank’s Climate-Smart Mining Facility at the World Bank headquarters in Washington, D.C., in March and Chapter 3 outlines key findings and recommendations May 2019, respectively. to the feasibility of adoption of the bolt-on FS-ASM Standard into six private and multistakeholder standards. In 2020, the Forest Carbon Partnership Facility (FCPF) made funds available to the Extractives Industries and Chapter 4 assesses the feasibility of adoption of the Environment & Natural Resources Units of the World Bank standard into selected pilot sites in Colombia, Peru, to carry out the study Developing Forest-Smart Artisanal Ghana, Liberia. and Small-Scale Mining Standards/Guidance, and a sister Chapter 5 outlines opportunities for partnerships, leve- study Guidance to Applying Nature-Based Solutions in rage, and funding. the Large-Scale Mining Sector that examines the scope for mining companies to more robustly finance and Chapter 6 presents general conclusions and recomme- support nature-based solutions. The FCPF funded these ndations. studies to get the private sector more directly involved in financing nature-based solutions. This final report has five annexes. Annex 1 is the main product of this assignment, the FS-ASM Standard and The specific objectives for the project are: Guidelines as a “bolt-on” standard to existing private and multistakeholder standards. Annexes 2–5 contain the • To produce a set of detailed technical guidelines and detailed feasibility assessments for piloting the FS-ASM PCI for FSM ASM; viii FOREST-SMART MINING - ASM Standard and Guidelines with ASM entities in Colombia, • Convert the feasibility study methodology designed Peru, Ghana, and Liberia. as part of this project into a publishable blueprint Chapter 6 of the main report, offering conclusions and • Promote the FS-ASM Standard to emission recommendations. Key recommendations cover the reductions programs in ASM nations with a view to following elements: integrating ASM into REDD+ and voluntary carbon programs. This final report has five annexes. • Aim to have governments consider if/how to use • Publish and promote the FS-ASM Standard under the FS-ASM Standard to guide the development of a Creative Commons license through a concerted regulations and extension services to support ASM communications campaign. to become more forest smart. • Pilot the FS-ASM Standard in the countries and sites • Invite third parties to use the standard as they see assessed for feasibility through this project as well as fit and where they see possibilities for preventing in other countries where stakeholders have expressed deforestation and forest degradation or enhancing an interest (for example, Democratic Republic of regeneration. Congo, Sierra Leone). • Support ASM entities and their stakeholders to • Take an intentional curated approach to seeding be prepared for FS-ASM implementation through and scaling adoption of the FS-ASM Standard capacity building and training. beyond engaged standard setters and pilots. • Develop tailored messages and briefs for different • Support the integration of the bolt-on standard audiences in selected countries as part of a globally into existing standards that have expressed interest. coordinated communications strategy that is localized in partnership with local implementing partners. • Develop concrete guidance and training programs for miners, governments, support organizations, and vulnerable groups like women miners, Indigenous Peoples, and local communities on how to implement the FS-ASM Standard. FOREST-SMART MINING - ASM ix 1. INTRODUCTION 1.1. Objective, Purpose, and Vision Per the project’s terms of reference, “the objective of this assignment is to assess and develop Forest Carbon guidance and tools for the artisanal and small-scale mining sector by including Forest-Smart Principles, Criteria & Indicators (FSM PCI) into existing ASM standards and certification systems, and to support their implementation by identifying REDD and environmental/Climate funding opportunities and develop roadmaps for pilot sites. The specific objectives for the project are: • “Objective 1: To produce a set of detailed technical guidelines and PCI for FSM ASM; • “Objective 2: To design a process to include FSM guidelines and PCI in existing ASM standards and certification systems, as well as targeted government policies and legislation; • “Objective 3: Processes to apply Forest-Smart ASM standards and certification systems are developed in selected pilot sites. Feasibility studies are conducted and detailed roadmaps and budgeted workplans are developed” (World Bank. 2020). Table 1.1 summarizes how each objective has been fulfilled. Table 1.1: Fulfillment of Objectives 1–3 This has been achieved by developing the “bolt-on” FS-ASM Standard, which includes PCI for Objective 1 artisanal and small-scale miners and guidelines for enabling stakeholders. See more information in chapter 2 The project has engaged multiple relevant stakeholders through the Global Advisory Panel, developed six tailored strategies for standard setters’ uptake of the FS-ASM Standard, reviewed Objective 2 ASM regulation in selected countries, and developed a proposition for ASM regulatory reforms in selected countries to facilitate the implementation of FS-ASM. See more information in chapter 3 This has been achieved by conducting feasibility studies and detailing road maps and budgeted Objective 3 workplans in the selected countries: Colombia, Peru, Ghana, Liberia. See more information in chapter 4 The mining sector is the fourth largest driver of livelihoods, and explore ways to engage ASM in carbon deforestation after agriculture, wood production, and finance. In the context of numerous pledges to protect urban development. It is responsible for 7 percent of forests made very recently at the Conference of the deforestation in tropical and subtropical forests, and Parties 26 on Climate Change in Glasgow, the existence mining’s presence in forests is significant and growing of an FS-ASM Standard should facilitate direction of for both large-scale mining and artisanal and small-scale funding into the ASM sector to support the introduction mining (ASM) (Hosonuma et al, 2021). Deforestation of forest-smart mining practices and facilitate continued and forest degradation are the second leading cause of responsible sourcing from artisanal and small-scale global warming. Forest loss disrupts ecosystem services, miners. depletes biodiversity, and ultimately undermines the fulfillment of basic human rights. The existence of an FS-ASM Standard will empower miners and local support organizations (for example, This World Bank–funded project aims to avoid, reduce, nongovernmental organizations, responsible mining mitigate, and manage ASM’s negative impacts on and sourcing initiatives, governments, public-private forests and ecosystem services to enable sustainable partnerships) to create the conditions that ensure ASM’s land use management and to promote sustainable impacts on forests are mitigated and forest values are 2 FOREST-SMART MINING - ASM better protected. This ability to better manage the risks Climate Accords (UNFCCC 2015), United Nations ASM poses to forests and forest values is essential for Guiding Principles on Business and Human Rights protecting the human rights of local communities and (OHCHR 2011), OECD Guidelines for Multinational Indigenous Peoples. It will also ensure that artisanal Enterprises (OECD 2011), Kunming Declaration (UNEP and small-scale miners can access responsible financial 2021), and so on and consumer markets, to support their formalization 5. Large-scale mining companies seeking to enfranchise and avoid them being pushed further into the illicit their ASM stakeholders into larger efforts to mitigate economy. Indeed, the consolidation of voluntary climate change through nature-based solutions or supply chain due diligence effortsinto mandatory laws to minimize their environmental liabilities at the for environmental and human rights due diligence landscape level by supporting ASM, as related eco- by downstream markets risks generating permanent nomic actors, to improve environmental management exclusion and further marginalization.1 On one hand, miners will have to demonstrate that they are putting in 6. Emission reductions projects/programs undertaking place measures to mitigate their impacts on forests in a forest-smart ASM activities operating within the process of continuous improvement; on the other hand, landscape of interest it is problematic if downstream actors expect some of the most marginalized members of their supply chains 7. Downstream companies seeking either (a) to develop to absorb the costs associated with this—it is a shared insetting programs that involve ASM, with a view responsibility. to offsetting and reducing Scope 3 greenhouse gas emissions, (b) to make market-facing claims about The standard has been developed as open source “bolt- their contributions to sustainable development in on” standard to avoid duplicating existing requirements source communities through the implementation and contributing to the proliferation of standards; it of the FS-ASM Standard (for example, in compliance enhances forest and climate requirements of existing with the SD VISta standard2) or (c) to mitigate or standards, guidelines, regulations, requirements, and remedy their Scope 3 carbon or biodiversity debts certification schemes. based on historic impacts 8. Any of the above working in other sensitive eco- It is envisaged that this FS-ASM Standard be used by the systems, noting the general adaptability and appli- following stakeholders: cability of the PCI/guidelines even outside of forests 1. Artisanal and small-scale miners seeking to improve their environmental management and mitigate It can be reasonably anticipated that such usage of environmental risk the FS-ASM Standard will contribute to the project’s expected outcomes: 2. Governments seeking to develop regulations whose enforcement would incentivize the introduction of • ASM standards/certification mechanisms include more environmentally friendly and rights-respecting forest-smart principles and open up opportunities for mining life cycles by artisanal and small-scale miners their application. operating in forests and thereby avoid, minimize, and mitigate ASM’s negative impacts on forests • Governments get the tools to strengthen the sustainability of their ASM sector while contributing 3. Standard setters seeking to strengthen the environ- to their climate commitments. mental and human rights performance of their stan- dards, especially in forested landscapes • Targeted ASM communities get access to technical advice to improve the quality of their activities, open 4. Responsible sourcing initiatives seeking to strengthen up to new markets, and access innovative sources of the environmental and human rights performance funding. of the mining entities they are supporting in order to more solidly support their achievement of the • Development partners define a path to involve ASM UN Sustainable Development Goals (UN 2015), Paris sector in REDD+ development and have identified 1 Examples of due diligence efforts include the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict- Affected and High-Risk Areas (2016), the OECD Due Diligence Guidance for Responsible Business Conduct (2018), and the OECD Guidelines for Multinational Enterprises (2011). Laws incorporating such due diligence efforts include the European Union’s Directive on Mandatory Human Rights, Environmental and Governance Due Diligence (also called the “horizontal due diligence law” [2021b] and its Battery Regulation (2021a). 2 “Sustainable Development Verified Impact Standard,” Verra, accessed July 11, 2021, https://verra.org/project/sd-vista/ FOREST-SMART MINING - ASM 3 forest-smart artisanal and small-scale mining. To validate the FS-ASM Standard, this first version of the PCI and guidelines must now be empirically tested in pilots. This will hopefully demonstrate their practical feasibility, utility, and thus value to sites/projects and developed specific road maps for 1.2. Methodology nature and society, concrete to governments, implementation communities, of forest-smart artisanal and business, and will also identify their gaps and weaknesses methodology Theprocess ofcomprised publicthat three workstreams fed andsuch that small-scale they can go through a further mining. improvement, consultation, into each other (Figure 1.1: Main Areas of Work Taken to finalization, proclamation, and ultimately widespread To validate the FS-ASM Standard, this first version of dissemination Achieve and adoption. the Project Objectives). the PCI and guidelines must now be empirically tested First, the bolt-on FS-ASM Standard was drafted, with the 1.2 Methodology in pilots. This will hopefully demonstrate their practical feasibility, utility, and thus value to nature and society, to support of the Global Advisory Panel (GAP)3. Second, governments, communities, and business, and will also and in parallel, the strategies for uptake and adoption The methodology identify their gapscomprised three and weaknesses workstreams such that they can that into each fedFS-ASM of the Standard into (Figure other 1.1). other existing standards go through a further process of improvement, public were drafted, with the support of some standard setter First, the bolt-on FS-ASM Standard was drafted, with members the of support the GAP. of Third, the to Global conceptually Advisory test the Panel 3 consultation, finalization, proclamation, and ultimately widespread and (GAP). Second, in parallel, dissemination the strategies for uptake and adoption of the FS-ASM Standard into and adoption. standard, feasibility assessments were d0ne at pilot sites other existing standards were drafted, with the support in Colombia, Peru, Ghana, of some and Liberia, standard including setter memberslocal of the stakeholder consultations and the design of workplans GAP. Third, to conceptually test the standard, feasibility and budgets assessments for future pilot were d0ne at pilot implementation. The sites in Colombia, Peru, Ghana, and Liberia, including local stakeholder findings consultations from these feasibility assessmentsandweretheused design of Global Advisory Panel Local stakeholder workplans and budgets for future pilot implementation. to update and The finalizefindings from this first version these of the FS-ASM feasibility consultation Standard. assessments were used to update and finalize this first version of the FS-ASM Standard. Figure 1.1: MainFigure 1.1: Areas of Main Work Areas Taken toof Work Taken Achieve to Achieve the Project the Project Objectives Objectives Drafting of bolt-on Strategies for Feasibility studies FS-ASM Standard standard uptake and pilot design Global Advisory Panel Stakeholder engagement Local stakeholder 1.2.1 Drafting the Bolt-On FS-ASM Standard To draft the FS-ASM Standard, two things were done in parallel: (a) the drafting of a concept note 3 See Table 2.1 in chapter 2 for a list of GAP members. setting the context, and principles for FS ASM, and (b) the establishment of the Global Advisory 3 See Table 2.1 in chapter 2 for a list of GAP members. 3 4 FOREST-SMART MINING - ASM 1.2.1 Drafting the Bolt-On FS-ASM 1. The FS-ASM Standard was designed as a bolt-on Standard standard, meaning that it is a flexible document that can be adapted into other standard setters’ procedures To draft the FS-ASM Standard, two things were done and normative documents. It is not designed to in parallel: (a) the drafting of a concept note setting function as a stand-alone standard: There is no vision the context, and principles for FS ASM, and (b) the for developing a bespoke assurance framework or establishment of the Global Advisory Panel. Feedback formal standard committee or board. was sought from the GAP and the World Bank on the initial concept note and integrated into the outline of 2. It was designed in close consultation with a multi- the FS-ASM Standard, which was also shared and agreed stakeholder committee—the Global Advisory Panel with the GAP. Then the standard drafting process began, — which had an advisory rather than decision- and a first draft was sent to the GAP and the World Bank making role and comprised the target standard for review on the May 22, 2021. After several internal setters. This not only increased the probability of and external iterations, a “field-ready” version of the FS- producing a quality product that would be more ASM Standard was sent to local partners on the July 12, practical and fit for purpose, but also increased the 2021, for piloting in Colombia, Peru, Ghana, and Liberia. probability of adoption by these standard setters as Results from feasibility studies were used to update and they had been involved in its development, had read finalize the FS-ASM Standard, which was sent to the GAP it closely, and had been engaged to consider under for final review on the November 5, 2021. The standard what circumstances they would be able to adopt it. is described in chapter 1 and submitted along with this report as annex 1. 3. The guidelines section of the standard provides instruction to local organizations that can increase Research limitations the likelihood of successful implementation of its PCI by providing support to the artisanal and small-scale • The broad scope of the guidelines has been difficult miners, who typically have low capacity and literacy to tackle; each section could be a very detailed and levels. long guideline in itself. 4. The field-testing of the draft standard generated • In some cases, it was difficult to reconcile different attention and interest from local stakeholders and views on things to prioritize and how to address allowed the consultants to conceptually test it with them in the FS-ASM Standard. All views have been artisanal and small-scale miners and their likely integrated, and broad, balanced consensus was support organizations and stakeholders. sought to the extent possible. • Although GAP members have been quite responsive 1.2.3 Feasibility Studies and engaged, not all members were always able The countries and sites where feasibility studies would to provide timely feedback because of their other be conducted were decided early on. A first short list commitments. That is relatively common when of countries and sites was presented to the World Bank engaging high-profile and busy people in a process. in the inception report. Once countries were agreed, greater detail was presented on sites and candidate local 1.2.2 Strategies for Uptake of the Bolt- partners, and in a dedicated meeting the World Bank On FS-ASM Standard and project team agreed the final selection. Local teams were informed and mobilized. Levin Sources worked To draft the strategies for FS-ASM Standard uptake and with Solidaridad in Ghana and with Diamonds for adoption into other existing standards, the project Peace in Liberia; the Alliance for Responsible Mining led team sent an initial survey to eight standard setters. This the fieldwork with ASM entities in Colombia and Peru. consultation identified the standard setters with the Country regulatory reviews and stakeholder analyses greatest interest and potential for successful adoption were done from February to May 2021. The fieldwork, and impact. Five to six standard setters were short-listed, conducted from July until September 2021, provided a for whom an adoption strategy would be developed: conceptual test of the FS-ASM Standard to gauge the GemFair (diamonds), planetGOLD, LBMA, Fairtrade, feasibility of its adoption, a carbon feasibility analysis, a CRAFT, and Fairmined (all gold). The results of the regulatory review, a local stakeholder consultation, and strategies can be found in chapter 3. eventually the creation of a road map, workplan, and Four important aspects were considered in the stan- budget for implementation of future empirical testing. dard’s design to further enhance the probability of the The results of the field studies are summarized in chapter standard’s uptake. 1; detailed results of the fieldwork in each country can be found in appendices 2 through 5 (separate documents). FOREST-SMART MINING - ASM 5 1.2.4 Summary of Deliverables Submitted The project team reported on its progress at various stages, submitting several deliverables (Table 1.2: Summary of Project Deliverables). Table 1.2: Summary of Project Deliverables Date Document Information November 17, 2020 Inception report Including the action plan, a proposition of candidate sites, initial stakeholder map, stakeholder engagement strategy, sites selection criteria, proposed methodological approach, initial thoughts on marketing, and comms February 27, 2021 Intermediate report Including initial conceptualization of the FS-ASM Standard, principles, and initial strategies for uptake into existing standards November 5, 2021 Interim report The field-ready draft version of the FS-ASM Standard, to be used for the feasibility assessments in Colombia, Peru, Ghana, and Liberia November 15, 2021 Draft final report Including the description of the process to integrate the FS-ASM Standard in existing standards, and a summary of the feasibility December 3, 2021 Final report studies of applying the standards to pilot ASM sites December 3, 2021 Other Field pictures, GIS data, and PowerPoint presentations 6 FOREST-SMART MINING - ASM Source: © Pixabay, parque nacional mole FOREST-SMART MINING - ASM 7 2. BOLT-ON FS-ASM STANDARD (PCI AND GUIDELINES) Per the project’s terms of reference, “the objective to inform the drafting of the PCI), regardless of their of the assignment is to assess and develop Forest scope. Hereby, ASM standards informed on what ASM Carbon guidance and tools for the artisanal and standard setters consider practically feasible at the ASM small-scale mining sector by including Forest-Smart level, and non-ASM standards informed about industry Mining Principles, Criteria & Indicators (FSM PCI) best practice, although often beyond the capacity of into existing ASM standards and certification systems, and ASM. ASM standards were also reviewed for on being to support their implementation by identifying REDD+ and potential “target standards” (standards to which the FS- environ-mental/Climate funding opportunities and develop ASM Standard could be “bolted on”). Carbon- and forest- roadmaps for pilot sites” (World Bank 2020). related standards were only reviewed with for being “source standards.” Objective 1 is “to produce a set of detailed technical guidelines and PCI for FSM ASM.” This is reflected by Based on the standard review, further literature review, the tasks to and the prior field experience of the drafting team, a concept paper was developed (contained in the • “Complete a desk review of various existing guidelines, intermediate report) for feedback from the client (World principles, criteria and indicators linked to internationally Bank) and the Global Advisory Panel (GAP) convened for recognized systems of norms, standards and certification this purpose. On the consultation process, see chapter . systems in value chains (including agriculture and forestry) related to deforestation, forest degradation and The received feedback informed an updated concept restoration of forest ecosystems; paper (summarized in chapter ) and the subsequent standard drafting task, performed by the multidisciplinary • “Complete a desk review to identify a set of best practices drafting team of the consortium. The first draft of the applicable to the ASM sector to avoid deforestation, FS-ASM Standard (contained in the interim report) forest degradation and to promote forest restoration; underwent a similar feedback loop, involving the World • “Develop guidelines for the implementation of FS ASM Bank and the GAP. based on best practices identified; and The resulting updated second draft of the FS-ASM • “Develop a set of PCI for FSM applicable to the ASM sector Standard was then field-tested with ASM entities with different levels of requirements (World Bank 2020).” and consulted with national stakeholders during the feasibility studies for pilot implementations in Colombia, Peru, Ghana, and Liberia, to produce the third draft. 2.1. Standard Development Process Applied The third draft of the FS-ASM Standard was circulated to Process the GAP for final comments, to be included in the final report and the final version of the FS-ASM Standard. The starting point for the development of guidelines, Comments have been received from GemFair, Fairtrade principles, criteria, and indicators for forest-smart mining International, and planetGOLD. Jara Bakx and Linda was the review of a representative sample of mainstream Carstens of Women’s Rights in Mining also reviewed the artisanal and small-scale mining (ASM), mining, and forest- draft standard to ensure that it is adequately gender and carbon-related standards1. All reviewed standards sensitive. These comments have been included in the were considered as “source standards” (standards used draft standard submitted with this report (annex 1). Per 1 Fairmined, Fairtrade, CRAFT, GemFair, Responsible Jewellery Council Code of Practices, IFC Performance Standard 6, IRMA Standard for Responsible Mining, UN REDD+, Carbon Fund Methodological Framework, Verified Carbon Standard (VCS), The REDD+ Environmental Excellence Standard (TREES), Verra–Jurisdictional and Nested REDD+ (JNR), Verra–Climate, Community, and Biodiversity Standards. 8 FOREST-SMART MINING - ASM earlier consultations with each organization, invitations • Principles, criteria, and indicators (PCI) shall guide ASM were also sent to Transparency International (to do an entities to conduct their mining activity in a forest- anti-corruption check) and to the Amerindian Peoples smart manner. This requires a very specific approach, Association (to do an Indigenous rights mainstreaming focusing on forest-specific topics to be complied check), but neither organization was able to contribute. with by ASM entities to avoid, minimize, mitigate, or remediate the degradation and destruction of forest Alignment with Commonly Accepted Standard landscapes. These are presented as “requirements” Setting Procedures that should be specifically applied and adapted to the ASM forest context under consideration. Specific Most voluntary sustainability standards are deve-loped indicators shall explain how to fulfill the criteria and by ISEAL-affiliated standard setters, following the ISEAL how to monitor them. Code of Good Practice (ISEAL 2014). However, given the timeline and resources of the assignment for developing • Guiding principles (guidelines) for governments, the FS-ASM Standard, it wasn’t possible to follow an civil society, private sector, and development ISEAL-aligned (and even less an ISEAL-conformant) organizations shall support stakeholders to analyze standard-setting process, which includes among other the context for forest-smart ASM, identify bottlenecks, things a multistakeholder process and several rounds of and develop a flexible and responsive action plan public consultations. for facilitating its implementation. Such guiding principles can comprehensively cover all aspects Notwithstanding, considering the aspiration of creating that—although relevant to ASM performance—are a “bolt-on” standard for “including Forest-Smart Mining not or only partially covered within the organizational Principles, Criteria & Indicators (FSM PCI) into existing ASM scope of usual ASM standards2. standards and certification systems” (World Bank 2020), this is not seen as a barrier for adoption. In any case, when the FS-ASM Standard is incorporated into any 2.2.2 Characteristics and Scope of the ISEAL-aligned or -conformant target standard, that target FS-ASM Standard standard will undergo a process aligned with the ISEAL According to the aspiration of future uptake by standard Code of Practice. setters and incorporation into their ASM standards, the guidelines and PCI themselves need to have the In the meantime, the project’s methodology was desig- characteristics of a standard as below. ned to seek to uphold the ISEAL Credibility Principles to the extent possible (see appendix A). To be fit for inclusion in existing standards as an adaptable bolt-on standard, the standard needs to avoid to the extent possible duplication of standard requirements 2.2. Rationale and Conceptual Design of the Standard already typically provided by existing ASM standards. ASM standards are typically voluntary sustaina-bility 2.2.1 General Considerations standards in the category of performance standards, regardless of occasionally specifying product standard Earlier PROFOR work (World Bank 2019a) researched a requirements3. Consequently, to be “boltable” to any diverse sample of 21 ASM sites across 12 countries and ASM standard, the FS-ASM Standard needs similar four continents, with variation in geological, economic, characteristics to a performance standard. environmental, social, and governance contexts, and developed a set of principles that incorporated actions The organizational scope needs to be adaptable to to be taken by ASM operators, governments, civil society, ASM initiatives that might adopt the FS-ASM Standard. downstream industries, and development organizations. The standard therefore refers to “ASM entities” as a flexible It concluded that, for mining to be truly forest smart, placeholder for the organizational scope of the adopting all stakeholders must take certain actions, not just the standard or for the legal definition of ASM in any country. miners. The geographic scope of most ASM standards is A forest-smart ASM standard therefore needs to take a predominantly agnostic to landscape types (except two-pronged approach: protected areas). To be applicable as bolt-on to these 2 Usually, ASM standards do not set requirements to be complied with by governments or other non-ASM actors. For example, conformance with requirements for governments is beyond the direct control of ASM organizations and therefore not auditable in a meaningful way. That said, the development of accompanying guidance to governments with greater detail on how to incentivize and enable forest- smart ASM could draw upon the guidelines to facilitate this. FOREST-SMART MINING - ASM 9 standards, the FS-ASM Standard needs to be applicable 2.2.3 Key Concepts for Principles, in any forest landscape, independent of the existence of Criteria, Indicators, and Guidelines carbon finance programs (for example, REDD+, VCS). The geographic scope shall therefore be global in principle⁴. The concept of forest-smart mining, defined simply, is The ecological scope of the standard includes the range mining that acknowledges the interlinkages between of boreal, temperate, subtropical, and tropical forests as forests, their intrinsic values, and other land uses well as wet and dry savanna woodlands, montane and (including socioeconomic uses and ecosystem services), tropical cloud forests, and forest scrub communities. and that actively seeks to reduce loss or damage to those values and, where possible, achieves a net neutral (or even The standard applies to the ASM of any mineral, including positive) outcome. While this may be appropriate for the but not limited to precious and platinum minerals/metals, large-scale mining sector, the ASM sector has resource precious stones, industrial minerals, industrial metals and capacity challenges that need to be acknowledged (ferrous and nonferrous), minor metals, and energy raw and for which adjustments need to be made. materials. By other classifications, this includes minerals traded into export markets (for example, technology critical elements, construction materials) as well as those a). Principles traded in domestic markets (for example, development The realization of forest-smart mining for the ASM sector minerals, including sand) (OECD 2021). needs to be guided by three basic principles⁵, which will underpin and inform the development of criteria In relation to existing law, requirements of national (or requirements) and associated indicators. Principles 1 laws and regulations shall always prevail and supersede (forest ecosystem safeguard and resilience) and 2 (human the PCI of the FS-ASM Standard, unless the latter are rights approaches) serve as key terms of reference higher. This automatically prevents requirements of the informing and guiding the design and implementation standard from contravening or conflicting with national of the PCI through Principle 3, the commitment to laws. This is different for the guidelines. The guiding working through the mitigation hierarchy (Figure 2.1: principles may intentionally go beyond the existing Forest-Smart ASM: The Principle Triangle). legal and regulatory framework, as an inspiration to proactively and innovatively create an enabling context for forest-smart ASM. 3 For example, Fairtrade or Fairmined Gold. 4 This must not be interpreted as a blanket endorsement by the FS-ASM Standard of ASM in any region or landscape, especially not in IUCN Category I–IV protected areas. 5 “Principles” represent core values, and the less they are in number, the more importance each of them gains. This makes it less likely that one of them is dropped in the process of incorporating into other standards. 10 FOREST-SMART MINING - ASM Figure 2.1: Forest-Smart ASM: The Principle Triangle Source: ©Jonathan Stacey. Note: This triangle illustrates the basis for developing forest-smart practices for ASM. ASM = artisanal and small-scale mining. Principle 1: Forest ecosystem safeguard and The crucially important forest values need to be balanced resilience: Biodiversity, carbon, and ecosystem and assessed alongside human rights–based values services that recognize that ASM communities have a right to life and livelihood. Furthermore, there will be wider Mining can negatively impact forests both directly and forest-dependent stakeholder communities whose indirectly. To avoid or mitigate these impacts, mining rights and need for livelihood will require recognition needs to be informed by the range of forest values and consideration. Failure to acknowledge the needs that combine in complexity in the provision of habitat of all forest-dependent human communities in the for species and of ecosystem services for people and development of forest-smart mining practices will likely planet. The identification and acknowledgement of result in intercommunity/stakeholder discord, potential these values provides a key term of reference in the conflicts, and a rejection of and lack of respect for the development of forest-smart actions. If mining activities very forest values that are being advocated. The role and fail to recognize their impacts on forests, then they will significance of Indigenous communities dependent on not become forest smart. The range of forest values intact forests is of key concern. Positive and inclusive encompasses wildlife habitats and associated globally approaches to engagement and participatory decision- threatened or endemic species, and the very ecosystem making as to how natural resources are extracted and services that forests provide by way of carbon storage managed and benefits shared play an important role and sequestration, climate regulation, water supply in ensuring sustainable outcomes for both forests and purification, soils development, and the wide array and people. At both national and international levels, of timber and non-timber products that local and policies may be developed and implemented without global human communities depend upon. In forests meaningful participation by key stakeholders. The design everywhere, but particularly in ecologically intact forests, and implementation of forest-smart practices need to the carbon storage and sequestration functions provide take human rights–based approaches into account to an increasingly valued global ecosystem service. ensure that all rights holders are acknowledged and meaningfully included. The development of forest-smart Principle 2: Human rights approaches: practices needs to be informed by this principle as a key Communities and livelihoods, both local and global term of reference. FOREST-SMART MINING - ASM 11 Principle 3: Commitment to the mitigation criteria as applicable, for continuous progress through hierarchy: Practical approaches to forest-impact improvement plans. Such a structural alignment with avoidance, minimization, and rehabilitation CRAFT might also make sense in view that some ASM standards (GemFair, planetGOLD, and in the future With reference to the two key principles above, the third probably Fairmined) already build on elements of principle—committing to the mitigation hierarchy— the Organisation for Economic Co-operation and provides the means whereby we approach the systematic Development Due Diligence Guidance (OECD DDG)- design of actions (requirements) that forest-smart ASM aligned CRAFT Code. Notwithstanding, for broader can adopt to practically and effectively reduce their adoption as a bolt-on standard, the FS-ASM Standard impacts on forested ecosystems. The development of refrains from prescribing a prioritization mechanism. practical forest-smart PCI—while focusing on what ASM entities/communities can realistically achieve within In general, attention must be paid that all require-ments their levels of capacity and resources—will also need at the PCI level address issues that are entirely controllable to recognize that forest-smart mining is not the sole by the ASM entities (for example, application for a certain responsibility of the ASM sector. The mitigation hierarchy permit). Requirements for which compliance depends can inform how a systematic array of practices can be on the actions of third parties (for example, being developed that enable ASM impacts on forests to be granted a certain permit) are programmed failures. Such avoided (in part), reduced, and rehabilitated. However, requirements that relate to an enabling environment, ASM capacity constraints will limit the extent to which and on which ASM entities cannot be audited because all forest impacts might be avoided and/or mitigated. duty bearers and other stakeholders have a role to play, Such limitations need to be identified, with suggested are therefore placed in the guidelines section of the measures proposed that indicate how governments and standard. the wider community of stakeholders might take on roles and responsibilities that enable a fuller realization of forest-smart ASM. c). Indicators The proposed principles and rationale for their function Regarding indicators, ASM standards apply different as core values underpinning FSM PCI for ASM are procedures for verification. For example, Fairmined discussed in more detail in appendix C of the FS-ASM engages various certification bodies that develop their Standard (annex 1). own compliance criteria (that is, indicators); Fairtrade has its own exclusive certification body; CRAFT relies on first- and second-party assurance and due diligence; b). Criteria, that is, requirements GemFair has De Beers’s proprietary assurance scheme; governments have mine or environment inspection Below the principles are the criteria. They describe/ protocols established by regulations, and so on. prescribe the concrete measures and actions ASM entities have to undertake, or avoid, to be in conformance with To maintain flexibility so that the FS-ASM Standard’s the standard⁶. Terms such as “provision” and “requirement” PCI can be incorporated in all these contexts, are possibly easier to communicate to miners, as they indicators developed for the standard avoid being indicate what an ASM entity must achieve to be deemed prescriptive; rather, they seek to provide guidance on standard compliant, or in more simple terms, what is how conformance of the ASM entity with the standard required to be done. The FS-ASM Standard uses the term requirements could be verified. In other words, indictors “requirement.” are offered as options or inspiration to allow a standard setter to use the indicators that are most likely to work for Progressivity is key at the requirement level. Some their audit system. requirements are more critical than others, and it is unrealistic to expect that ASM entities will be able to comply with all requirements simultaneously and from d). Guidelines, that is, guiding the outset. Almost all ASM standards have some degree principles of progressivity built in. Recently, CRAFT took a new two- layered approach combining stepwise and continuous Mining within forested landscapes is seen with progressivity. A similar approach might make sense for considerable concern in public and political opinion. the PCI for ASM entities: (a) for stepwise progressivity, Mining is a significant driver of defore-station and forest grouping requirements into high, medium, and low degradation, and this applies particularly to ASM, which risk/priority, and (b) establishing pass/progress/fail is too often carried out in an uncontrolled manner and 6 “the ASM entity shall …” or “the ASM entity must not ….” 12 FOREST-SMART MINING - ASM in the informal economy. Positive examples of forest recognized areas, then the complex responsibility for stewardship by ASM exist (ELL and WWF 2012; World undertaking highly technical and sophisticated data Bank 2019a); notwithstanding, such positive cases gathering, analyses, and assessments will not fall to ASM are the exception rather than the norm. The FS-ASM entities. This avoidance can be best achieved by abiding Standard’s requirements for miners (that is, the standard’s to guidelines that promote impact avoidance safeguards PCI), if adopted into ASM standards, have the potential to within the planning, land access, and permitting roles of improve the performance of ASM. government, with support from civil society and other relevant stakeholders. However, poverty-related ASM cannot reasonably be expected to meet industry standards for large-scale The FS-ASM Standard is conceptualized as a voluntary mining companies in two main areas along the mitigation sustainability standard (like other ASM standards). Such hierarchy. The first regards the need for a fully informed standards do not have the purpose or the power to approach to biodiversity impact assessment and establish a full set of requirements/criteria and indicators avoidance, and the second is in the offsetting of residual to stakeholders such as governments, civil society, negative impacts in order to realize a net neutral—or development organizations, and so on. The guidelines indeed—a net positive impact on biodiversity. If ASM for institutional stakeholders should therefore be cannot be expected to meet these requirements, then “guiding principles,” recommending actions to establish significant impact avoidance needs to be realized an enabling context for the ASM to comply with the FS- through a guiding and enabling environment developed ASM Standard’s PCI. by government and facilitated by other stakeholders. Mining practices that fail to account for the values of Suggestions and recommendations for possible incen- forests as complex ecosystems, where biodiversity tives for forest-smart ASM need to be a core element of underpins important ecosystem services such as diverse these guidelines. The FS-ASM Standard can be expected forest products, regulated water supplies, and stored to go beyond compliance with existing environmental carbon, are unlikely to be authentically considered forest regulations (similar to how Fairmined and Fairtrade smart. go beyond legal ASM). Existing legal enforcement mechanisms are therefore not sufficient as drivers to The project therefore envisages the need to outline promote the uptake of forest-smart ASM. a second and complementary approach through the provision of guidelines for governments, civil society, the private sector, and development organizations 2.3. Consultation Process to help establish an enabling environment for forest- The FS-ASM Standard has been consulted with smart ASM. In steering ASM away from forests most international stakeholders—the Global Advisory Panel highly prioritized for biodiversity, ecosystem services, (see Figure 2.2: Consultation Points with the Global and carbon sequestration, such as protected areas, Advisory Panel) and certain issue experts—and national Key Biodiversity Areas (KBAs), and other internationally stakeholders in each pilot country. Figure 2.2: Consultation Points with the Global Advisory Panel Meeting 1 Meeting 2 Meeting 3 Consultation 4 Consultation 5 • Intro to the • Introduction of • Intro to the • Submission of • Submission of project the conceptual content / first the field-ready the revised FS- approach, draft of the FS- FS-ASM Standard ASM Standard • Intro to the panel principles, and ASM Standard to review and after field studies criteria and Guidelines sign off to review and • Strategy sign off discussion and • Feedback and • Feedback and next steps next steps next steps March 8, 2021 April 19, 2021 May 5, 2021 May 27, 2021 November 5, 2021 FOREST-SMART MINING - ASM 13 In addition to the engagement stated above, an initial project and use it in their programming, either individual meeting with each GAP member was done nationally or internationally. May sit on the GAP. to seed their interest in the project and hear their early thoughts. Moreover, an optional workshop on REDD+ 3) FS ASM amplifiers. Stakeholders who are and financial carbon mechanisms was also offered to willing to learn and promote the project GAP members to enhance their understanding of the through social media (ultimately, this category carbon sections of the FS-ASM Standard. became defunct because of the low-profile approach the project eventually followed). Stakeholders were offered four different levels of engagement in the conceptualization, design, drafting, 4) FS ASM learners. Stakeholders who have and finalization of the standard, to fit their availability and an interest in the program but are unlikely to level of interest vis-à-vis other present strategic priorities: engage with it beyond learning. 1) FS ASM GAP members. Actively involved in A fifth category emerged organically: stakeholders who shaping the standard by discussing, reviewing, wished to participate on the GAP as observers because of and providing feedback. Sit on the advisory high interest but who had either low capacity or political panel. barriers to formal participation. Table 2.1: Global Advisory Panel Members and Observers includes a summary of 2) FS ASM implementers. Stakeholders who GAP members and observers. want to act on what they learn from this Table 2.1: Global Advisory Panel Members and Observers Stakeholder Person invited to sit Engage- Invite type on the panel ment type Director Lihui Sun CCCMC Guidelines for Responsible Rachel Zhong Members Outbound Mining Investment June Xiang Fairtrade Gold and Associated Precious Anna Barker Member Metals Code for Responsible Extraction (CORE) – Beatrix Richards Standard setters Members from Solidaridad and Unilever Jan-Kees Vis GemFair – from De Beers Ruby Stocklin-Weinberg Member International Tin Supply Chain Initiative Roper Cleland Observer (iTSCi) – from ITA Alan Martin Responsible Gold Guidance – from LBMA Members Neil Harby Giulia Carbone Conservation NGOs/ KBA Partnership Members Andy Plumptre multilaterals WWF Global Extractions lead Tobias Kind Member Indigenous Peoples Amerindian Peoples Association Laura George Observer African Women in Mining Association Miners Georgette Barnes Member (AWIMA) Katrine Danielsen, KIT Gender Women’s Rights in Mining Observer Royal Tropical Institute ASM technical planetGOLD and planetGOLD II Susan Keane, NRDC Member partners (i.e., leading ASM or responsible sourcing Stephanie Venutti OECD Responsible Minerals Unit Observers projects) Louis Marechal Note: ASM = artisanal and small-scale mining; CCCMC = China Chamber of Commerce of Metals, Minerals & Chemicals Importers & Exporters; ITA = International Tin Association; NGO = nongovernmental organization; NRDC = National Resources Defense Council. 14 FOREST-SMART MINING - ASM 2.4. Forest-Smart ASM Standard (FS-ASM Standard) The FS-ASM Standard, containing the PCI for ASM entities and guidelines for ASM stakeholders, is presented in annex 1 of this report, a stand-alone document. It is structured in three sections: Section A: Introduction and General Principles A.1 Introduction A.1.1 Background A.1.2 Type of Standard A.1.2.1 A Progressive, Risk-Based Approach A.1.2.2 A Collective Approach A.1.3 Structure of the Standard A.2 Three Principles for Forest-Smart ASM A.3 Application in Protected Areas, Key Biodiversity Areas, and High Conservation Value Areas A.4 Linkage to REDD+ and Carbon Standards A.5 Scope A.5.1 Organizational Scope A.5.2 Geographic Scope A.5.3 Legal Scope A.6 Application A.7 References Section B: PCI for ASM Entities B.1 Introduction B.2 Scope B.3 General Principles and Subsidiarity B.4 Implementing the Requirements (Background and Significance of the Methodological Approach) B.5 Requirements (Criteria and Indicators) B.5.1 Situation Assessment and Planning B.5.1.1 Stakeholder Identification and Engagement B.5.2 Direct Impacts – Mining B.5.2.1 Planning and Preparation of Mining Activities B.5.2.2 Forest and Vegetation Clearance Prior to Mining B.5.2.3 Technical Rehabilitation B.5.2.4 Topsoil Management B.5.2.5 Biological Rehabilitation B.5.2.6 Site Closure and Handover B.5.3 Direct Impacts – Nonmining B.5.4 Indirect Impacts B.5.5 Carbon Finance Requirements (Criteria) B.5.5.1 Stakeholder Engagement B.5.5.2 Setting Out the Baseline Case, Additionality, and the Forest Carbon Reference Level B.5.5.3 Accounting For and Monitoring the Project Case—Minimizing Deforestation and Degradation and Forest Restoration—and Certifying the Project B.5.5.4 Capacity Building, Handover, and Site Closure FOREST-SMART MINING - ASM 15 Section C: Guidelines to Support the Achievement of Forest-Smart ASM C.1 Introduction C.2 Scope C.2.1 Who Should Use the Guidelines C.2.2 Where to Use the Guidelines C.2.3 How to Use the Guidelines C.2.4 Circumstances in Which the PCI and Guidelines Should Not Be Used C.3 Conditions for an Enabling Context C.3.1 Government Prioritizes Forest Protection and Recognizes the Legitimacy of ASM as a Source of Livelihood C.3.2 There Is Good Governance and an Enabling Policy Environment C.3.2.1 Policies for Land Use Allocation and Ownership Are Clear and Fair C.3.2.2 Laws and Regulations Provide the Right Incentives for Forest-Smart Mining C.3.2.3 Laws and Regulations That Take Special Consideration to Safeguard Comparatively Weaker Individuals and Communities and Those with Special Rights C.3.3 There Is Peace, Justice, and Strong Institutions C.3.3.1 Law Enforcement C.3.3.2 Transparency and Accountability C.3.3.3 Anti-corruption C.3.4 Miners Are Organized, Settled, and Engaged in a Process of Formalization C.4 Process-Related Guidelines to Set the Miners Up for Success C.4.1 Cooperation, Partnership, and Multistakeholder Approaches (SDG 17) C.4.1.1 Capacity Gaps and Actions to Be Considered by Diverse Stakeholders in Developing an Enabling Environment for the PCI C.4.1.2 Partnership Approaches and the Role of Civil Society Organizations C.4.1.3 Interrelationships between LSM and ASM C.4.1.4 Interrelationships between ASM and Downstream Businesses C.4.2 A Human Rights–Based Approach Is Taken C.4.2.1 Free, Prior, and Informed Consent C.4.3 A Risk-Based Approach Is Taken to Environmental Management Planning C.4.4 A Landscape-Level Approach Is Taken C.4.4.1 Develop and Use Global, National, and Local information on Forests and Geology to Inform Landscape-Level Planning C.4.4.2 Develop Equitable Access to Formal Mining Rights for Environmentally Responsible ASM within Context of Other Competing Land Uses That Impact Forests C.4.4.3 Develop Public Finance Mechanisms That Support FS-ASM Adoption and Planning at the Local Level through Stakeholder-Inclusive Local Environmental Management Plans C.4.5 The Route to Forest-Smart ASM Is Evidence-Based C.4.5.1 The Forest’s Values Are Profiled C.4.5.2 ASM Miners, Entities, and Communities Are Profiled C.4.5.3 Nature of Mining Impacts on People and Forest Ecosystems Is Understood and Used to Prioritize Actions in the Approach to Forest-Smart ASM C.4.6 The Process Is Pragmatic and Realistic to the Miners’ Situations C.4.6.1 Miners and Their Communities Are Incentivized to Pursue FSM C.4.6.2 Implementation of the PCI Is Affordable but Balanced with the Needs to Address Social Acceptability and Ecological Viability, as Defined by the FRM 16 FOREST-SMART MINING - ASM C.4.6.3 Pursuit of Compliance with the FSM PCI Is Well Planned, Implementation Is Monitored, and Success Is Rewarded C.4.6.4 Roles and Responsibilities of Stakeholders Are Clearly Defined and Understood by All C.4.7 Capacity of Miners and Other Stakeholders Is Built to Support the Design and Implementation of a Route to Forest-Smart ASM C.4.7.1 Capacity Limitations of the Miners and of Other Stakeholders Are Well Understood and Accommodated in the Plan C.4.7.2 There Is Appropriate Training Across Stakeholder Categories C.4.7.3 There Is Appropriate Sensitization of Stakeholders as Part of a Broader Communications Plan to Support Implementation of the Road Map C.5 Financing Support Programs for Forest-Smart Mining C.5.1 Development Finance C.5.2 Corporate Social Responsibility and Impact Finance C.5.2.1 Supply Chains – Downstream Finance C.5.2.2 Sustainable Finance C.5.3 Carbon Finance C.5.3.1 Carbon Finance Principles C.5.3.2 Carbon Offsetting versus Insetting C.5.4 Public-Private Partnerships Appendix A: Glossary Appendix B: Capacity Gaps, Risks, and Actions for Stakeholders to Consider in Developing an Enabling Environment for the PCI Appendix C: The Three Principles for Forest-Smart ASM: Rationale FOREST-SMART MINING - ASM 17 3. FEASIBILITY OF ADOPTION OF THE BOLT-ON FS-ASM STANDARD IN GLOBAL PROCESSES The assignment’s terms of reference indicate that “the 3.1. Strategies for Standard Setters objective of the assignment is to assess and develop Forest Carbon guidance and tools for the ASM sector This chapter analyzes the readiness of ASM-related by including Forest-Smart Mining Principles, Criteria & standards owned and/or maintained by Global Advisory Indicators (FSM PCI) into existing ASM standards and Panel (GAP) members to integrate the requirements certification systems, and to support their implementation of the Forest-Smart Artisanal and Small-Scale Mining by identifying REDD+ and environmental/Climate funding (FS ASM) Standard. Strategies have been developed opportunities and develop roadmaps for pilot sites” (World based on assessments of the standard setters’ websites Bank 2020). and normative documents and informed by interviews with Ruby Stocklin-Weinberg (GemFair), Anna Barker Objective 2 is “to design a process to include FSM (Fairtrade), Alan Martin and Neil Harby (LBMA), Susan guidelines and PCI in existing ASM standards and Keane (planetGOLD), and Marcin Piersiak (Fairmined certification systems, as well as targeted government and CRAFT) on various dates throughout the process; policies and legislation.” This is reflected by the tasks responses to the FS-ASM Standard’s research team’s to questionnaires in January and September; and reviews of the draft strategies in November. • “Identify existing standards and certification systems for responsible ASM and carry out a detailed analysis of their A summary table indicating key next steps and the contents, especially environmental requirements and appetite of standards or initiatives to integrate or pilot issues related to deforestation, forest degradation, and FSM can be found in appendix B. ecosystems rehabilitation; • “Develop a strategy for integration of FSM concept 3.1.1 GemFair in existing ASM standards and certification systems, including a). Where is the standard now? »» Concrete technical proposals for the integration of previously defined FSM PCI in each of the GemFair is a program of De Beers Group, currently in pre-identified ASM standards and certification operation in Sierra Leone (Kono District), that aims systems; and to create a sustainable route to market for ethically »» Practical proposals related to methodology, sourced ASM diamonds. In 2019, the program released agenda and processes to include FSM PCI in its first standard for ASM (GemFair 2019a) and an existing standards and certification systems; accompanying manual (GemFair 2019b). The standard is based on the Organisation for Economic Co-operation • “Conduct a review of ASM regulation in pilot studies’ and Development Due Diligence Guideline (OECD DDG) targeted countries focused on environmental and forest (2016), De Beers’s Best Practice Principles Assurance compliance; and Programme, and the CRAFT Code (ARM 2018). It is tailored to the requirements of national law in Sierra • “Develop proposition for ASM regulatory reforms Leone, but it can be applied to other geographies by in pilot studies’ targeted countries to facilitate the adapting some sections (Legitimacy Requirements and implementation of FSM guidelines” (World Bank 2020). Aspirational Criteria). 18 FOREST-SMART MINING - ASM The standard is split into four sections: the community—who hired local farmers and miners to backfill the land and prepare it for cultivation. Then • A: Legitimacy Requirements GemFair worked with members of the neighboring • B: Core Requirements villages—80 percent of whom are women—to cultivate • C: General Requirements the land. • D: Aspirational Criteria Although in early stages, the sites have already seen Environmental requirements feature in sections C and four harvests of vegetable crops and rice. By running D. The standard does not currently mention forests, but this program, GemFair is tackling one of the most critical many of the environmental requirements would help environmental impacts of artisanal diamond mining— minimize forest degradation. Carbon stocks are beyond the lack of reclamation once the mining activities have the current scope of the standard. ceased—while also supporting income generation and food security in the region. Here are some results of the GemFair currently works with over 216 artisanal diamond project thus far: mine sites in the Kono District. Depending on the season, • 130 direct beneficiaries between 10 and 25 people work at each site. There are • 910 indirect beneficiaries approximately 3,240 direct beneficiaries of the program (the mine site workers) and 19,440 indirect beneficiaries • 42 pits backfilled (their families). Some impacts of GemFair to highlight • 3 acres reclaimed include the following: • 420 kilograms of crop seedlings donated • 4 harvests completed ASM Assurance Programme • 25 plant types harvested • To date, GemFair has trained 1,461 individuals GemFair has rolled out further training for the farmers (cumulatively since 2018) on fair labor standards on how to cultivate the land more sustainably and also and safer and environmentally responsible working increase their yield. It is also exploring fish farming in practices and equipped more than 200 miners with former mining areas. the skills they need to respond to accidents and emergencies at the site. b). Where is the standard going • GemFair will continue to provide training to artisanal next? miners on ASM standards and mine site first aid in 2022. GemFair is interested in exploring the FS-ASM Standard’s criteria and indicators and plans to keep abreast of • In addition to classroom training, GemFair field developments to the standard to see where the GemFair staff are dispatched to participating mine sites on a ASM Standard could benefit from a bolt-on in this topic regular basis to assess the miners’ compliance with area. the GemFair ASM Standard. Where they identify gaps, GemFair staff provide on the spot mentoring to the c). How to get there? miners. If the noncompliances cannot be tackled during the site visit, GemFair develops a corrective The authors advise GemFair to keep up to date with action plan for the miner, which may include specific the developments of the FS-ASM Standard, to raise time-bound deliverables or remedial training or other awareness with GemFair’s internal management team capacity development support—such as introducing and miners. GemFair has been engaged as a member of personal protective equipment to a mine site—to the the GAP in the review of the FS-ASM Standard and has miner and his or her workers. proactively been engaged in all the consultation periods. GemFair is carrying out a review of the FS-ASM Standard Reclamation and Cultivation Program requirements to determine which PCI are relevant for inclusion in GemFair’s miner training curriculum as part In late 2020, GemFair decided to implement a program of their road map currently under development. GemFair that would support artisanal miners to reclaim their is advised to share their road map with the World Bank mining areas and leave the land in a state for future once it is finalized. productive use, like cultivation. Working closely with the local community and authorities, GemFair Moreover, GemFair is recommended to engage with the selected several legacy mining areas to be backfilled. World Bank in Sierra Leone. If the World Bank is involved GemFair worked with a team leader—a miner from in regulatory reform in Sierra Leone, it is worth speaking FOREST-SMART MINING - ASM 19 with the consultants who are carrying out that work equivalent to “principles” to address the barriers to reclamation that presently disincentivize miners and communities from restoring a). Higher-level requirement topics (for example, 3.2 mined-out land. Environmental Protection) b). Second level of subrequirement topics (for The World Bank could also carry out a regulatory example, Management of Toxic Substances) assessment of Sierra Leone’s readiness for FS ASM, following the methodology used for this project. c). Third level of criteria (for example, 3.2.1 Gold Recovery without Mercury) 3. Guidance 3.1.2 Fairtrade a). Brief guidance at the level of criteria to support a). Where is the standard now? interpretation of the requirements, best practices, suggestions, and examples of how to comply Fairtrade International has been issuing standards for with the requirement ASM since 2009, when its small Producer Organizations Standard was merged with the Alliance for Responsible b). Guidance absent for the majority of requirements Mining’s Standard Zero for gold from ASM to create the joint Fairtrade and Fairmined Standard. After this The standard incorporates the mitigation hierarchy three-year partnership ended in 2012, version 1.1 through its intent to “progressively minimize” the of the Fairtrade Standard for Gold and Associated negative environmental impacts of ASM, structuring the Precious Metals (Silver and Platinum) for ASM was requirements by those most realistically achievable in released, with the objective of “empowering producers the short to medium term. and local communities through trade and delivering economic, social and environmental transformation and The Fairtrade standards work with farms and mines restoration.” An updated version 1.2 of the standard was that are on a journey toward sustainability and are released in 2015, following earlier updates of the version designed to ensure continuous improvement. Fairtrade in 2013 and 2014 (Fairtrade 2015b). The updates relevant has core requirements that must be met from day 1 of to our project include measures on mercury usage and certification and development requirements that the Indigenous Peoples’ rights. The standard is currently mine must gradually meet in a stepwise fashion over under revision again, and the new update is expected to six years; the longer a mine is certified as Fairtrade, the be published in the first quarter of 2022. higher the standards they have to meet. This pragmatic approach recognizes that improvements require The standard applies to gold supply chain actors, investments, so certified mines can benefit from the including import and export depending on the role the additional funds generated through higher prices (due business plays1. There are currently 15 Fairtrade-certified to price guarantees) and higher income (due to Fairtrade ASM sites in Peru, with more than 1,500 artisanal and sales with the Premium), which thus provide the capital small-scale miners, and additional mines in East Africa needed to make these necessary improvements. are working to achieve the standard2. Certification is achieved following a successful third-party audit by Fairtrade advocates for “environmental stewardship,” FLOCERT. understood as “Responsible ASM that actively encourages better preventive and restorative environmental The Fairtrade standard covers all stages of the mining practices and the application of responsible methods life cycle and contains four chapters: General, Trade, of production. Responsible miners abide by the Production, and Business and Development. Each environmental laws in their countries, contribute to chapter includes the following: environmental protection, human health and ecological restoration in its operations and communities, and 1. The intent mitigate negative impacts. Respecting protected areas, a). Objectives and scope of application of the avoiding damaging important biodiversity, minimizing chapter the ecological footprint of mining, and where possible, 2. The requirements, which can be regarded as restoring or replacing biodiversity, and where this is 1 Anna Barker, Senior Supply Chain and Program Manager, personal communication to Estelle Levin-Nally, November 6, 2020. 2 Anna Barker, Senior Supply Chain and Program Manager, personal communication to Blanca Racionero-Gomez, January 29, 2021. 20 FOREST-SMART MINING - ASM not possible, compensating for that residual loss, are Workers (CLAC), whose role is to bring the standards principles for environmental protection” (Fairtrade 2015b, to life and run training with the ASM sites. There is annex 2).3 opportunity for the local team to be trained in FS ASM if funding is available⁵. The existing principles and requirements cover three of four forest values—ecosystem services, biodiversity, In sum, the Fairtrade Gold Standard has extensive and respect for the human rights of forest peoples. Most environmental requirements, with some of them specific stages of the mining life cycle are considered, but the to forest protection, but these are mostly development core criteria prioritize the production stage. requirements. There is guidance on the standard and new guidance will be included in the new revised The requirements of the Fairtrade Gold Standard standard. (Fairtrade 2015b) focus on the direct environmental impacts of mining, with limited recognition of the There is also little consideration of the indirect impacts of indirect impacts. Carbon stocks are not referenced, but mining on the environment, let alone forests. Fairtrade does have a climate standard assessed by FLOCERT and a new scheme for farmers, workers, and b). Where is the standard going miners to receive carbon credits. The Fairtrade Climate next? Standard (Fairtrade 2015a) was produced in collaboration There is high interest from Fairtrade to incorporate the and will be implemented with the Fairtrade Gold FS-ASM Standard’s PCI into their standard, as Fairtrade is Standard⁴, an internationally recognized standard setter committed to a social justice agenda, of which climate for climate and development interventions. The Fairtrade justice is a core part. Moreover, deforestation and the Climate Standard aims to enable smallholders to gain environment are top of the agenda for consumers and access to the carbon market by producing Fairtrade companies, and Fairtrade wishes to understand how Carbon Credits, facilitating training to smallholders, and they can work further in this space. generating climate finance. While the Fairtrade Carbon Credits already on the market are not yet generated Fairtrade is open to exploring the possibility of piloting by gold mines, there is scope and the possibility of FSM in some of their sites, but it sees funding as a big establishing carbon credits from Fairtrade ASM sites if constraint. It is unlikely and very challenging for Fairtrade funding was identified. Gold is unique in comparison to to implement a pilot if the market is not able to absorb the other Fairtrade projects, which focus on agriculture the extra cost and invest in the journey to compliance. (that is, growth of shade trees or use of crop waste to generate biofuel gas cookers). We would need to scope and identify how Fairtrade Carbon Credits could work c). How to get there? effectively in Fairtrade’s gold mines. Growing the climate The authors advise Fairtrade to follow these recom- offer for Fairtrade supply chain actors is a critical part of mended steps to achieve its desired vision with regards Fairtrade’s strategy going forward. to forest-smart ASM. Fairtrade International also uses their supply chain Pilot the FS-ASM Standard in a Fairtrade site or requirements for selling Fairtrade gold to support sites. environmentally friendly practices by supply chain participants, through the supply chain requirements for 1. Internal workshop. Plan an internal workshop selling Fairtrade gold: The Premium is used to support with the gold team to determine a more concrete whatever projects the miners choose to pursue, such as pathway and timelines to pilot FS-ASM in a the introduction of cleaner technologies, the optimization Fairtrade site. of water usage, and to minimize the environmental footprint of Fairtrade artisanal and small-scale mining 2. Get everyone on board. Raise awareness of organizations; the license fee (Fairtrade mark) is used the FS-ASM Standard with Fairtrade leadership to fund capacity building of the organizations so they (including the CEO, CTO, legal counsel, the can meet the standard’s environmental requirements. Board, and head of responsible sourcing), market Capacity building is done by the Latin American and stakeholders (gold importers, refiners, jewelry Caribbean Network of Fair Trade Small Producers and manufacturers, designers, brands, and so on), 3 Which is based on ARM (2008). 4 See the Gold Standard website, http://www.goldstandard.org. 5 Anna Barker, Senior Supply Chain and Program Manager, personal communication to Blanca Racionero-Gomez, January 29, 2021. FOREST-SMART MINING - ASM 21 country-level stakeholders (including miners), and The biggest barrier to progressing this agenda is funding other relevant stakeholders, to buy them into the and certainty of sales for Fairtrade producers. Besides process. peer reviewing and guiding the above process (in alignment with the implementation and coordination of 3. Assess internal resources. Assess internal capacity the other pilots planned as part of this project), Fairtrade and funding available to implement a pilot of the would benefit from a markets study to explore market FS-ASM Standard. Fairtrade is concerned with interest in FS-ASM–compliant material, and a benefits their capacity and resources to implement new study to ascertain the added value that FS-ASM can programs. bring participating miners and mining communities. 4. Plan. Draft a plan to pilot the FS-ASM Standard or some of its requirements. A pre-feasibility 3.1.3 Fairmined assessment and funding assessment for the piloting of FS-ASM has been done in Peru; given a). Where is the standard now? that Peru is the country with most Fairtrade- certified sites, it is logical to trial a pilot there. The Fairmined Standard for Gold from Artisanal and 5. Funding. Seek funding to fill the capacity gaps Small-scale Mining, Including Associated Precious encountered in step 1 to be able to implement Metals, version 2.0 (ARM 2014) was created by the step 2. Alliance for Responsible Mining (ARM), with the support of international supply chain actors and experts 6. Road map. With the funding received, agree on a participating in the Standard Committee and following timeline and pathway for piloting. two rounds of public consultations. The Fairmined Standard was developed to support the sustainable 7. Implement and report. Coordinate impleme- development of ASM communities consistent with ntation of the road map with the World Bank or ARM’s vision of a “legitimate, responsible and profitable any other party tasked with coordinating the ASM sector which promotes inclusive and sustainable other pilots and gathering lessons learned with development.”6 The standard has been under revision the purpose of finalizing, demonstrating, and since 2019 with the objective of making it more inclusive supporting uptake of the FS-ASM Standard. of different ASM stakeholder groups while maintaining its status as best-practice “gold to be proud of.” More Integrate the FS-ASM Standard and Guidelines details of the revision process are available on the requirements into the Fairtrade Gold Standard. Fairmined website⁷. 1. Internal workshop. Once a pilot has been implemented, plan an internal workshop with the The most important milestones reached in the last six gold team to determine a more concrete pathway years include the following: and timelines to the below steps. • Twenty-five mining organizations in four countries 2. Gap assess Fairtrade against the FS-ASM Standard obtained Fairmined Certification for at least one year, to decide the process and progressivity for uptake with more than 4,133 direct beneficiaries. of the standard’s PCI and guidelines, and also to • More than $6 million in Fairmined Premium have further develop and improve the guidance that been paid to certified mining organizations by the supports the implementation of the Fairtrade market. standard. • Five certified mining organizations are currently 3. Feasibility assessment. Assess results from the pilot certified in two countries and nine more ASM study, and in parallel to the gap assessment, assess organizations are looking forward to certification in (a) the feasibility of non-piloted ASM organizations three countries. to implement the standard’s PCI with or without support from Fairtrade and (b) how much support • More than 377 businesses from 33 countries are they would need at what cost. working with Fairmined gold. 4. Road map. Decide the timeline and pathway to integrate requirements, taking into account the results from the pilot study and steps above. The 6 “About the Alliance for Responsible Mining,” Alliance for Responsible Mining, accessed December 2021, next revision cycle of Fairtrade should happen https://www.responsiblemines.org/en/history-2/. in 2025. It is not possible to amend the standard 7 See “Fairmined Standard Revision,” Fairmined, between the cycles of consultation. https://fairmined.org/fairmined-revision. 22 FOREST-SMART MINING - ASM • More than 1.6 tons of Fairmined gold have been sold. leaders. This model will also provide even more flexible solutions for the market to engage with the sector. The standard includes requirements to achieve the highest responsible ASM practices: formal and legal b). Where is the standard going mining operations, environmental protection, fair labor, next? social and trading conditions, traceability of Fairmined The following actions are planned for 2022 within the minerals from the extraction point to the point of sale, timeline of the Fairmined Standard revision: and socioeconomic development through the Fairmined Premium. It also includes flexible market models to fit • Validation and discussion of the Fairmined Standard different business strategies of clients and requirements 3.0 proposal with the Fairmined Standard Committee. for Fairmined suppliers and licensees. ARM will propose exploring the inclusion of the FS- ASM criteria in the future version of the standard, In terms of relevance to the FS-ASM Standard, Fair- including the recommendations derived from the mined already covers 16 environmental and ecosystems feasibility exercise for forest-smart mining in the field- protection requirements: compliance with environmental testing for this project. Considering the envisaged regulations; management of toxic substances such progressive nature of the Fairmined system and the as mercury and cyanide, in line with the Minamata integration of the CRAFT Code, it will be important Convention; and water management and protection to ensure that the integration of FS-ASM criteria (water bodies must be protected from the discharge of is also aligned with the step-by-step high-to-low tailings, residues, and acid mine drainage). In addition, risk mitigation approach that takes into account mined areas must be restored and rehabilitated and the priorities and capacities of diverse ASM groups any technological change must have from the outset (March–June 2022). an environmental mitigation plan (that is, concept of • Planning and launch of the international Fairmined prevention in the mitigation hierarchy), and there are Standard 3.0 public consultation to collect comments additional requirements for “ecological gold” regarding and recommendations from current and potential nonuse of toxic substances and stricter restoration and rehabilitation commitments. For example, Fairmined- users of Fairmined Certification, Fairmined supply certified organizations in Colombia and Peru manage chain, and other stakeholders (July–September 2022). waste and hazardous substances, recycle water, and • Piloting the new version of the standard with small- carry out revegetation and restoration pilots. ARM’s scale mining organizations and the proposal of website provides more details on the environment and transition for already certified organizations (October– responsible mining8. December 2022). Building on the lessons from the application of the • Approval of changes by the Fairmined Standard open source CRAFT Code over the last three years, the Committee after the consultation (October– Fairmined Standard revision has taken a fresh direction, December 2022). and between 2020 and 2021 ARM developed “the • Publication of Fairmined Standard 3.0 and a transition Sustainable Mines Program,” which aims to streamline period for mining organizations already certified with the progressive improvement approach promoted the standard (December 2022). by ARM, offering a continuous road from mitigation of the most severe risks using the CRAFT Code all the Considering the severity of the global climate change way to best-practice sustainable development through and biodiversity crises, ARM recognizes the necessity mining offered with Fairmined. The next iteration of the of strengthening the environmental protection section Fairmined Standard system will go beyond just certifying of the Fairmined Standard, especially for ASM located best practice, proposing a framework for sourcing from in Key Biodiversity Areas, including forest landscapes. ASM with a wide scope of performance levels. This new The FS-ASM criteria are uniquely positioned to fill this proposal will integrate stepwise compliance, assurance, gap. Environmental due diligence and compliance will and incentives while maintaining the Fairmined best- increasingly become one of the key criteria of legitimacy practice ASM brand for high achievers (both miners for ASM operations present in areas with critical natural and market) to differentiate themselves as sustainability habitat. While many miners develop their operations in forest locations where ASM is a traditional activity and an important part of their livelihoods, they are also 8 See “Environment and Responsible Mining,” Alliance for increasingly aware that reaching very high environmental Responsible Mining, https://www.responsiblemines.org/en/ standards is the only way for their activity to be viable environment-and-responsible-mining. in the long term, because of increasing pressure from FOREST-SMART MINING - ASM 23 their buyers, their governments, and other local and of the “bolt-on” standard, it is necessary to consider the international stakeholders. At the same time, there is enabling conditions of the guidelines part of the FS-ASM little guidance available to facilitate environmental Standard (section C). management in forest areas that is tailored to the specific impacts and capacities of the ASM sector. FS • Policy advocacy at international and national levels ASM is an important step to providing such high-level to get ASM on the climate change, biodiversity, principles, and ARM is committed in supporting miners environmental sustainability, human rights, and to implement these principles. Indigenous rights agendas. It will help to include FS ASM practices in formalization programs led by governments. c). How to get there? • The ASM sector needs to be incorporated into REDD+ programs as a community actor and economic sector. The current Fairmined Standard revision is a perfect Some countries will need to make additional efforts opportunity to test the bolt-on approach of the FS-ASM because there are considerable differences between Standard, especially considering the high expectations countries’ implementation of REDD+ strategies. of performance related with Fairmined being a best- practice standard for ASM. • The industry needs to be willing to support with economic incentives/other kinds of support or buy At the level of mining organizations, the full FS-ASM minerals from artisanal and small-scale miners who Standard adoption requires internal capacities, resources, implement more advanced environmental due and a more advanced level of formalization. For ASM diligence practices such as the ones in the FS-ASM miners at the level of CRAFT (see chapter ), it is important Standard. Miners need market incentives because to have the possibility to implement priority actions they may perceive extra efforts to adopt additional recommended by FS-ASM in a progressive approach that FSM environmental requirements, especially the is aligned with the approach of CRAFT Module 5, which new elements related to carbon management that already includes basic environmental management. regulations are not requesting. Therefore, in the progressive sustainable mines approach • Support and funding from private, public, that ARM is taking (CRAFT toward Fairmined), the FS-ASM or cooperation sectors are needed for the Standard’s PCI would also be integrated progressively, implementation of the improvement plans to close prioritizing some criteria for ASM with lower capacity and the gaps to fulfill FS-ASM requirements in the pilot sustainability performance, while its fuller scope would sites. Results of piloting the FS-ASM Standard will be be applied in mines closer to achieving the sustainability valuable for encouraging and drawing lessons learned leaders status, that is, compliance with the Fairmined for inclusion of the standard’s PCI into voluntary Standard with a strengthened environmental aspect. sustainability standards for the ASM sector. At the same time, ARM is interested in incorporating the FSM PCI in its current work with miners in environmentally 3.1.4 CRAFT rich and fragile areas. While mercury continues to be an important challenge that is already the focus of countless a). Where is the standard now? projects and interventions, the FSM framework offers an opportunity to go beyond mercury and apply a practical The CRAFT Code 2.0 (ARM 2020a) was launched one year environmental management approach in important ago after a second round of public consultation (ARM forest areas such as the Amazon region, the Congo basin, 2020b) following the ISEAL Code for the development the biogeographical Chocó region along the northwest of standards. The CRAFT Code version 1.0 (2018) and Pacific coast of South America, and the forests of Central version 2.0 (2020) were developed under a Creative America. Following the first promising experiences field- Commons license by ARM and RESOLVE, with funding testing the draft standard, ARM is keen to include the support from the European Partnership for Responsible concept of forest-smart mining and FS ASM pilots in Minerals (EPRM) and the contribution of two governance future funding applications and will attempt to include bodies: a strategy-level advisory group and a technical some actions recommended in the FS-ASM criteria standard committee, composed of key stakeholders in assessment carried out in Chocó in other interventions the ASM sector and the industry. in this territory. The CRAFT Code is a voluntary progressive performance In considering the inclusion of the FS-ASM criteria in the standard and a market entry-level standard. It offers a Fairmined Standard, for the successful implementation practical framework to identify and manage the highest 24 FOREST-SMART MINING - ASM risks related to ASM, integrating the five-step framework standard. of the OECD DDG and the list of risks described in its • New criteria were written for the other 3T and cobalt second annex. It also proposes a consensus regarding products. “high” risks, to promote progress on a variety of important sustainability issues, once the critical OECD DDG risks Volume 2A of the code has specific environmental have been mitigated. and forest criteria for all ASM operations and all commodities captured in Module 5 (High risks requiring The overall intent of the CRAFT Code is to promote improvement: coordination with protected areas the sustainable social, environmental, and economic authorities; coordination of the use of mining land with development of the ASM sector by leveraging the local inhabitants who require the same resource; water process of due diligence, an obligatory step that buyers protection and biodiversity). Carbon stocks are beyond must take when engaging with upstream producers, the current scope. In terms of priority high (severe) risks including ASM. The code aims to empower the miners relating to specific commodities, mercury is highlighted in understanding and facilitating the due diligence for gold ASM as are radioactive emissions from tantalum process. It gives supply chain actors a tool to make the ore (coltan) concentrates. due diligence efficient and cost-effective while focusing on support to the ASM to reduce the risks and advance Based on feedback from other allies, CRAFT is used by their performance. The fact that the code was developed ARM; the planetGOLD program in all countries where it in participation with the key players in the responsible intervenes; and in various public or private ASM initiatives minerals space, including the OECD as an observer, for gold mines in Colombia, Democratic Republic of generates confidence in its legitimacy and encourages Congo, Honduras, and Mauritania, for gemstone mines the industry to make a step to constructively engage in Kenya, Malawi, Sierra Leone, and Zambia, and for with the ASM. diamond mines in Liberia. These are the main changes in CRAFT 2.0: b). Where is the standard going next? • New structure: Now CRAFT is composed of three volumes to meet the needs of specific public, with a According to the Creative Commons open source license fourth volume on guidance. terms of the CRAFT Code, ARM as the code maintainer • Volume 1: CRAFT – Introduction and general has very limited control over who uses the code, for characteristics which purpose, and under which conditions. However, to ensure consistency in the CRAFT application, version • Volume 2: CRAFT requirements for ASM mineral 2.0 introduces a new chapter (Volume 3) on guiding producers principles for CRAFT schemes, on how schemes are »» 2A: Commodity-independent requirements expected to interact with ASM producers, and what claims may be made related to the usage of CRAFT. At »» 2B: Commodity-specific requirements this level, there could be an opportunity to add FS ASM criteria to the CRAFT Code for specific applications, or in • Volume 2’s five modules reflect the sequence that other words, to “branch” the main code. ASM mineral producers are expected to follow to conform to the requirements. For a future revision of the core CRAFT Code open • Volume 3: CRAFT for users or schemes source standard, the standard-setting organizations ARM and RESOLVE must convene the CRAFT Standard • Volume 4: CRAFT Guidance book Committee and the CRAFT Advisory Group and propose • New CRAFT scope for more minerals: gold, 3T, cobalt, including those FS-ASM Standard requirements that and colored gemstones. could be deemed as representing the most severe high risks in Module 5. Per the ISEAL Code, ARM must • Clarifications were made on some criteria. review its standards at least every five years to ensure • Clarifications were added to the criteria related to continued relevance and effectiveness in meeting its public and private security, child labor, complaints stated objectives. However, given the relatively recent mechanism, and relationship with the community. date of the latest CRAFT Code revision (2020), with it still being in the early days of implementation, and given the • More guidance for communication was added. considerable effort in time, resources, and engagement, • Further guidance was added for CRAFT schemes, it does not appear viable to consider the integration of users, and supply chains that want to use the CRAFT the FS-ASM Standard into the main version of the CRAFT FOREST-SMART MINING - ASM 25 Code in the short term. revision cycles, invite additional new members who can contribute with FS ASM–relevant experience and On the other hand, ARM is actively applying the CRAFT open discussion for the amendment in the standard. Code within its CRAFT scheme called the Sustainable Additionally, incorporate lessons learned from the Mines Program, which aims to facilitate connecting CRAFT branches and implementation. CRAFT implementing ASM entities with formal markets and to bring partners to invest in the CRAFT mines’ 3.1.5 planetGOLD Phase 2 (GOLD+) progressive improvement through Mines Sustainability Plans. Considering that some of the projects are located a). Where is the standard now? in forested areas, ARM is eager to pilot FS-ASM Standard elements in Colombia, Guyana, Honduras, Peru, and The planetGOLD program seeks to significantly reduce Suriname. All the mining sites mentioned are gold ASM. mercury use and otherwise improve the production There is especially strong momentum in good mining practices and work environment of artisanal and practices in forests in the Amazon region, where many small-scale gold mining (ASGM) in order to support projects and initiatives (for example, Conservation X implementation of the Minamata Convention. The Lab challenges, or Amazon Aid’s campaign) are looking program comprises eight projects: seven country-based at innovative solutions for reducing deforestation and projects and one global knowledge management improving environmental protection beyond mercury and communications project that facilitates the reduction or elimination. In Africa, the concept could be dissemination of information from planetGOLD. The especially interesting for countries in the Congo basin; global project is executed by the Natural Resources for example, the Ministry of Environment in Gabon has Defense Council (NRDC) with technical assistance from recently expressed interest to ARM in receiving guidance the United Nations Environment Programme (UNEP) and on the environmental management of mining in tropical the United Nations Industrial Development Organization forest. (UNIDO). The planetGOLD program implementation period is 2019–2024; it has a funding package of $45 c). How to get there? million from the Global Environment Facility (GEF), with an estimated $135 million in cofinancing from partners. The CRAFT Code indicates that “depending on demand, additional Modules on Medium- and Low Risks may be PlanetGOLD is funded by the Chemicals and Waste developed in future versions of the CRAFT.” As the current division of the Global Environment Facility (GEF), is led standard review cycle was just finalized in October 2020, by UNEP, and is implemented in partnership with UNIDO, a new review cycle for a version 3.0 may not commence the United Nations Development Programme (UNDP), in the short term unless strong demand is signaled from and Conservation International. miners or the market. But as CRAFT is open source under Creative Commons License CC-BY-SA 4.0, branching Phase 2 of planetGOLD is funded by GEF, is executed by is allowed. This opens up the possibility of creating an Conservation International with technical assistance from “FSM branch version of CRAFT” that, if taken up by the NRDC, UNIDO, and UNDP, with an implementation implementers, may later be merged into the core version period of 2022–2028, and has a funding package of $342 of CRAFT during future revision. Since the CRAFT Code is million (coming from GEF and estimated cofinancing). an open source document, any institution that saw value to this approach could create the FSM branch version of GOLD+ will expand the scope of planetGOLD by adding CRAFT and publish it under a Creative Commons license. new country projects and will focus on integrated jurisdictional management approaches that will consider The following should be considered regarding the a wider range of environmental impacts, including the future inclusion of FS ASM principles or the high-risk prevention and mitigation of forest impacts as well as requirements in the next version of the CRAFT Code: mercury contamination from small-scale gold mining. • Use lessons learned from pilot applications and study In 2021, planetGOLD formally released its own environ- the incentives for the miners to apply the PCI for mental and social standards, the planetGOLD Criteria for ASM entities, particularly for ARM’s Sustainable Mines Environmentally and Socially Responsible Operations. Program. These specific criteria govern ASGM operations in order to help planetGOLD participants meet responsible sourcing • Evaluate the relevance, interest, and opportunities for requirements, as well as social and environmental funding an “FS ASM branch version of CRAFT.” safeguards required of GEF-funded projects. • In Standard Committees for future CRAFT Code 26 FOREST-SMART MINING - ASM The planetGOLD Criteria incorporates Modules 1–4 from the program now, will be formally added in 2023. The the CRAFT Code, which are aligned with the OECD DDG, program is interested in exploring piloting the FS-ASM and also includes three specific planetGOLD criteria: Standard in some of the planetGOLD countries. The ultimate decision, however, is up to the Project Steering • Criteria Module 1: Adopting a Management System Committee and each individual country project. (from CRAFT) • Criteria Module 2: Legitimacy of the ASM Mineral Deforestation from ASGM is certainly a huge concern of Producer (from CRAFT) international stakeholders. PlanetGOLD feels that there is substantial need to give practical guidance to ASGM • Criteria Module 3: “Annex II Risks” Requiring Imme- operations on how to prevent/mitigate forest impacts diate Disengagement (from CRAFT) of small-scale gold mining while also addressing the main mission of preventing mercury contamination; • Criteria Module 4: “Annex II Risks” Requiring Disenga- addressing broader environmental impacts is a focus of gement after Unsuccessful Mitigation (from CRAFT) phase 2. Incorporating the FS-ASM Standard and piloting • Criteria A: Mercury-Free Processing and Management it in some countries would align the program-wide of Chemicals and Wastes (planetGOLD-specific operational criteria with this strong interest in protecting criteria) forests. • Criteria B: Respect Rights and Lives of Indigenous Peoples (planetGOLD-specific criteria) c). How to get there? • Criteria C: Environment Protection (planetGOLD- specific criteria) The authors advise planetGOLD to follow these recommended steps to achieve planetGOLD’s desired vision with regards to FS ASM. The protection of ecosystem services, forests, and minimization of biodiversity and deforestation appear under Criteria C. Carbon stocks are beyond the current Integrate FS-ASM Standard and Guidelines scope of the standard. requirements into the planetGOLD Criteria. b). Where is the standard going 1. Get everyone on board. Raise awareness of the FS- next? ASM Standard with GEF planetGOLD implementing agencies (Conservation International, UNIDO, UNEP, With regards to the incorporation of FS-ASM principles, and UNDP), the Program Steering Committee, there is high appetite from stakeholders and planetGOLD. the Project Advisory Group (PAG), and country- The leadership (GEF, UNDP, and UNEP) are very interested level stakeholders (including the country project in coupling protection of biodiversity and forested executing teams and ASGM beneficiaries, as well as areas with their mercury efforts. Country-level teams local governments), to buy them into the process. and artisanal and small-scale miners are interested, but This may involve training sessions with these various they are also very focused on immediate priorities for stakeholders, sharing documentation through completing their projects. Many stakeholders (including email, and having an FS ASM expert on hand to potential downstream buyers) are very interested as part respond to queries/questions from planetGOLD of the overall story of responsible gold production. As organizations to support strategic inclusion and such, planetGOLD is interested in potentially updating programmatic implementation. It is particularly the planetGOLD Criteria to include FS-ASM Standard significant to convince the steering committee about requirements. The ultimate decision, however, is up to how important the uptake of the FS-ASM Standard the Project Steering Committee and each individual is for attracting potential gold buyers, since they are country project. concerned about delaying the uptake of existing criteria. Moreover, planetGOLD (phase 1) is presently being executed in Colombia, Ecuador, Guyana, Indonesia, 2. Market analysis. Assess the interest from external Kenya, Mongolia, Peru, and the Philippines. PlanetGOLD stakeholders, particularly gold buyers, in incorporating will expand implementation in 2022 (planetGOLD phase the FS-ASM Standard requirements in their sourcing. 2) in Bolivia, Republic of Congo, Ghana, Honduras, The results of this analysis would help convince the Madagascar, Nigeria, Suriname, and Uganda, and in 2023 steering committee and other relevant stakeholders. in Côte d’Ivoire, Guinea, Mali, Nicaragua, Sierra Leone, and Zambia. Ecuador, which is informally affiliated with FOREST-SMART MINING - ASM 27 3. Gap assess planetGOLD criteria against the FS-ASM Pilot the FS-ASM Standard in planetGOLD Standard to decide the process for uptake of the countries. standard’s PCI and guidelines. 1. Plan with Conservation International as a first step, 4. Feasibility assessment. In parallel to the gap assess- since they are the implementing agency of phase 2, ment, assess (a) the feasibility of implementation which has a focus on broader environmental impacts of the standard’s PCI by planetGOLD beneficiaries such as the prevention and mitigation of forest with or without support from planetGOLD, and impacts. (b) how much support they would need at what cost. The feasibility assessment would help engage 2. Decide which countries to focus on. The current set Conservation International and the midterm review of planetGOLD countries are likely too far into their team to consider the incorporation of FS-ASM in programs of work to easily accommodate piloting future phases of planetGOLD. the FS-ASM Standard’s PCI. It would be more fruitful to explore the phase 2 countries to see where there 5. Engage with Conservation International. Discuss may be an appetite for such pilots, and the funds internally with Conservation International the best for conducting the pilots could be programmed strategy to follow in order to proceed with agreements into the projects from the start. The selection of with GEF and other planetGOLD implementing countries should be assessed based on interest, agencies. capacity, and alignment with the project’s mission. Three planetGOLD phase 2 country projects would be interesting to explore in particular: 6. Engage with the midterm review team of the global project. Discuss with the team to evaluate a. Ghana, since an existing feasibility, workplan, the advisability of updating the planetGOLD Criteria road map, and budget has been designed to include FSM PCI. The midterm review will provide for the implementation of FS-ASM Standard an opportunity to revisit the criteria, their usefulness requirements, which could be used to program to the program and its stakeholders, the country the Ghanaian projects experiences with applying the criteria, and so on. If b. Republic of Congo, since the project concept the review recommends incorporating the FS-ASM already aims to complement the Congo Basin Standard, the planetGOLD global project can work Sustainable Landscapes Impact Program, so the on its incorporation in 2022, but a road map will need FS-ASM Standard requirements would be a natural to be crafted to plan exactly how and when revisions fit. will be made. c. Côte d’Ivoire, since the country has made significant progress in REDD+ and ASM operations in the 7. Road map. Decide the timeline and pathway to Tai NP area of the country are eligible for carbon integrate requirements taking into account the benefits. results from steps 2–5. The planetGOLD Criteria has no specific formal revision cycle. If the midterm 3. Assess internal resources. Assess internal capacity and review, Program Steering Committee, Program funding available to implement a pilot of the FS-ASM Advisory Group, and the country projects think that Standard in selected planetGOLD countries. the adoption of the FS-ASM Standard demands immediate attention, the global project could be 4. Plan. Draft a plan to pilot the FS-ASM Standard or directed to work on its incorporation, really at any some of its requirements. time during the project. 5. Funding. Integrate FS-ASM requirements into the The World Bank could work closely with the planetGOLD funds of selected phase 2 countries that address the global project to peer review and guide this process, in gaps encountered in step 3 and align with the plan alignment with the implementation and coordination drafted in step 4. of the other pilots planned as part of this project. More concretely, if the standard’s requirements are to be 6. Road map. With the funding received, agree on a integrated in the planetGOLD Criteria, planetGOLD timeline and pathway for piloting. would need external support to support the process: (a) concrete guidance on how to execute each criterion, 7. Implement and report. Coordinate implementation with case studies and examples of how to conform; of the road map with the World Bank or any other and (b) training on forest-smart mining (background, party tasked with coordinating the other pilots sustainability case, the standard) and the PCI. 28 FOREST-SMART MINING - ASM and gathering lessons learned with the purpose of The RGG states that environmental impacts are to be finalizing, demonstrating, and supporting uptake of managed through appropriate due diligence policies the FS-ASM Standard. and governance structures designed as part of step 1. Actual or potential adverse environmental impacts in the gold supply chain are to be identified in step 2. And the 3.1.6 LBMA design and implementation of a management strategy to address identified environmental risks is explained in a). Where is the standard now? step 3. LBMA (formerly known as the London Bullion Market There is room to improve the RGG to ensure more robust Association) is an independent precious metals authority environmental risk management by LBMA refiners. and standard setter. LBMA’s “responsible sourcing Besides the fact that the protection of ecosystem programme is mandatory for all Good Delivery refiners services and the minimization of biodiversity impacts wishing to trade with the London Bullion Market.”⁹ It and deforestation do not appear in any specific section includes an independent audit program for gold and of the standard, forests are not mentioned in any step or silver, which is supported by the Responsible Gold anywhere in the RGG. The RGG does not provide enough Guidance (RGG), the Responsible Silver Guidance, and guidance on the type of environmental issues to identify the toolkit for refiners. The current version 8 of the RGG and manage; however, version 9 of the RGG, which (LBMA 2018) is applicable worldwide and refiners are will be applicable from January 1, 2022 (LBMA 2021a), assured annually. The refiner’s toolkit provides useful does recognize the World Gold Council’s Responsible checklists, forms, and questionnaires to assist them in Gold Mining Principles (RGMP), affording greater ESG sourcing gold or silver responsibly. coverage from industrial producers. Carbon stocks are beyond the current scope. The RGG provides guidance to assist gold refiners with responsible sourcing, as well as requirements b). Where is the standard going of responsible sourcing that refiners should commit. next? Version 8 of the RGG introduced environmental, social, and governance (ESG) issues for the first time. In its Version 9 of the RGG was launched in November 2021. present revision cycle to produce version 9, LBMA has Version 10 will begin development in 2023. recognized that ESG issues and sourcing from artisanal and small-scale mines require dedicated attention in LBMA is keen to incorporate the FS-ASM Standard’s PCI 2022;10 this aligns well with the possibility of integrating into the Responsible Sourcing Programme as part of the FS-ASM Standard into a future version of the RGG. the next standard revision, in order to help de-risk ESG concerns in ASGM and provide traceability and legality The RGG’s structure is based on the OECD’s five-step to ASM material for refiners. LBMA is revising a toolkit due diligence framework for sourcing minerals from for refiners that are sourcing from ASM and would like conflict-affected and high-risk countries and its Gold to include FS ASM as part of it. LBMA would require Supplement, and it includes some ESG issues that go consultation with and agreement by its members and beyond those captured in Annex II. In sum, RGG broad other relevant stakeholders on the incorporation of the requirements are as follows: FS-ASM Standard’s PCI. They also anticipate that the main • Step 1. Establish strong company management barrier would be convincing refiners of the PCI’s utility systems. and winning their support for inclusion of the PCI into the RGG and toolkits. ESG requirements are a relatively new • Step 2. Identify and assess supply chain risks. concept in LBMA’s audit system, and implementation of • Step 3. Design and implement a management all the PCI at once might present too sudden a change. strategy to respond to identified risks. Phased-in and incremental adoption is more likely. • Step 4. Obtain independent third-party assurance Moreover, LBMA is looking to convene and connect on supply chain due diligence practices. refiners that are members of their Responsible Sourcing • Step 5. Report annually on supply chain due Programme with ASGM operations that are looking to diligence. pilot the FS-ASM Standard. Increasing direct sourcing 9 “Guidance Documents,” LBMA, accessed December 2021, https://www.lbma.org.uk/responsible-sourcing/guidance-documents. 10 Artisanal mining accounts for 20 percent of annual mined production but less than 1 percent of the throughput of LBMA Good Delivery List refiners (LBMA 2021b). FOREST-SMART MINING - ASM 29 of ASM material by Good Delivery List (GDL) refiners is initiatives that have a commercial application (unless a current strategic objective of LBMA and will be the there is a commercial agreement between LBMA focus of extensive consultations with key stakeholders in and a particular service provider). Ownership of the the value chain to find practical ways to remove current FS-ASM Standard’s intellectual property would have barriers to such sourcing. One option being considered to be clarified before LBMA could make a full public are initiatives, such as the FS-ASM Standard, which can endorsement. de-risk ASM material and act as a bridge between mining communities and GDL refiners. LBMA also intends to 6. Agreement. Present results from steps 2–5 and open its ASM Working Group (currently a closed forum seek agreement within LBMA’s members on the for GDL refiners) to outside organizations that have incorporation of all (or some) FS-ASM requirements demonstrated technical expertise and a field presence in into the RGG and Refiners Toolkit. ASM communities, such as Levin Sources and ARM. 7. Road map. Decide the timeline and pathway to c). How to get there? integrate requirements taking into account the results from steps 2–4 based on the next revision cycle of the RGG and toolkits planned for late 2022 or early 2023. The authors advise LBMA to follow these recommended steps to achieve its desired vision with regards to FS ASM. Convene LBMA members with ASGM entities willing to pilot FS ASM. Integrate FS-ASM Standard requirements into the RGG and the Refiners Toolkit. Additional opportunities for piloting the FS-ASM Standard, beyond the sites covered by the feasibility 1. Get everyone on board. Raise awareness of the FS- assessments in this report, might exist in some of the ASM Standard with LBMA leadership (including the ASGM sites of planetGOLD, Fairtrade, Fairmined, or CEO, CTO, legal counsel, the Board, and head of other responsible sourcing initiatives in which LBMA is responsible sourcing), LBMA’s members, and other participating already, such as the Zahabu Safi program relevant stakeholders, to buy them into the process. in the Democratic Republic of Congo or the Swiss Better This is also an opportunity to engage the banking Gold Initiative. LBMA is aware of these programs and community on forest-smart mining. can play a facilitating role to connect them to LBMA members who might be interested in buying their gold. 2. Benefits study. To convince LBMA members, who may be reticent to include more requirements, it is important to analyze the possible advantages (on 3.2. Other Standard-Setter Processes finances, reputation, and so on) of taking up the FS-ASM Standard requirements. Consider benefits Other standard setters can offer opportunities for not just to LBMA and its members but also to the engagement to accelerate the adoption of the FS-ASM achievement of more sustainable mining generally as Standard and to seed exploration of additional pilots a means to protect and enhance the gold brand, on in different sites and countries. The project team has the one hand, and the provenance of mined gold on received expressions of interest from the China Chamber the other. of Commerce of Metals, Minerals & Chemical Importers & Exporters (CCCMC), with respect to its Guidelines for 3. Gap assess LBMA’s RGG against the FS-ASM Standard Social Responsibility in Outbound Mining Investments to decide the process and progressivity for uptake of (CCCMC 2014), and from CORE, with respect to the CORE the standard’s PCI and guidelines. Standard (CORE 2019). 4. Feasibility assessment. In parallel to the gap assess- ment, assess (a) the feasibility of LBMA’s members to implement the standard’s PCI with or without support from LBMA and (b) how much support they would need at what cost. 5. Clarify intellectual property. LBMA supports open source initiatives like the CRAFT Code but adopts an ad hoc policy not to endorse proprietary systems or 30 FOREST-SMART MINING - ASM Source: © Pixabay, Africano masculino liberia negro FOREST-SMART MINING - ASM 31 4. FOREST FEASIBILITY OF ADOPTION OF THE BOLT-ON FS-ASM STANDARD IN LOCAL PROCESSES The terms of reference of the assignment indicate that “the 4.1 Selection of Pilot Countries and objective of the assignment is to assess and develop Forest Pilot Sites Carbon guidance and tools for the ASM sector by including Forest-Smart Mining Principles, Criteria & Indicators (FSM Artisanal and small-scale mining (ASM) takes place in PCI) into existing ASM standards and certification systems, more than 80 countries for a variety of minerals. For and to support their implementation by identifying this project, the client set Latin America and West Africa REDD+ and environmental/Climate funding oppor- as the scope and flagged Guinea and Côte d’Ivoire tunities and develop roadmaps for pilot sites” (World as two possible priority countries for the design of Bank 2020). pilots for testing the FS-ASM Standard. The consultants additionally proposed Colombia, Ghana, Liberia, and Objective 3 is “Processes to apply Forest-Smart ASM Peru as candidate countries. standards and certification systems are developed in selected pilot sites. Feasibility studies are conducted The six countries (Figure 4.1: Forest Cover of Candidate and detailed roadmaps and budgeted workplans are Countries) were assessed against a set of criteria such as developed.” This is reflected by the tasks to (a) REDD+ relevance (with 13 subcriteria), (b) situation of ASM (with 7 subcriteria), and (c) potential for uptake • “Identify and select pilot ASM operations/sites for the and implementation (with 7 subcriteria), intended application of ASM’s FSM PCI Standards. Two types of to ascertain the impact proposition (considering sites will be selected: carbon finance and ASM factors), feasibility, and likely »» Sites with an history of implementation of ASM sustainability of pursuing pilots in each country. standards and certification systems to demonstrate best-practice examples and motivate stakeholders to pursue their application; and »» Sites with significant potential for funding to support the application of standards through environmental and carbon finance, especially linked to REDD+ and World Bank programs. • “Analyze the feasibility of applying standards or certification systems for FSM PCI to those pilot ASM operations and assess the gaps to comply with standards. • “Develop detailed road maps and budgeted workplans for the implementation of FSM standards in selected pilot ASM operations, taking into consideration timelines and availability of environmental or carbon funding (World Bank 2020). 32 FOREST-SMART MINING - ASM Figure 4.1: Forest Cover of Candidate Countries Source: Global Forest Change 2000-2019 Data Download, Global Forest Watch, University of Maryland (accessed September 30, 2020), https://data.globalforestwatch.org. Note: The canopy density threshold of the forest cover of candidate counties is 15 percent in Africa and 30 percent in Latin America. The assessment resulted in the selection of Colombia, ASM standards and certification (Colombia, Peru, Ghana); Peru, Ghana, and Liberia in which to conduct the feasibility Liberia and Ghana have advanced REDD+ readiness; and studies for piloting the Forest-Smart Artisanal and Small- Colombia and Peru are making good progress toward Scale Mining (FS ASM) Standard (Table 4.1) Three of the REDD+ readiness. countries count on experience with the application of Table 4.1: Pilot Country Selection Uptake Consortium REDD+ ASM Proposal potential experience Colombia Good Strat., FREL, Context: conducive ARM, WWF, IIAP In-country: ARM Short list NFMS (HQ), FFI Cert. ASM Peru Good Strat., NFMS Context: conducive ARM, PureEarth, In-country: ARM Short list CINCIA (team), FFI Cert. ASM Côte Advanced Strat., Context: public Impact Limited potential Optional, if any d’Ivoire FREL, NFMS, SIS and polit. opinion partner short-listed inconducive unfeasible Guinea Poor Context: legislation WB, EU, CEPF Weak potential Eliminate inconducive partners None Liberia Advanced Strat., Context: conducive RSPB (Gola), FIP, In-country: FFI Short list FREL, NFMS, SIS GIZ (office) Ghana Advanced Strat., Context: conducive WB: FCPF and Strong partners Short list FREL, NFMS, SIS MMIP near-Cert. Note: ARM = Alliance for Responsible Mining; ASM = artisanal and small-scale mining; CINCIA = Centro de Innovación Científica Amazónica; EU = European Union; FCPF = Forest Carbon Partnership Facility; FFI = Fauna & Flora International; FREL = forest reference emission level; IIAP = Pacific Environmental Research Institute; MMIP = Multi-Sectorial Mining Integrated Project; NFMS = national forest monitoring system; SIS = safeguard information system; WB = World Bank. FOREST-SMART MINING - ASM 33 Each country’s pilot site was selected from a portfolio of between two and five potential pilot sites per country (Table 4.2)1 Table 4.2: Pilot Site Selection Proposed Mineral Environment REDD+ Piloting partner Colombia Gold ARM working with Biodiversity Carbon-dense Testing PCI in Afro-descendent hotspot forest community-managed Chocó groups of miners forests (Site 3) Peru Gold ARM working Proximity to Uncertainty Testing ground for the Puno with Indigenous Bahuja Sonene regarding the prevention PCI principle (Site 2) communities National Park availability of REDD+ Ghana Gold Solidaridad, NGO Proximity to Located in Testing improved working with Atewa Range a hotspot environmental Gold formalized highly Forest Reserve intervention area management in Empire mechanized ASMO for REDD+ mechanized operations Resources with experience with using mercury, and (Site 4) Fairmined restoration Liberia Diamonds Diamonds for Peace, Biodiversity Falls under priority Testing deforestation NGO working with hotspot Landscape 1 and degradation Weasua pre-formalized ASMO REDD+ jurisdiction avoidance and (Site 5) restoration aspects Note: ARM = Alliance for Responsible Mining; ASMO = artisanal and small-scale mining organizations; NGO = nongovernmental organization; PCI = principles, criteria, and indicators. 4.2 Feasibility Studies for Piloting the mainstreaming, anti-corruption, community-based FS-ASM Standard natural resource management). 4.2.1 Methodology • Baseline and gap assessment of the mine site and its already preexisting conformance with the FS-ASM As outlined in chapter 1.2, the methodology for Standard’s requirements (PCI for ASM entities) and conducting the feasibility studies in each pilot country national environmental regulations, including the and site consisted of the following: collection of miners’ and other national stakeholders’ feedback on the assessment’s findings and on incentives and desirable activities that would make • Stakeholder mapping and engagement to forest-smart ASM more feasible. map and describe the relevance of all local and national stakeholders, including those relevant to the implementation of REDD+ and climate • Forest carbon assessment, summarizing the financing generally that could be instrumental in the REDD+ status of the country; identifying ongoing implementation of (a) the feasibility study and (b) the forest carbon, climate, and biodiversity initiatives; and subsequent potential pilot and scaling of FSM. conducting a preliminary qualitative assessment of the forest resources currently affected by the ASM mine site, estimating the additionality that could be • Review of ASM and REDD+ regulation, conducted achieved by implementing the FS-ASM Standard in as a desk review of regulations related to ASM and the pilot site. Carbon feasibility assessment centers REDD+ and a light-touch desk review of natural around a reasonability assessment as to whether the resource and land use policies and processes, recent history and extent of forest loss lends itself focusing on environmental and forest compliance to the development of a carbon-financed forest and key factors that determine the success of forest- conservation initiative. smart mining governance (for example, gender 1 See the country feasibility assessments in the annexes. 34 FOREST-SMART MINING - ASM • Stakeholder consultation, collecting feedback • The Alliance for Responsible Mining (ARM), as the on the appropriateness of the FS-ASM Standard maintainer of the CRAFT Code, has vast experience in (the draft PCI for ASM entities and guidelines) to the applying the CRAFT Code for gap analyses to which— local reality and the national context and assessing for the feasibility assessment—the FS-ASM Standard to what extent the standard corresponds with the was bolted on. necessities, priorities, and capacities (both know-how and financial) of the miners. 4.2.2 Colombia • Producing recommendations on ASM and The full Colombia Feasibility Assessment (partly in English, REDD+ regulations, based on the findings from partly in Spanish) is contained in the separate Annex 2: the baseline and gap assessment, a strengths, Feasibility Assessment of Piloting FS ASM in Colombia. weaknesses, opportunities, threats (SWOT) analysis, and stakeholder consultations. Pilot Site • Producing a road map and budgeted workplan The pilot site selected for Colombia corresponds to a for piloting and integrating the standard’s PCI into the Special Reserve Area (ARE) located in the municipality of selected site and the guidelines into relevant local Tadó, in the eastern part of the department of Chocó, and national institutions, including climate finance within the collective territory of the community council mechanisms. ASOCASAN, an ethnic-territorial organization that manages the resources of the area for around 5,000 • Identifying funding opportunities for each pilot people, grouped into approximately 1,500 families. country and site. Community members are dedicated to traditional alluvial gold mining, currently at 52 artisanal mine sites, For “bolting on” the FS-ASM Standard, the CRAFT Code distributed in the seven land plots of the area. ASOCASAN was used for various reasons: is familiar with the concept of ASM standards and certification schemes: the council was formerly certified • The CRAFT Code is open source under Creative by the Oro Verde Program, is currently using CRAFT, and Commons License CC-BY-SA 4.0, which explicitly aspires toward Fairmined certification. allows any adaptation under the condition that the adapted version contains a reference to the source (which is herewith done: ARM 2020a) and that the adapted version is published under the same Creative Commons license terms (this does not apply because no amended CRAFT version is published). Therefore, testing the FS-ASM Standard in combination with CRAFT does not infringe any intellectual property rights of standard setters. • Modules 1–4 of the CRAFT Code represent the supply chain risks addressed by the Organisation for Economic Co-operation and Development Due Diligence Guidance, which is considered the minimum benchmark for engagement with an ASM entity. FOREST-SMART MINING - ASM 35 Figure 4.2: ASOCASAN Alluvial Mine Site, Colombia Source: © Alliance for Responsible Mining. According to its role as a community council, ASOCASAN Gap Assessment has already developed a Territorial Management Plan, which links community needs, resources management, Due to time and resource constraints for assessing the and ecosystem services, integrating a traditional multi- pilot site feasibility, the gap assessment was carried out optional community production system, based on the on a sample of two visited mine sites out of the existing combination of agriculture, fishing, mining, forestry, 52 mine sites, using a translated version of the second animal husbandry, hunting, and artisanal work in draft version of the FS-ASM Standard (see chapter 2.1). accordance with the natural conditions of the landscape. Figure 4.3: Summary of Gap Assessment Results of FS- ASM Requirement Sections B.5.1–B.5.4 in Colombia For the above reasons, ASOCASAN’s Board of Directors summarizes the findings. declared from the outset their interest in forest-smart mining as a pathway toward potential future carbon financing projects. 36 FOREST-SMART MINING - ASM Figure 4.3: Summary of Gap Assessment Results of FS-ASM Requirement Sections B.5.1–B.5.4 in Colombia 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% B.5.1 B.5.2 B.5.3 B.5.4 Not applicable 16 2 No progress 44 1 Ongoing 8 10 1 Finished 7 6 4 1 Note: FS-ASM Standard Requirement B.5.1: Situation Assessment and Planning; B.5.2: Direct Impacts – Mining; B.5.3: Direct Impacts – Nonmining; B.5.4: Indirect Impacts. It is notable that all requirements of section B.5.1 of the Only two requirements were identified by the miners standard are already either met or ongoing. Regarding as encompassing a gap that cannot be closed. These direct impacts from mining (section B.5.2), approximately need to be reassessed during the implementation a quarter of the requirements were assessed as fulfilled of the pilot project. If necessary, the flexibility of the or in progress. Two-thirds of the requirements of sections Frugal Rehabilitation Methodology (FRM) will allow B.5.3 and B.5.4 together (direct non-mining and indirect implementers to identify an alternative approach impacts) are met or ongoing. for fulfilling the requirements. In any case, during implementation of the pilot project, a gap analysis needs The gap analysis confirms the following: to be conducted on all mine sites and using the final • The FS ASM preparedness of the ASM entity. Even version of the FS-ASM Standard. prior to the existence of the standard, efforts were already being undertaken that were aligned with the In conclusion, piloting the FS-ASM Standard is considered requirements of the standard (that is, relatively high feasible at the mining sites of ASOCASAN. number of requirements assessed as already fulfilled or ongoing). Forest Carbon Assessment • By implementing the FS-ASM standard, a significant Colombia has made significant progress in its REDD+ number of direct impacts from mining will be readiness: it has a REDD+ strategy, a forest reference addressed, which—without the standard—might emission level (FREL), and a national forest monitoring remain unaddressed (that is, all requirements assessed system (NFMS) (with a forest definition). However, as “no progress”). although summaries of safeguard information have been submitted to the United Nations Framework Some requirements were assessed as “not applicable.” Convention on Climate Change (UNFCCC), it appears In some cases, this relates to requirements that really the safeguards information system (SIS) is not finalized address non-applicable site conditions; in some cases, and the nature of safeguards against the conversion of it relates to the wording of the draft standard (or the natural forest to plantation forest and specific protections translation into Spanish), which was subsequently for biodiversity in the REDD+ system were unclear2. The improved; and in some cases, the requirements address topics that miners are not yet familiar with and on which 2 “Colombia.” UN-REDD Programme Collaborative Workspace, they would need training before application. accessed October 1, 2020, https://www.unredd.net/index. php?option=com_country&view=countries&id=44&Itemid=603. FOREST-SMART MINING - ASM 37 level of measurement, reporting, and verification (MRV) benefits that are perceived from it. It was reported that institutions and capacities in the country is good, and a proposal for the development of a carbon initiative Colombia has set clear country targets under the Paris was discussed (and under development for some time Agreement (World Bank 2019d). It is unclear on first now) by the community councils of the municipalities of review whether the country has finalized a benefit- Unión Panamericana and Tadó. sharing system for REDD+ and rules on nesting and the international sale of emission reductionsIt eribus re Also, it would need to be confirmed that a suitable nossum ad ut everum ullam ea prore odis am volorero methodology for a project where mining is a driver is A GIS analysis (Figure 4.4) was performed by combining available under the Verified Carbon Standard (VCS) (or data on tree cover, forest loss, and intact landscapes from one would need to be developed, which is very time- the Global Forest Watch, data on protected areas from consuming). It would be theoretically possible for miners the World Database on Protected Areas, and selected to obtain benefits through a benefit-sharing mechanism geographic features (water bodies, roads, populated for a jurisdictional initiative. However, there is no sites) from Open Street Map with the pilot site location. indication that a suitable initiative exists. For the pilot site location, 2-kilometer and 5-kilometer buffer areas are indicated. The site is located near intact Outcome of Stakeholder Consultations forest landscapes and the Tatama Protected Area. Stakeholder consultation involved the Ministry of Mines The assessment shows that deforestation patterns do not and Energy, Regional Autonomous Corporation for the correlate clearly with the locations of mine sites along Sustainable Development of Chocó (CODECHOCÓ), the river. Therefore, direct impacts of mining at the ASM Mayor’s Office of Tadó, Technological University of scale do not seem to be a main driver of deforestation Chocó (UTCH), planetGOLD, WWF, Fondo Acción, in the wider proximity of the pilot site. This matches the Pacific Environmental Research Institute (IIAP), and fact that mineral extraction is done in a very artisanal the Colombian Institute of Technical Standards and manner, mostly manual, with a very low footprint. There Certification (ICONTEC). is, however, fairly significant deforestation in the area generally. This suggests that a quite substantial carbon When consulted on the FS-ASM Standard, stakeholders benefit could be generated through project activities, expressed concerns regarding the capacity of artisanal but it appears that this would be in the broader landscape miners to conform with all requirements without through limiting other impacts as well as mining impacts external support. This highlights and strengthens the and through restoration of cleared areas. points made in the standard’s guidelines on the need for enabling engagement and resources to assist in capacity Local experience with carbon finance exists. Fondo building and implementation. On the other hand, it was Acción, a nongovernmental organization (NGO) that also mentioned that due to their ethnocultural traditions has implemented REDD+ projects in the region (GoCO- as afro-descendant communities recognized by Law Minambiente 2017), indicates that a REDD+ project in the 70 of 1993, miners have a degree of environmental area would need to be implemented at scale, addressing sensitivity that has not been lost and it is easy for people deforestation/degradation in the landscape generally, to who carry out mining on a traditional scale to implement be viable on a cost-benefit basis. The NGO notes that the action on revegetation, activities that are done as part of national market for credits has a ceiling for credit prices, their native tasks. This is a seen as a favorable condition while the international market does not. However, it is for piloting the standard at this site. still significant that the national market exists. Some stakeholders suggested that the thematic scope The development of a project would need to consider of the standard could be expanded to health and safety in detail the circumstances of the ASM in the area (for and other environmental topics such as water resource example, the legal circumstances) and the extent of management. These suggestions were noted by the the carbon benefit that could be created. The miners’ standard team but not addressed in order to maintain capacity to engage on carbon will need to be built. the thematic focus of a bolt-on standard. Concerns Furthermore, the community councils whose territories about the verbatim applicability of certain standard are composed of geographic areas of high biodiversity requirements in the specific context of the Chocó must reach internal cooperation agreements that allow were addressed during the standard development (see the delimitation of a larger area (potentially exceeding chapter 2.1), clarifying the flexibility of the FRM. the size of the mining area), since small areas of land would not provide a balance between the cost of National and regional government officials referred to implementing the REDD+ project and the economic the technical and financial shortcomings of the ASM 38 FOREST-SMART MINING - ASM Figure 4.4: GIS Analysis of Forest Resources and Deforestation in the Proximity of the Colombian FS-ASM Pilot Site and Its Buffer Areas (2 km, 5 km) Source: Global Forest Change 2000-2019 Data Download (accessed September 30, 2020) and Intact Forest Landscapes 2016 (accessed October 14, 2021), Global Forest Watch, University of Maryland, https://data.globalforestwatch.org; World Database on Protected Areas, Protected Planet (accessed October 14, 2021), https://protectedplanet.net; Open Street Map FOREST-SMART MINING - ASM 39 sector, highlighted the difficulties of ASM formalization • Conduct training and education processes that in Colombia, and responded positively to the standard. strengthen the knowledge of the ecosystems They consider that projects for implementing the inhabited by artisanal and small-scale miners, and the standard would generate local capacity of good mining importance they have not only for their environment practices and contribute to compliance with often but for life in general. ignored obligations, such as site rehabilitation during mine closure. The standard is seen as a contribution to • Conduct training and education programs on the implementation of environmental instruments that organizational issues and associativity, as the main are mandatory for miners to develop their mining activity. axis for the development of organized miners and Additionally, they positively recognized the potential to community councils. generate additional income for miners in the long term. • Establish public policies that have an impact on Recommendations on ASM and REDD+ attracting financial resources required to improve Regulations ASM technology. During the consultations, stakeholders made various • Recognize the ASM sector as a legitimate mineral recommendations that reflect starting points for producer and connect it to responsible supply chains. identifying potential incentives to promote adoption and implementation of the FS-ASM Standard3: • Develop a methodology that allows to account for and claim forest carbon credits by ASM operators, as • Assistance from state institutions, which have the an incentive to conform with the FS-ASM Standard appropriate human and financial resources to support and for good environmental performance in general. ASM entities with geological research, exploration, and planning. Road Map, Budgeted Workplan, and Funding Opportunities • Regulations that apply differentiated technical and environmental instruments for ASM, in accordance A road map (summarized in Figure 4.5), a budgeted with its economic capacity. workplan, and an exploratory analysis of potential funding opportunities for piloting the FS-ASM Standard • Regulations that allow the use of motor pumps in Colombia is contained in the separate Annex 2: appropriate to the scale of operations (for example, Feasibility Assessment of Piloting FS ASM in Colombia. no more than 6 horsepower) and establish the environmental conditions under which their use would be possible, as technical aids for artisanal mining, to improve work conditions and contribute to its profitability. • Harmonize the environmental instruments of community associations in exercise of the provisions of Law 70 of 1993 with the requirements for environmental management plans. Validating the instruments of the Law 70 of 1993, which have strong ancestral connotations, for the purpose of being presented in the scope of mining and environmental legislation (for which they are not valid), would be considered a major incentive. 3 “ The list of recommendations reflects the views stakeholders expressed when consulted on the feasibility of implementing the FS-ASM Standard. The list is therefore not to be understood as a comprehensive portfolio of recommendations to improve ASM and REDD+ regulations in general, which is beyond the scope of this assignment. 40 FOREST-SMART MINING - ASM Figure 4.5: Sequence of Major Activities, Colombia 2. 1. Environmental Implementation 3. Creation of a 4. Create a water Impact Study of environmental community nursery management plan Preparation management measures 1.1 Detailed 3.1 Construction baseline and 2.1 Follow-up to 4.1 Construction of mapping of key the implementation treatment systems aspects and efficiency of management 3.2 Provisioning measures 4.2 Water recirculation 1.2 Diagnosis of pilots water use aspects 2.2 Workshops and 3.3 Capacity building training, following a 1.3 Environmental training program Review of other management actions necessary to measures adjustments to the reduce deforestation/ characteristics of degradation and the work fronts Seed rescue Nursery and storage search for market Compliance management opportunities with regulatory requirements Such a project should have a minimum duration of 2–3 The CMO mining claim covers approximately 300 years, covering various annual vegetation cycles and thus hectares in the catchment area of the Pallecapampa allowing validation of the expected forest outcomes. stream, which is the main water source for the district capital. Within this area, hard-rock gold ore is extracted by underground mining, accessing the vein type deposit 4.2.3 Peru by multiple access tunnels of varying size and depth according to the terrain conditions. Gangue mineral is The full Peru Feasibility Assessment (partly in English, dumped on waste rock dumps (Figure 4.6) and the ore is partly in Spanish) is contained in the separate Annex 3: processed by amalgamation. Feasibility Assessment of Piloting FS ASM in Peru. Pilot Site The Comunidad Minera de Ollachea (CMO) is a legally established ASM entity owned by the Ollachea Peasant Community⁴, located in the Ollachea district at 2,800 meters altitude, province of Carabaya, department of Puno in southeastern Peru. The CMO is duly constituted with 78 members (61 males and 17 females) and provides employment opportunities to approximately 760 men and women. 4 Peasant communities are organizations of public interest, with legal existence and legal personality made up of families that inhabit and control certain territories, linked by ancestral, social, economic, and cultural ties, expressed in communal ownership of land, communal work, mutual aid, democratic government, and the development of multisectoral activities, whose aims are oriented to the full realization of its members and the country (Article 2, General Law of Peasant Communities. Law no. 24656). FOREST-SMART MINING - ASM 41 Figure 4.6: A CMO Mine Site and Waste Rock Dumps, Peru Source: © Alliance for Responsible Mining. The CMO Board of Directors expressed a keenness to Gap Assessment participate in initiatives that help improve its mining operations by adapting and/or improving them with The gap assessment was carried out using a translated a focus on sustainable management of the Ollachea version of the second draft version of the FS-ASM Peasant Community’s natural resources; the board also Standard (see chapter 2.1). Figure 4.7 summarizes the expressed an interest in carbon finance projects and findings; standard requirements that cover issues not REDD+ mechanisms. present in the area (that is, alluvial mining–related issues) as well as standard requirements that exceed Peruvian regulations were classified as “not applicable.” An additional gap analysis of the Peruvian legislation versus FS-ASM Standard requirements (Figure 4.9) clarified this misunderstanding. Hence, most “not applicable” requirements need to be interpreted as “no progress.” 42 FOREST-SMART MINING - ASM Figure 4.7: Summary of Gap Assessment Results of FS-ASM Requirement Sections B.5.1–B.5.4 in Peru 100% 9 0% 80% 70% 60% 50% 40% 30% 20% 10% 0% B.5.1 B.5.2 B.5.3 B.5.4 applicable Not aplica No 7 25 7 0 No progress Sin Progreso 6 14 0 0 In progress En curso 1 21 2 2 Finished Terminado 1 13 0 0 Note: FS-ASM Standard Requirement B.5.1: Situation Assessment and Planning, B.5.2: Direct Impacts – Mining, B.5.3: Direct Impacts – Nonmining, B.5.4: Indirect Impacts; no aplica = not applicable; sin progreso = no progress; en curso = in progress; terminado = completed. It is notable that the level of preexisting conformance Forest Carbon Assessment (requirements assessed as finished and ongoing) is much lower than in Colombia (compare with Figure Peru has made progress in REDD+ readiness and has 4.3). A gap closure analysis carried out jointly with the a REDD+ strategy and an NFMS⁶, but the FREL and SIS miners, however, confirmed that all gaps can be closed⁵, are not complete. The nature of safeguards against the although it will require external support and guidance. conversion of natural forest to plantation forest and Thirteen requirements, mostly related to section B.5.2 of specific protections for biodiversity in the REDD+ system the standard (roughly 20 percent of the requirements to was unclear on first review. The level of MRV institutions reduce direct mining impacts), exceed the technical and and capacities in the country is good. MINAM (Ministry financial capacity of the CMO and therefore will depend of the Environment) has responsibility for the National on the availability of third-party support and investment. Strategy for Forests and Climate Change and REDD+. The country has not finalized its benefit-sharing system for The CMO’s Environmental Management Plan (EMP), REDD+ (FCPF 2020). Peru is participating in the World submitted to the Regional Directorate of Energy and Bank’s Carbon Fund (an emission reductions program in Mines (DREM), details its environmental commitments. the departments of Ucayali and San Martin) but has not The considerable number of issues identified during the yet signed an Emission Reductions Payment Agreement gap analysis therefore confirms that by implementing (FCPF 2019b). the FS-ASM Standard, a significant number of direct and indirect impacts from mining will be additionally A GIS analysis (Figure 4.8) was performed by combining addressed, which—without the standard—might data on tree cover, forest loss, and intact landscapes from remain unaddressed. the Global Forest Watch, data on protected areas from the World Database on Protected Areas, and selected In conclusion, piloting the FS-ASM Standard is considered geographic features (water bodies, populated sites) from feasible at the mining sites of the CMO. Open Street Map with the pilot site location. For the pilot 5 One gap was identified as technically impossible to close. In response, the final version of the FS-ASM Standard was amended, further clarifying the concept of the FRM as a nature-based solution that needs to be adapted to local site conditions. 6 “Peru,” UN-REDD Programme Collaborative Workspace, accessed October 1, 2020, https://www.unredd.net/index.php?option=com_country&view=countries&id=52&Itemid=612. FOREST-SMART MINING - ASM 43 Figure 4.8: GIS Analysis of Forest Resources and Deforestation in the Proximity of the Peruvian FS ASM Pilot Site and Its Buffer Areas (2 km, 5 km) Source: Global Forest Change 2000-2019 Data Download (accessed September 30, 2020) and Intact Forest Landscapes 2016 (accessed October 14, 2021), Global Forest Watch, University of Maryland, https://data.globalforestwatch.org; World Database on Protected Areas, Protected Planet (accessed October 14, 2021), https://protectedplanet.net; Open Street Map. 44 FOREST-SMART MINING - ASM site location, 2-kilometer and 5-kilometer buffer areas are could ascertain whether the project sits within a broader indicated. Additionally, the GIS analysis contains current jurisdiction that is successfully attracting carbon finance; mining cadastre data⁷. perhaps a future benefit-sharing system could distribute funding for FS ASM. This would need to be developed in The pilot site is located in the upstream section of a collaboration with the government. tributary of the Inambari River, with intact forest located about 20 kilometers downstream. No protected area Outcome of Stakeholder Consultations exists near the pilot site. Tree coverage within the buffer areas appears to be low in the GFW database, mainly Stakeholder consultation on the FS-ASM Standard because the site is located at the timberline between involved the Servicio Nacional Forestal (SERFOR), tropical mountain forest and tropical cloud forest⁸. Tree Organismo de Supervisión de los Recursos Forestales height in such forests is limited (see Figure 4.6) and y de Fauna Silvestre (OSINFOR), Regional Directorate of therefore apparently not fully reflected as “forest” in the Energy and Mines (DREM), Wildlife Conservation Society GFW data set. That notwithstanding, it is a very fragile (WCS), the NGO Pure Earth, and the miners’ federation ecosystem, similar to the protected páramo in Colombia. Sociedad Nacional de Minería de Pequeña Escala (SONAMIPE). The assessment of the area of study reveals that deforestation patterns along the river do not correlate The stakeholder responses were rather mixed, somewhat clearly with the locations of mining licenses. Therefore, ad hoc, and led by nonspecific perspectives on ASM direct impacts of mining do not seem to be a main driver in general and not always specific to the PCI and their of deforestation in the wider proximity of the pilot site. application. Feedback on the completeness of the This matches the fact that mineral extraction is mainly standard produced some rewording proposals (in the done by underground mining, whereby surface areas are Spanish translation), but no factual gaps were identified only occupied by mine entrances and waste rock dumps that would have required a substantial amendment (see Figure 4.6). of the draft version. The consulted stakeholders— including three environmental organizations—raised no The importance of forest-smart mining at the pilot objections on how the FS-ASM Standard approaches the site relates less to massive carbon storage potential topic of Key Biodiversity Areas and High Conservation (which is low in tropical cloud forest compared with Value Areas. In the main, stakeholders received the tropical rainforest) but to the protection of the highly standard positively. fragile ecosystem services of the cloud forest. The national Peruvian vegetation map indicates that “the Stakeholders also suggested further environment- ecological and strategic conditions of this coverage related topics, such as mercury use, to be included in represent a reason for them to be conserved and the standard. These suggestions were noted by the protected as centers of biodiversity and as excellent standard team but not addressed in order to maintain providers of environmental services (water regulation, the thematic focus of a bolt-on standard. soil conservation, carbon storage, visual richness, etc.)” (GoPE-MINAM 2015, 50). Government entities consulted, such as SERFOR, OSINFOR, and DREM, considered the structure of the The site assessment suggests that despite the site’s standard, its organizational and geographic scope, and potential for carbon storage, it might not be feasible its PCI requirements. The FS-ASM Standard was seen to fund FS ASM in the area through carbon finance, as supporting many of the policies established by the particularly not as a stand-alone project under a Peruvian government that—due to budget constraints— voluntary standard. The avoidance of small mining are not implemented. The officials proposed to pilot and impacts might be able to be integrated into the implement the standard also in other regions and ASM country’s REDD+ benefit-sharing system, which could contexts (for example, alluvial mining). distribute payments for results in the broader landscape. However, it is understood that Peru has not finalized its benefit-sharing system for REDD+. Further research 7 Catastro Minero Actualizado, GEOCATMIN, Instituto Geológico, Minero y Metalúrgico, accessed October 14, 2021, https://geocatmin.ingemmet.gob.pe/geocatmin/. 8 Classified as Bosque de montaña montano (Bm-mo) and Bosque de montaña altimontano (Bm-al), according to the Mapa nacional de cobertura vegetal (GoPE-MINAM 2015). FOREST-SMART MINING - ASM 45 Recommendations on ASM and REDD+ Regulations Figure 4.9: Requirements of the Peruvian Mining Regulations versus Requirements of the FS-ASM Standard 100% 9 0% 80% 70% 60% 50% 40% 30% 20% 10% 0% B.5.1 B.5.2 B.5.3 B.5.4 Requirements not found in the Act 11 29 7 0 Requirements found in the Law 4 44 2 2 Requirements found in the Law Requirements not found in the Act The gap analysis of the Peruvian legislation versus FS- With a legal framework in place or under improvement, ASM Standard requirements illustrates the extent to outreach and engagement with artisanal and small- which the standard exceeds legal requirements (Figure scale miners in the informal sector needs to touch 4.9). On a positive note, this proves the additionality the ground. For that purpose, Peru already has the REINFO standard could provide, but it raises concerns about in place, which is the registry of informal miners in the environmental regulations—even more so since the process of formalization. These individuals, natural or vast majority of ASM operations, still stuck in the process legal, can legitimately develop mining activities, provided of formalization, are not even compliant with all legal they commit to completing the Comprehensive Mining requirements. Formalization Process. Such outreach and engagement need to do the following: Therefore, advancing the ASM formalization process is seen as a priority in general but specifically as a starting • Establish more detailed information on the characte- point for implementing the FS-ASM Standard. To support ristics of mining projects registered in REINFO, a bank this process, the following actions are recommended⁹: of projects according to the mining activity carried out, as well as their location. Strengthening an enabling legal and regulatory framework for the ASM sector is a precondition for • Identify informal mining settlements that are occu- a successful formalization process. This requires the pying the mining rights of third parties and assume following: an active role as facilitators to provide channels for resolving these conflicts through a policy of dialogue • Implement the support measures for artisanal mining and consensus building to make viable the option stipulated in the current Regulations of Law No. 27651 of signing “exploitation contracts or agreements” or – Law for the Formalization and Promotion of Small- other contractual forms that lead to formalization. Scale Mining and Artisanal Mining and in all current and complementary legislation on this issue. • Provide training and technical and environmental assistance to miners registered in REINFO. • Adapt sectoral regulations to the reality and condi- tions of artisanal mining producers so that the cost of Continued support to legal ASM operations, however, formality does not become a barrier. is as important as the initial outreach to the informal sector. Therefore, the following is needed: 9 See footnote 5 in chapter 2. 46 FOREST-SMART MINING - ASM • Disseminate the progress made by mining owners • Promote awareness plans on different environmental and/or operators that meet the operational, environ- issues, for compliance with current legislation at the mental, labor, social, and organizational standards organizational level. required by law; promote internships to draw on the lessons learned. • Implement topsoil management plans and proce- dures in a structured manner to optimize the recovery • Conduct a detailed analysis and seek solutions to the of degraded areas or intervened zones. issues presented by the Corrective Environmental Management Instrument (IGAC)/Environmental Road Map, Budgeted Workplan, and Funding Management Instrument for the Formalization of Opportunities Small-Scale Mining and Artisanal Mining Activities (IGAFOM) that are observed or in the process of A road map, a budgeted workplan, and an exploratory evaluation so that they do not become abandoned. analysis of potential funding opportunities for piloting the FS-ASM Standard in Peru is contained in the separate • Seek national and international funding to support Annex 3: Feasibility Assessment of Piloting FS ASM in mining owners and operators who are formalized, to Peru. Such a project should have a minimum duration make this process sustainable over time. of 2–3 years, covering various annual vegetation cycles and thus allowing validation of the expected forest Last but not least, permanent capacity building and outcomes. training is essential: 4.2.4 Ghana • Promote participatory workshops in situ with the presence of mine owners and mine operators and The full Ghana Feasibility Assessment is contained in the all personnel working in different areas of mine separate Annex 4: Feasibility Assessment of Piloting FS ASM operation, plant, and administration in order to do in Ghana. the following: Pilot Site »» Improve occupational health and safety stan- dards, environmental management standards, The pilot site selected for Ghana is the small-scale mine organizational standards, and others imposed of Key Empire Resources Ltd., a privately owned mining by the Peruvian legislation. company, operating on a small-scale mining lease of 25 acres, located near the village Akyem Ekorso, Atiwa West »» Transmit knowledge about new operational municipality, Eastern Region. The concession area falls technologies and handling of toxic substances, within a rural setting, with subsistence farming, transport as well as the treatment of acidic water prior to business, petty trading, and mining the main economic its discharge. activities. The mine currently employs 17 employees (all »» Involve universities in the field of research and male). technical training to implement improvements in systems or methods of exploitation, meta- A few years ago, and with support from Solidaridad, Key llurgical recovery. Empire Resources had been working toward Fairmined certification. This exercise stalled when the government In support of implementation of the FS-ASM Standard, of Ghana imposed a temporary ban on all small-scale the following is further recommended: mining and operations were suspended. In 2019, the mine was allowed to resume operations. Activities to resume work toward certification have not yet • Create a space for multisectoral discussion on the commenced. relationship between forestry and ASM issues. The deposit being exploited is alluvial, with the ground • Design a national forest-smart mining plan that incor- excavated to the gold-bearing gravels and stockpiled porates forest management and REDD+ issues into for subsequent processing. The mining method the environmental management instruments that includes excavating the gold-bearing coarse materials guide small-scale miners. and transporting them to the plant for processing in a trommel with a capacity of 100 tons of gravel per hour. • Implement REDD+ mechanisms articulated to forest The pilot site is surrounded by technically similar mining management in ASM concessions. operations on both riversides (see inset in Figure 4.10). FOREST-SMART MINING - ASM 47 Figure 4.10: Alluvial Open-Pit Mining Operation of Key Empire Resources in Ghana and Google Earth View of Adjacent Operations Source: (main) © Solidaridad West Africa; (inset) Google Earth. Gap Assessment The gap analysis was undertaken relative to the five While the priority level for this subtheme is thematic areas of the FS-ASM Standard. generally high, the gap identified was the lack of documentation, particularly records on baseline, 1. Situation assessment and planning requirements. monitoring, and progress reports. However, as Key Empire Resources proactively prioritizes engage- the complexity level for the gap is low, the mine ments with relevant stakeholders such as government is likely to close these gaps with the necessary agencies (Forestry Commission of Ghana, the awareness raising, guidance, and technical Environmental Protection Agency, Minerals Commi- support. ssion), civil society organizations, experts, and the local community. However, the mine has yet to use »» Forest and vegetation clearance prior to mining. the information from the various engagements to No documented records of harvested timber develop appropriate impact mitigation and control exist. Suitable sites within the immediate vicinity measures and plans that will guide their operations of the operating pits have been designated throughout the life of the mine. for stockpiling topsoil material to be used for land reclamation after mining ore from the pit. 2. Direct mining impacts However, there was no inventory of the amount of topsoil stored and volumes used on the mine. »» Planning and preparation of mining activities. 48 FOREST-SMART MINING - ASM »» Technical rehabilitation. The ASM entity has yet operations and the control measures to be instituted to meet a number of the requirements under to eliminate or control these potential risks. technical rehabilitation, particularly waste and water management plans/records, and standard 5. Carbon finance. Some miners and management operating procedures for the safe handling and members are aware of some existing emission storage of chemicals including hydrocarbons reductions programs (ERPs); however, the ASM entity such as oils, diesel, and so on. is unable to take advantage of these programs since they target the cocoa and shea sectors, which are »» Topsoil management. Generally, the topsoil prioritized under Ghana’s REDD+ program. Key Empire management strategy was compliant with the is willing to engage with the relevant stakeholders requirements except for the lack of a docu- for the development of ERPs for the ASM sector and mented soil management plan as well as indicated the need for their capacity to be built on records/inventory on soil organic material. various emission reduction strategies as well as the provision of technical support for the development »» Biological rehabilitation. The mine partners and implementation of these strategies in their mine with the Forestry Commission of Ghana for value chain. The ASM entity indicates their willingness their seedlings needs and therefore does not to adopt international ERP guidelines/voluntary necessarily prioritize the establishment of a standards as long as these guidelines/standards fit nursery on site. However, the mine must develop into the local ASM mining context. an environmental management policy and a mine rehabilitation plan to fully comply with the It was realized that all the gaps can be closed with the requirements, which are also in accordance with necessary support. The level of complexity in addressing ASM regulatory requirements in Ghana. most of the issues was low by the miners, making them relatively easy to address, particularly as they are well »» Site closure and handover. Based on the geo- established in the ASM regularly frameworks in Ghana. logical/soil characteristics, acid mine drainage is unlikely at the site. The mine, in accordance In conclusion, piloting the FS-ASM Standard is considered with ASM regulations, has indicated that they feasible at the mining site of Key Empire Resources Ltd. will, under the supervision of the Environmental Protection Agency and with the involvement of Forest Carbon Assessment the local and traditional authorities, sign off and hand over the rehabilitated concession to the REDD+ Readiness in Ghana is at an advanced stage. community upon mine closure. The Ghana REDD+ Strategy/Action Plan, which was established and launched in 2016, is well aligned with 3. Direct nonmining impacts. Even though the ASM key national developmental strategies and policies, entity has no inventory/records of the local wildlife including the National Climate Change Policy, Forest and globally recognized as endangered species, they Wildlife Policy, Ghana’s Shared Growth and Development indicated this information can be obtained from Agenda GSGDA, and Ghana’s Nationally Determined the Forestry Commission or Wildlife Society. Miners Contribution (NDC) to UNFCCC (GoGH-GFC, GhREDD+, would need to be educated on wildlife conservation and FCPF 2016; Graham 2016). The assessment of land and the prohibition of hunting and consumption of use and land use change drivers was undertaken and wild/bushmeat. The mine must develop a written adequately informed the process and development of policy on wildlife conservation. the Ghana National REDD+ Strategy. The strategy options were selected through a participatory and inclusive 4. Indirect mining impacts. Risk assessments on process including the use of a Strategic Environmental forest impacts as well as mitigation measures have and Social Assessment process. not been documented even though management indicates they are aware of the necessary measures The FREL was established in 2017 and there are structures to be put in place. These measures should however in place for MRV (GoGH-GFC 2016; Graham 2016). Ghana be outlined in an environmental management plan has developed NFMS protocols and its structures are in for the mine. This plan should be developed after a place, including institutional arrangements for an NFMS comprehensive environmental and social impact (IKI and BMU 2019). Good progress has been made in assessment has been conducted. Key Empire must influencing key national policy development processes, engage with key stakeholders as well as with the but these are yet to be translated into legally binding local community on the potential risks of its mining laws. FOREST-SMART MINING - ASM 49 Ghana has submitted its first summary of information in the intensity of forest loss between mining and on Reducing Emissions from Deforestation and forest nonmining economic activities. Degradation (REDD+) safeguards to the UNFCCC, providing a comprehensive demonstration of how the The analysis suggests that a significant carbon benefit country is addressing the Cancun Safeguards and how could be generated through project activities avoiding it intends to respect and report on REDD+ safeguards deforestation/degradation and undertaking restoration. using its functional institutional framework (IKI and BMU It is not clear the extent to which the evident clearance 2019). A framework has also been established for REDD+ is due to mining as opposed to agriculture. This area is in safeguards implementation and monitoring, including a hotspot intervention area (HIA) for the Ghana Cocoa the development of a safeguards information system REDD+ Forest Program (GCRFP), which is an ERP. The Web platform and a feedback and grievance redress HIA is a focus area for intervention within a subnational mechanism. Because the REDD+ Strategy and Ghana’s REDD+ program and it is understood that this area NDC are closely linked, the ERP for the cocoa-forest benefits from the payment agreement signed with the landscape has been featured as one of the interventions FCPF Carbon Fund. The baseline for the GCRFP is for the that will enable Ghana to meet its NDC target of reducing entire program area and carbon will only be transacted current national emissions by up to 45 percent by 2030. on at the program level (GoGH-GFC 2020). Therefore, it would not be feasible to develop a voluntary project The capacity of the national REDD+ secretariat under a voluntary standard (for example, the Verified has been enhanced through several training and Carbon Standard), as this would require the development capacity-building activities to ensure sustainability of of a project-specific baseline. However, it appears there the outcomes, including the implementation of the is the possibility of the avoidance of mining impacts benefit-sharing plan, safeguards, and the feedback and being integrated into the GCRFP’s benefit-sharing grievance redress mechanism (GoGH-GFC 2016; Graham plan, which exists and provides for the distribution of 2016). An advanced benefit-sharing plan was developed benefits to farmer groups, traditional authorities, and HIA for the first ERP, and there is significant progress in communities at this point (GoGH-GFC 2020). resolving issues relating to tree tenure with the support from other programs, including the Ghana Forest The circumstances of the ASM activities in the area Investment Program (G-FIP). For example, a law has been would need to be considered (for example, the legal promulgated regarding tree tenure. Multiple stakeholder circumstances) along with the extent that the carbon REDD+ management arrangements were established, benefit that could create. With Ghana experiencing including engagement, stakeholder consultation, and artisanal mining in some of its forested areas, REDD+ has communication platforms (Graham 2016). Ghana has to consider how this driver of deforestation and forest signed an Emission Reductions Payment Agreement degradation can be addressed. The miners’ capacity to with the Forest Carbon Partnership Facility (FCPF) Carbon engage on carbon will need to be built. Fund (FCPF 2019a). In this case, as the pilot site—the Key Empire Resources A GIS analysis (Figure 4.11) was performed by combining site—is only 25 acres, the initiative to integrate FS data on tree cover, forest loss, and intact landscapes from ASM into the ERP would need to involve the collective the Global Forest Watch, data on protected areas from engagement of the miners in the area. the World Database on Protected Areas, and selected geographic features (water bodies, roads, populated sites) from Open Street Map with the pilot site location. The pilot site is located close to the protected areas Atewa Range and Esukawkaw. No areas identified as intact forest landscapes exist near the pilot site. The assessment of the area of study reveals extensive deforestation has occurred over the last 20 years. Forest loss in the vicinity of the mine site (along the river), as visible in Figure 4.11, can be mainly attributed to active or abandoned mine sites (see inset in Figure 4.10 for ground truthing). In non-mineralized areas, deforestation is supposedly related mainly to agriculture and wood removal. There appears to be no significant difference 50 FOREST-SMART MINING - ASM Figure 4.11: GIS Analysis of Forest Resources and Deforestation in the Proximity of the Ghanaian FS ASM Pilot Site and Its Buffer Areas (2 km, 5 km) Source: Global Forest Change 2000-2019 Data Download (accessed September 30, 2020) and Intact Forest Landscapes 2016 (accessed October 14, 2021), Global Forest Watch, University of Maryland, https://data.globalforestwatch.org; World Database on Protected Areas, Protected Planet (accessed October 14, 2021), https://protectedplanet.net; Open Street Map. FOREST-SMART MINING - ASM 51 Outcome of Stakeholder Consultations at first. Although legal mines are no longer targeted, this militarization generates a culture that does not Stakeholder consultation reached out to the Minerals align with the conditions necessary for forest-smartness Commission, Water Resources Commission, Obeng (e.g. participation, inclusion, respect for human rights, Mining Group, and Ghana Women in Mining. etc.), and could pose a barrier to the implementation of forest-smart mining in the sector. FSM implementation will need to demonstrate how it can work as a strong The outcome of the consultations indicates that the innovation tool in achieving better governance and consulted draft version of the standard fits into the local ensure the collaboration between traditional authorities, ASM context and the compliance criteria are feasible. alternative job creation, innovative law enforcement that will address issues of corruption, and political While the stakeholder feedback did suggest any major interference. revisions to the draft standards, the various stakeholders unanimously highlighted that consistent stakeholder With an estimated 85 percent of artisanal and small- engagement throughout the pilot, education, training scale miners in Ghana operating in the informal sector, of regulatory bodies, advocacy, sensitization on the measures should be put in place to promote formalization standard and guidance, and support to mines will be of the sector. It has been revealed that to address the imperative for the overall success of the pilot and beyond. environmental challenges of ASM, the activities of the sector must be regulated. Although the law provides for Generally, stakeholders are of the view that the draft the regularization of the sector in Ghana, ASM activities standard and its requirement are feasible and with largely remain outside the law. Improvements in the relatively low complexity levels for compliance in regulation of the ASM sector and mainstreaming of comparison to other ASM standards. activities within it are therefore required. Stakeholders are looking forward to the final version of the The absence of regularization in Ghana’s ASM sector is standard and active participation in the implementation the main cause of the environmental challenges since of the pilot and subsequent upscale nationwide. regulators have little ability to influence environmental performance, leading to proliferation of abandoned pits Recommendations on ASM and REDD+ and pollution of water bodies, among others (Aubynn Regulations et al. 2010; ACET 2015). Regularization of ASM activities will start, however, with their formalization. The issue of The country’s national regulations and institutions legalization or regularization and its attendant change present a good framework to plan and implement FSM. in the ASM setting brings into critical focus the need for These are robust enough to incentivize FSM. However, government to pay attention to formalization as a first enforcement of the laws has always been challenging. In step to legalization and regularization. the wake of increasing youth unemployment and access to Chinese technology that facilitates mining at scales Measures such as decentralizing ASM licensing to the that go beyond known traditional practices for small- district level and educating mining communities on the scale mining, the context of any responsible mining ASM licensing procedure should also be undertaken. would have to be based on very innovative project phase There should also be more effort from government to interventions that seek to address the major underlying promote the sector. The Minerals and Mining Policy drivers of irresponsible mining. for instance has strategies to promote responsible and sustainable ASM mining; however, the challenge is The youth in most rural landscapes are abandoning government’s commitment to implement such policies. agriculture. Institutional failure and political will to enforce laws and avoid political interference in mining- The current REDD+ strategy identifies mining as a major related law enforcement will be among the major driver of deforestation, but it has not come out with a governance issues to address. Invariably, the most critical deliberate strategy to address it. The REDD+ interventions component to promote FSM will be not technology or are in cocoa, shea, and mangroves landscapes. The capacity but an elaborate discussion and implementation piloting of FS ASM by this project will help propose of governance-related issues that will compel miners intervention strategies to be explored under REDD+ in to stick to best practices. The mining sector has been to address ASM landscape challenges. heavily militarized in response to persistent violations of forestry and mining laws. The uncoordinated nature of Ecuador, by Theodora Panayides, Levin Sources militarization meant that legal mines were also targeted 52 FOREST-SMART MINING - ASM Road Map, Budgeted Workplan, and Funding duration of 2–3 years, covering various annual vegetation Opportunities cycles and thus allowing validation of the expected forest outcomes. A road map, budgeted workplan, and an exploratory analysis of potential funding opportunities for piloting While a number of activities are required for the the FS-ASM Standard in Ghana is contained in the implementation of the pilot, the sequence and timely separate Annex 4: Feasibility Assessment of Piloting FS implementation of some activities are critical to the ASM in Ghana. Such a project should have a minimum overall success of the pilot (Figure 4.12). Figure 4.12: Sequence of Major Activities, Ghana SIGNING OF KEY STAKEHOLDER TRAINING AND TECHNICAL MOU WITH ASM SENSITIZATION ON DEVELOPMENT SUPPORT & GUIDANCE OF RECORDS ENTITY FS-ASM STANDARD TO ASM ENTITY TEMPLATES • Commitment • Trust building, • ASM • Full by ASM Entity buy-in and capacitated compliance commitment of to implement with FS-ASM stakeholders FS-ASM Standard EXTENSIVE STAKEHOLDER CONSULTATION ON ASM ERP ERP developed for ASM Note: ASM = artisanal and small-scale mining; ERP = emission reductions program; FS = forest-smart; MOU = memorandum of understanding. The gap assessment conducted at the Key Empire site shows that it is feasible to implement the FS-ASM Standard there, but the ASM entity does not have the capacity to implement it without external support. In this regard, the miners will be trained and provided with the necessary tools for them to be able to meet the requirements of the FS-ASM Standard. The training will involve training of trainers for lead miners, who will then also train the workers of adjacent mines, taking a landscape approach with outreach beyond the 25 acres of the Key Empire mining lease. 4.2.5 Liberia The full Liberia Feasibility Assessment is contained in the separate Annex 5: Feasibility Assessment of Piloting FS ASM in Liberia. Pilot Site The pilot site selected for Liberia is the Weasua Community in the Gbarma District, Gbarpolu County. The Weasua Community consists of Weasua Town and 16 satellite villages (the majority are camps) where people FOREST-SMART MINING - ASM 53 do mining. Ten of the satellite villages are not accessible Reportedly, there are more than 20 existing pits, including by car or motorbike. It is an 80-minute motorbike drive the illicit ones. to the farthest satellite village, called “City in the Forest,” from Weasua Town. Diamond mining is done manually, in open pits, with stone washing carried out on site, inside the pit. Miners Miners are organized in the Weasua Clan Mining usually start digging at the center of a mine using shovels & Agricultural Cooperative Society (WECMACOS). and then expand the digging area. Organic materials WECMACOS is the only mining cooperative in Liberia are left or piled up at mine sites. Rain or groundwater that was organized and received the full-fledged accumulates in the pit and forms a manmade pond. status (in August 2021) after the Ministry of Mines and Small motor pumps are used to keep the pits dry, and Energy developed the road map to formalize the ASM the miners do not care where the water goes so long as sector.10 WECMACOS is not operating mines as an entity; it is outside the pit. As Figure 4.13 indicates, after they miners who are the members of the cooperative work pile up enough gravel, miners wash it in the manmade individually on their mines. They have the knowledge pond using a sieve to find diamonds. Once a mine is and experience to operate diamond mines. considered mined out, the miners go farther along the trail or off the trail to find a new mine site. Miners say that It is estimated that diamond mines exist along the there are more than 50 abandoned mines in the Weasua trails and along the Lofa River within an area about 15 Community land. kilometers by 15 kilometers in the Weasua Community. Figure 4.13: Diamond Mine Pits in the Weasua Community Area, Liberia 10 Some mining cooperatives were formed before the road map was developed, but they do not function properly as cooperatives. Some work like a private company and others are dormant according to the Cooperative Development Agency. Therefore, WECMACOS is the only diamond ASM mineral producer in Liberia currently working in line with the Ministry of Mines and Energy’s policy. 54 FOREST-SMART MINING - ASM Source: (left and right) © Diamonds for Peace. Gap Assessment environmental degradation but of the lack of funds to obtain equipment. Requirement B.5.2.5.6 (nursery for Although Weasua is one of the oldest diamond mining target seedling production) was also considered in communities in Liberia and surrounded by forests, progress. WECMACOS’s knowledge on environmental protection or the importance and benefits of protecting the forests Most likely the miners underestimate the complexity was found to be minimal. of implementing the FS-ASM Standard—even more so since the standard is intended to be implemented as a However, community miners, probably due to the bolt-on standard in combination with other applicable diversified rural economy—WECMACOS is a mixed ASM standards, which adds complexity. mining and agricultural cooperative—enthusiastically expressed their willingness to learn and implement the The following steps to close the gaps were identified and standard’s PCI. In the gap analysis, miners attributed a proposed by the local support organization, Diamonds high priority to all topics of the standard but assessed the for Peace: complexity of their implementation on average as low to medium. This is in stark contrast to the fact that all criteria 1. Raising awareness about FSM PCI among except two were marked as “no progress.” national-level stakeholders. It is necessary to provide them with information on FSM PCI and some The miners are considered to be in conformance with major international guidelines/schemes/certification requirement B.5.2.1.8 on unnecessary extension of the systems to be used and benefits and incentives mining activities into forest habitats because they mine to implement the pilot in the country so that the manually without use of heavy earthmoving equipment. national-level stakeholders have shared knowledge However, that fact is a result not of their efforts to avoid and avoid future confusion. FOREST-SMART MINING - ASM 55 2. Raising awareness about FSM PCI targeting the Forest Carbon Assessment ASM entity and local stakeholders. It is necessary to raise the ASM entity’s and local stakeholders’ Liberia has made significant progress in REDD+ readiness awareness before starting important components of given it is a poor country with minimal resources. It the pilot so that everyone has a basic idea of what has a REDD+ strategy and has submitted an FREL to will be done in the pilot site and avoid future big the UNFCCC, and the NFMS is complete (Liberia has a confusion. forest definition). It also has an operational safeguard information system.11 3. Stakeholder engagement. Once the ASM mineral producer and the local stakeholders have the basic MRV sits within the REDD+ Implementation Unit (RIU), idea, they are ready to have more detailed discussions which is part of the Forest Development Authority, which and engage themselves. also contains the Liberia Institute of Statistics and Geo- information (LISGIS). Therefore, Liberia has institutions for 4. Developing and convening technical trainings. MRV, but capacity in the country is limited. Technical training needs to include components on diamond and gold mining and action plan Liberia has a National Response Strategy on Climate development (planning of the ASM mineral Change and a REDD+ action plan. The Environmental producer’s mining activities with the knowledge Protection Agency is the national designated authority on and skills miners gain). Such training material should climate change matters, while the Forest Development be developed by the standard setter, to be used in Authority is responsible for all forest-related matters. multiple countries. It can then be adjusted to the local context, if necessary, before convening the The Land Rights Act provides a good basis for under- training in Liberia. standing land ownership and tenure in Liberia. However, certain aspects of ownership are still unclear; for example, 5. Monitoring the activities. The ASM entity needs the act is not clear on who owns proposed protected more detailed planning and preparation before areas. A current survey of customary rights is under starting a new mining project. This needs to be way. Furthermore, ownership of carbon is unclear, but monitored during its planning, preparation, and it is likely to sit with landowners. Liberia does not have implementation. a finalized benefit-sharing system for REDD+ or rules on nesting or the international sale of emission reductions. 6. Improving/taking necessary measures based Liberia’s REDD+ strategy notes that Liberia is “taking a on monitoring results. Based on the monitoring ‘nested’ approach to REDD+, meaning that interventions results, the local support organization will give are taken at a sub-national level and are fitted within a encouragement and technical advice to the ASM national framework for enabling and monitoring REDD+ entity. The local support organization may also need results” (GoLB-FDA 2016). Protection for forests and to convene another training or workshop if the ASM biodiversity within Liberian REDD+ exists but does not entity is weak in a particular area. appear definitive, although this would depend on the project developer. 7. Feedback to national-level stakeholders. After imple-menting all the above, the local support The FCPF website does not indicate whether Liberia organization will compile the results and give is receiving funds from the World Bank’s Carbon Fund. feedback to the national-level stakeholders and Opportunity exists to inform the country REDD+ system discuss the way forward. of forest-smart mining as a REDD+ activity, with a priority in Liberia’s REDD+ strategy being to “Prevent or offset clearance of high carbon stock and high conservation In conclusion, conditions for piloting the FS-ASM value forest in agricultural and mining concessions” Standard at the mining sites of WECMACOS are favorable (GoLB-FDA 2016). and feasible thanks to the enthusiasm of the miners and the local support organization. However, different to A GIS analysis (Figure 4.13) was performed by combining the proposed pilot implementations in Colombia, Peru, data on tree cover, forest loss, and intact landscapes from Ghana, this pilot would be implemented from scratch, as no in-country experience with the implementation of ASM standards exists. This means that greater support would be necessary from the coordinator of the pilots. 11 Liberia REDD+ Safeguards Information System (website), accessed October 1, 2020, https://liberia-redd-sis.info. 56 FOREST-SMART MINING - ASM the Global Forest Watch, data on protected areas from images publicly available from Google and ESRI. For the the World Database on Protected Areas, and selected pilot site location, 2-kilometer and 5-kilometer buffer geographic features (water bodies, populated sites) areas are indicated. The pilot site is located near intact from Open Street Map with the pilot site location. The forest landscapes and close to the Gola Forest National pilot site location was plotted based on location data of Park. visited pits and further clearly identifiable pits on satellite Figure 4.14: GIS Analysis of Forest Resources and Deforestation in the Proximity of the Liberian FS ASM Pilot Site and Its Buffer Areas (2 km, 5 km) Source: Global Forest Change 2000-2019 Data Download (accessed September 30, 2020) and Intact Forest Landscapes 2016 (accessed October 14, 2021), Global Forest Watch, University of Maryland, https://data.globalforestwatch.org; World Database on Protected Areas, Protected Planet (accessed October 14, 2021), https://protectedplanet.net; Open Street Map. FOREST-SMART MINING - ASM 57 The assessment of the area of study reveals that extensive of the comment is however now addressed in the final deforestation has occurred over the last 20 years. Forest version of the standard, by a revised wording that closes loss visible in Figure 4.14 can be partly attributed to potential loopholes for ASM in protected areas. active or abandoned mine sites, but larger areas of loss appear to be related to agriculture. This suggests that a The partly different perspectives and interpretations significant carbon benefit could be generated through highlight the need to create a common understanding, project activities, but it appears that this would be in as suggested above on gaps to be closed. the broader landscape through limiting the impacts of agriculture as well as mining and through the restoration Feedback on the PCI for ASM entities was almost of cleared areas. The REDD+ voluntary activity causing unanimously positive, assessing all requirements as the emission reductions/removals could be the feasible and in line with Liberian regulation. Generally, implementation of an FS–environmental management stakeholders are of the view that the draft standard and plan in the landscape encompassing direct and indirect its requirement are feasible. nonmining impacts as well as mining impacts. Recommendations on ASM and REDD+ A more in-depth feasibility study could assess whether Regulations this would be viable as part of a voluntary project under a voluntary standard (for example, the Verified The in-country assessment has two general recomme- Carbon Standard). Any planned initiative would need ndations: to consider customary and statutory land rights in the • Early start of awareness messaging and engagement. area, and capacity building and technical support would There is currently a very polarized view of forestry and be required to implement an initiative. Also, it would artisanal mining activities in Liberia. In forestry, it is need to be confirmed that a suitable methodology for large-scale commercial logging versus conservation a project where mining is a driver is available under a and protected areas. This has led to most thoughts voluntary standard such as the VCS (or one would need of commercial logging as a deforestation driver to be developed, which is very time-consuming). (replanting is rarely done); therefore, having artisanal mining also under way in forests already Otherwise, the avoidance of smaller mining impacts being “degraded” by commercial logging will be a might be able to be integrated into the country’s REDD+ difficult public perception to overcome. Similarly, benefit-sharing system that could distribute payments as a significant amount of ongoing artisanal mining for results in the broader landscape. However, as this in rural, forested areas is unlicensed with little to no type of system does not yet exist in Liberia, and as the regulatory monitoring, it may be difficult to convince site does not sit within an initiative or jurisdiction that regulators and the public to accept the environmental is successfully attracting carbon finance, it is suggested degradation associated with artisanal mining activity. that this would only be a possibility in the somewhat It is therefore imperative to ensure the messaging is distant future. clear that forest-smart mining is not promoting ASM in protected areas, because the government has had Outcome of Stakeholder Consultations a difficult experience removing illicit artisanal miners who have previously been pervasive in several key Stakeholder consultation involved outreach to the protected national parks across Liberia. Ministry of Mines and Energy, Forestry Development Agency, the United Nations Development Programme • Strengthened ASM licensing and monitoring. While office, Society for Conservation of Nature in Liberia, and key regulators may be accepting the FSM concept, the NGO Green Advocate. no published and established guidelines currently exist on how ASM is expected to be conducted for regulatory compliance. Having clearly established Feedback from the stakeholder consultation on regulatory expectations for compliance will provide intent and scope of the draft version of the standard much needed guidance on how ASM activities can was not unanimous, with replies reflecting different realistically be developed within forests and alongside perspectives and interpretations, but in the majority, forest resources in a responsible manner. feedback was positive except on aspects related to the rights of Indigenous Peoples within protected areas in Specific recommendations include the following: the geographic scope. Suggestions to limit Indigenous Peoples’ rights have not been adopted by the authors, • Develop mining regulations. None currently exist, as this is not aligned with principle 2 of the standard, so this will require detailing regulations for all sizes of Credit: which A. Cooke takes a human rights–based approach. The intent operations, including ASM. 58 FOREST-SMART MINING - ASM • Any ASM regulations to be developed should offer • Good practices of voluntary carbon financing projects pathways for safe and efficient mineral recovery in Liberia and in other mineral-producing countries and enable some level of equipment use and need to be collected. Given that no methodology mechanization. exists for incorporating ASM into carbon finance, it needs to be explored if possibilities exist under • Develop guidance notes for how licensed artisanal voluntary carbon standards such as VCS, or whether mining can be conducted in forested areas, providing avoidance of impacts by ASM could be integrated clarity on all authorizations required from community into the country’s REDD+ benefit-sharing system. This to regulatory levels and considering the various forms can draw on lessons learned from other sectors, such of legality of forests, such as authorized community as smallholder farmers. forests, forested communally owned lands, and so on. Road Map, Budgeted Workplan, and Funding • Ensure inspection procedures that are responsive Opportunities to access in difficult terrain in remote forested areas where artisanal mining activity is also undertaken. A road map (summarized in Figure 4.15), a budgeted The lack of convenient road networks in many areas workplan, and an exploratory analysis of potential where natural resources are located is often the funding opportunities for piloting the FS-ASM Standard leading challenge regulators mention regarding their in Liberia is contained in the separate Annex 5: Feasibility ability to maintain routine monitoring schedules for Assessment of Piloting FS ASM in Liberia. such sites. Figure 4.15: Sequence of Major Activities, Liberia National-level Developing stakeholders’ technical training awareness raised The AMP and local The AMP receives stakeholders’ technical training awareness raised Stakeholder The AMP’s National-level engagement knowledge & skills stakeholders are on FSM improved aware of the results The AMP plans and implement mining and The AMP satisfies The AMP & local associated FSM activities the minimal criteria stakeholders are using the obtained skills of FSM PCIs aware of the results Monitoring, technical assistance to the AMP for improvement and continuous practice Note: AMP = artisanal and small-scale mining mineral producer; FSM = forest-smart mining; PCI = principles, criteria, and indicators. Such a project should have a minimum duration of 2–3 years, covering various annual vegetation cycles and thus allowing validation of the expected forest outcomes. Credit: A. Cooke FOREST-SMART MINING - ASM 59 5. PARTNERSHIP, LEVERAGE, AND FUNDING OPPORTUNITIES A number of potential entry points exist for partnership The NYDF Global Platform is looking to provide and collaboration to influence on forest-smart mining tailored implementation guidance to NYDF (FSM) in artisanal and small-scale mining (ASM) supply endorsers, that is, national governments, companies, chains, through the implementation of the Forest-Smart and nongovernmental organizations (NGOs). The FS- Artisanal and Small-Scale Mining (FS ASM) Standard ASM Standard could be part of the implementation and beyond. Decisions about which stakeholders are guidance tailored specifically to ASM entities as part more appropriate to engage with and at what stage will of goals 3, 4, and 7. Moreover, the NYDF Platform is depend on strategic priorities, budget availability, and planning to host regional multistakeholder events policy choices. Annex 1 section C.5 outlines concrete on global forest action, one or more of which could financing support systems for FSM. feature one of the pilot sites2. • With funding from the German government, 5.1 Partnership and Leverages the Organisation for Economic Co-operation and Development (OECD) has commissioned Some global processes offer opportunities for engage- Levin Sources to design a Practical Actions for ment to accelerate the adoption of the FS-ASM Standard Environmental Due Diligence Tool that will support and to seed exploration of additional pilots in different businesses along minerals value chains to source sites and countries. These opportunities include the responsibly in ways that mitigate environmental risks. following: There is scope to ensure that this tool aligns with and references the FS-ASM Standard, to raise awareness • The New York Declaration on Forests (NYDF) Progress among downstream actors of the standard and how Assessment Click or tap here to enter text.completed its deployment in their supply chains could support its review of goals 3 and 4 in 2020, and goal 7 in achievement of their responsible sourcing and 20211. These goals seek to reduce deforestation decarbonization strategies3. from infrastructure and extractive industries, support alternative livelihoods (which includes ASM), and • The Environmental Governance Programme (EGP) reduce emissions from deforestation and forest and Forest Team of the United Nations Development degradation in accordance with global climate Programme (UNDP) are convening a series of agreements. From 2022, the NYDF assessments will dialogues on mining and forests to design and be fully integrated within the NYDF Global Platform, implement a program of work during 2022–2023 with the initiatives’ combined efforts focused clearly that will assist EGP countries (Argentina, Colombia, on implementation and recognizing the importance Ecuador, Kenya, Kyrgyz Republic, Liberia, Mongolia, of accountability, especially as the number of countries Namibia, Peru, and Zambia) to improve governance committing to ending deforestation drastically increased of mining/forest interactions. This is being done with the recent (2021) Glasgow Leaders’ Declaration in partnership with the New York Declaration on on Forests and Land Use. They will also be taking a Forests and the Wildlife Conservation Society. There is regional approach to future assessments, including opportunity for the World Bank to coordinate with the building regional networks of endorsers to advance UNDP to ascertain the following: achievement of the goals. 1 “What Is the NYDF Progress Assessment?” New York Declaration on Forests, accessed December 15, 2021, https://forestdeclaration.org/about/nydf-progress-assessment. 2 Text verified by Erin Matson and Madeline Craig, November 16, 2021. 3 Text verified by Sophia Gnych, OECD, November 15, 2021. 60 FOREST-SMART MINING - ASM »» If/how the UNDP country offices could engage - LandScale allows users to measure in and support implementation of the FS ASM progress in the overall sustainability of a pilots. landscape over time. It includes indicators to measure deforestation, soil health, labor »» If/how UNDP may want to ultimately convene or rights, governance, water, and more, and manage the coordination of the various FS ASM it is possible to add additional indicators pilots (including outside of EGP countries) in (such as those in the FS-ASM Standard). No partnership with or on behalf of the World Bank. carbon asset or claim arises from using this standard. LandScale can be combined with a jurisdictional REDD+ scheme. An FS ASM »» If/how UNDP might help the World Bank raise initiative could sit within the landscape or funds for the pilots designed by this project. LandScale/jurisdictional REDD+ framework. »» Whether the program of work that emerges from »» There may also be an opportunity to design a the UNDP dialogues would include additional carbon accounting methodology for FS-ASM’s pilots of FS ASM in new sites and new countries. impacts in terms of avoiding deforestation, Furthermore, the World Bank could participate forest degradation, and perhaps for integrating in the dialogue series as a stakeholder to build restoration into an FS ASM carbon project and a strategic understanding of what opportunities have this approved by Verra. Conceivably, an for partnership exist⁴. existing methodology could be adapted for FS ASM. It would be important to understand • Verra is a standard-setting body that helps channel what existing Verified Carbon Standard (VCS) finance toward some of the world’s most pressing project methodologies (the basis of the carbon environmental challenges⁵. Verra has expressed accounting for projects implemented) are an interest in being engaged by the World Bank applicable to FS ASM and what methodologies once the standard is developed to pursue a couple might need to be developed to implement of opportunities that could help make their own such projects. Then methodology development standards more applicable to ASM⁶. could be undertaken if required. If adapting a methodology, the methodology designer »» There is opportunity to integrate the FS-ASM would submit a concept note to Verra for review Standard into two Verra standards: SD VISta, of the proposed revisions to the existing Verra which certifies at the project level, and LandScale, methodology, Verra would give acceptance or which verifies the assessment of a landscape at not, then the designer would make the revisions the landscape level⁷. before further review and external validation/ verification. - Under SD VISta, it is not possible to produce a tradable carbon asset, but it is possible »» Verra is considering developing a supply chain to produce a measurable carbon claim (for intervention program (often referred to as example, the ASM entity has contributed insetting). This program could use and adapt the toward the host country’s net zero targets) carbon accounting methodologies that already or a measurable sustainable development exist as part of the VCS to quantify interventions. or human rights claim (for example, the ASM Verra sees benefit in engaging with FS ASM. It entity or its funder can make a quantifiable is possible that the standard’s principles, criteria, claim about how it has reduced human and indicators (PCI) could be used as the basis rights impacts or biodiversity impacts, or for the development of a carbon accounting is supporting achievement of the United methodology for FS-ASM’s impacts in terms of Nations Sustainable Development Goals avoiding deforestation, forest degradation, and through application of the FS-ASM Standard), restoration (see the previous bullet point). An and have it assured⁸. FS ASM initiative could be a working case study 4 Text verified by Ann Cathrin Pedersen, UNDP, November 6, 2021. 5 “Who We Are,” Verra, accessed November 11, 2021, https://verra.org/about-verra/who-we-are/. 6 Naomi Swickard, Verra, Interview with Estelle Levin-Nally and Chris Smith, May 6, 2021. 7 Naomi Swickard, Verra, May 6, 2021. 8 Naomi Swickard, Verra, May 6, 2021. FOREST-SMART MINING - ASM 61 for a possible insetting pilot, with Verra aiming Gold’s complementary project, Women of Peace, to build the program on the basis of rigorous women in ASM communities, including Indigenous carbon accounting and evidence-led design⁹. women in Ituri’s equatorial forest, carried out conflict- resolution activities related to mining, with an • The United States Agency for International emphasis on issues that created or sustained gender- Development (USAID) Zahabu Safi (Clean Gold) based insecurity in the community. Members of the Project is a five-year program to build commercially Network for the Empowerment of Women in Mining viable responsible gold supply chains from the Communities (REAFECOM) were also supported to eastern Democratic Republic of Congo. The project more actively and effectively participate in natural currently works with four cooperatives in the resource governance mechanisms using a rights- provinces of Ituri, Maniema, and South Kivu, where based approach11. existing forest is under threat. It is helping the cooperatives to mitigate human rights risks and build • Regeneration, a RESOLVE initiative with first funder viable cooperative businesses, in line with the OECD Rio Tinto, was established to finance ecological and Due Diligence Guidance (DDG), in order to access economic regeneration through remining legacy responsible downstream markets. The Zahabu Safi tailings and waste rock and processing water. While (Clean Gold) Project conducted market assessments the priority for this initiative is regeneration at legacy in 2019, 2020, and 2021 to understand the sourcing large-scale mines, there will also be attention to ASM, needs and priorities of refiners and jewelers and building on the work already initiated by RESOLVE is working with communities in each sector to through Salmon Gold (in Alaska, the Yukon, and facilitate relationships that result in self-sustaining British Columbia) and its land reclamation program responsible supply chains. Addressing environmental in Sierra Leone. This includes a program of work that risk is becoming more of a necessity for buyers scopes, identifies, prioritizes, and develops projects because legislation (especially in Europe) and their either restoring legacy ASM sites or restoring legacy customers are increasingly demanding greater large-scale mining sites with ASM labor12. environmental responsibility in supply chains. So, there is a confluence of opportunity: The Zahabu Safi (Clean Gold) Project has entered its fourth year and is 5.2 Funding now close to supporting the ongoing export of gold mined in one of the world’s most important forest 5.2.1 Philanthropic Foundations biomes. Relationships with downstream partners are deepening, leading to greater understanding of their Philanthropic foundations can act as amplifiers and needs. The project could use its existing relationships provide financial resources to enhance the uptake of and understanding to scope whether it could finance the FS-ASM Standard. There are three key foundations to the design of a road map, budget, and workplan for engage: The Ford Foundation, the Forest Conservation a pilot in eastern Democratic Republic of Congo. Fund, and the Climate and Land Use Alliance. The objective would be to allow others to build on the project’s learning and its progress in establishing The Ford Foundation seeks to reduce poverty and enduring supply chains by raising funds to implement injustice, promote international cooperation, advance such FS ASM pilots with interested cooperatives10. human achievement, and strengthen democratic values. In 2020, the Ford Foundation commissioned a study • The Canadian NGO Impact has expressed an interest to analyze the institutional landscape of international in piloting the FS-ASM Standard in Ituri, Democratic initiatives working to address the negative impacts of Republic of Congo, or in Côte d’Ivoire, where it has mining in forests. This study informed the development many years of experience supporting artisanal and of a new program. Given the foundation’s historic interest small-scale miners to access responsible markets in FSM, it would be sensitive and prudent to share the through the introduction of responsible business FS-ASM Standard and engage them in conversations on conduct and formalization as well as to implement how to build a program to facilitate the uptake of the environmental risk mitigation and remediation standard. strategies as part of its Just Gold Project. Via Just 9 Text verified by Candace Vinke, Verra, June 9, 2021; and Naomi Swickard, Verra, December 3, 2021. 10 Text verified by Nikki Duncan, Global Communities, November 24, 2021. 11 Text verified by Joanne Lebert, Impact, December 15, 2021. 12 Text verified by Stephen D’Esposito, Regeneration, November 12, 2021. 62 FOREST-SMART MINING - ASM The Forest Conservation Fund aims at decentralizing strategy and is now looking to deploy its impact conservation by empowering local communities and investment capital in service of regional and global private sector actors to protect forest under their control. climate goals. There is the potential for the fund to run conservation projects in mining concessions and ASM sites; thus, they 5.2.2 Public Funders could support piloting FS ASM. Public funders can act as amplifiers, provide human or The Climate and Land Use Alliance (CLUA) seeks to financial capital, and engage relevant actors to enhance realize the potential of forests and land use to mitigate the uptake of the FS-ASM Standard. Some key public climate change and protect the environment. The funders to engage include the following: alliance financially supports efforts in Brazil, Indonesia, Mexico, and Central America, and at the global level it The Global Environment Facility (GEF) through supports international public and private sector policies, planetGOLD seeks to improve environmental programs, and finance that help conserve forests and management of artisanal and small-scale gold mining land. The uptake and support for FSM could be enhanced operations. Although it currently focuses on mercury and with the alliance’s funding. waste management, the program has developed criteria to include environmental commitments. The uptake and Other funds and foundations to engage with include the support for FSM could be enhanced with GEF funding. following: • The Cartier Foundation, and more concretely Cartier The United Nations Development Programme is for Nature, which focuses on forests’ preservation, currently leading a forests and mining dialogues series the restoration of ecosystems, solutions for the that will lead to a program of work on the interactions preservation of natural resources and decreased between mining and forests in up to nine countries carbon emissions, and relief for environmental involved in their Extractives and Governance Programme. emergencies. There is the potential to enhance FSM with the program of work currently being developed. • The Lion’s Share Fund strives to halt biodiversity loss and protect natural forests. The Organisation for Economic Co-operation and Development has significant influence over the • The Tany Meva Foundation—and more concretely international policy arena for minerals. The recent launch its conservation and climate change themes—seeks of the OECD Tool on Environmental Due Diligence in to manage and restore existing protected areas, Key Mineral Supply Chains presents an opportunity for Biodiversity Areas, and other territories, as well as amplifying FSM. support innovations and applied research for climate change mitigation and adaptation. The Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) is • The Good Energies Foundation seeks to reverse committed to leveraging mining for sustainable develo- climate change and mitigate poverty. pment while ensuring that the environmental and social impacts are managed. It is interested in supporting with human resources the uptake of FSM by creating a • The Sigrid Rausing Trust promotes human rights and guideline to manage ASM occurring in Key Biodiversity the preservation of nature from further degradation. Areas. • The David and Lucile Packard Foundation, and It is crucial to further engage the China Chamber more concretely their climate change theme. of Commerce of Metals Minerals & Chemicals Importers & Exporters (CCCMC) because China plays • The George & Betty Moore Foundation seeks to a key role in consumer, manufacturing, and midpoint of create positive outcomes for future generations, global mineral supply chains. The CCCMC is interested focusing on four themes, one of which includes in enhancing FSM, and the FS-ASM Standard could be environmental conservation. included in their existing guidance documents. • The Soros Open Society Foundation, and more Other public funders to potentially engage include the concretely the Soros Economic Development Fund, German Agency for International Cooperation (GIZ), which has recently developed a Climate Justice UN Decade of Ecosystem Restoration, Inter-American FOREST-SMART MINING - ASM 63 Development Bank (IDB), African Development Bank Furthermore, in light of momentum post-CoP26, large (AfDB), Canadian International Resources and Deve- corporations will be augmenting their climate and lopment Institute (CIRDI), New York Declaration on biodiversity ambitions. Many downstream companies Forests (NYDF), United Nations Environment Programme, will start to more seriously consider how to handle Scope European Commission, Federal Institute for Geosciences 3 emissions and impacts and explore insetting as an and Natural Resources (BGR), and Foreign Commonwealth opportunity. Some may even start to explore remedying and Development Office (FCDO), among others. past impacts in their supply chains by supporting restoration projects in damaged landscapes. Key sectors Moreover, an FS ASM green bond or climate-smart to target in this respect include jewelry, electronics and mining green bond could be also considered for ICT, construction, and automotive companies. Equally, financing FS ASM projects. Multilateral issuers like the large-scale mining companies facing threats to the social Asian Development Bank, the World Bank, and the license to operate because of the cumulative impacts International Finance Corporation could issue bonds of multiple miners in a landscape may seek to engage to raise debt finance from a diverse set of investors with and support the mitigation of environmental risk by with a priority to protect forests, empower vulnerable artisanal and small-scale miners operating in or around groups, and advance climate change mitigation and their concessions or within their area of interest (from adaptation—for example, institutional investors, an impact mitigation point of view). There is a strong foundations, religious organizations, asset managers, business case for them to minimize the sector’s impacts downstream companies, and so on. Forest-smart ASM overall since the larger mines tend to be more visible, projects for implementation by regional, national, higher profile, and exposed to significant political risk provincial, or local governments, responsible mining should the public or politicians look for a fall guy in the and sourcing programs (including ASM entities that are face of acute or chronic severe environmental impacts. part of existing certification schemes), public-private partnerships, or REDD+ or VCS programs could be 5.2.4 Civil Society candidates to receive this funding (World Bank 2015). Civil society has the power to report, monitor, advocate, 5.2.3 Industry and Multistakeholder and hold governments and companies to account. As Initiatives such, civil society has a large role to play in pushing the agenda of FSM. We recommend engaging civil Industry and multistakeholder initiatives are key targets society to amplify and raise awareness about the FS- for the integration of FSM standards, but they may ASM Standard. This is crucial to buy in the acceptance also be able to support access to funding and piloting of civil society members who will ultimately demand of FS ASM in their sites and can also act as amplifiers products compliant with the standard’s requirements. and communicators of FSM to their stakeholders and Some standard setters have already pointed out that the members. FS-ASM Standard will only be able to be implemented if buyers demand it and are willing to pay the extra cost for The most important industry-led multistakeholder compliance. initiatives to engage include the International Tin Association, LBMA, Responsible Minerals Initiative, Cobalt Examples of international NGOs to engage include Institute, Tantalum-Niobium International Study Center IISD Forests and Climate Change, International Union (TIC), International Tin Supply Chain Initiative (iTSCi), for Conservation of Nature (IUCN), WWF International, Responsible Jewellery Council (RJC), Impact Facility, BirdLife International and other members of the KBA Drive Sustainability, Global Battery Alliance, Responsible Partnership, planetGOLD, Indigenous Peoples’ Advisory Mineral Development Initiative (RMDI), Responsible Forum (IPAF), Women’s Rights in Mining, CDP, Delve, Mica Initiative, Moyo Gems, European Partnership for Leaf Initiative, Responsible Sourcing Network, African Responsible Minerals, RE-SOURCE project, and Public Investing in Mining, Association of Women in Mining Private Alliance for Responsible Minerals Trade, among Africa (AWIMA), European Forest Institute, Terre des many others. Hommes, Earthworm, Solidaridad, Pact, and Impact, as well as report authors Alliance for Responsible Mining Some of these initiatives have already been engaged as and Fauna & Flora International. part of the Global Advisory Panel and strategy drafting. Ensuring that they stay committed to FSM in the long National and local civil society organizations have crucial term will require further engagement once the project roles to play, coming to the fore in the design and finalizes. delivery of the pilots and strategizing how to scale within target countries. 64 FOREST-SMART MINING - ASM 5.2.5 Carbon Finance VCS/Climate, Community, and Biodiversity Standards [CCBS]), complying with national requirements in the The most likely ways that FS ASM will obtain carbon broader landscape through limiting other impacts as finance will be for the ASM entity to integrate its FS ASM well as mining impacts and through restoration of project into an existing landscape-scale carbon initiative cleared areas. Look to finance initially through grant or to develop a voluntary project within the landscape funders/specialist developers seeking a return or to that could then attract voluntary funding, in certain make a specific impact; market credits in national instances compliance funding, and perhaps a share of compliance market/the international voluntary results-based payments made to the broader jurisdiction market. for reducing emissions. Such voluntary projects would likely need to aim toward limiting mining and other • Peru. Investigate whether FS ASM activities could be impacts within the landscape broadly to be viable. They integrated into the country’s REDD+ benefit-sharing could nest with government jurisdictional programs or system; further research could ascertain whether stand alone. the project sits within a broader jurisdiction that is successfully attracting carbon finance. Both the voluntary market and REDD+ country systems can provide finance to initiatives that reduce emissions. • Liberia. Develop a stand-alone/nested project under Projects can be developed for the voluntary carbon a suitable voluntary standard (for example, the VCS/ market using voluntary standards, for example, the CCBS) in the broader landscape through limiting VCS. Emissions reductions are quantified and certified other impacts as well as mining impacts and through under such standards and can be sold on the voluntary restoration of cleared areas. Look to finance initially market. Country REDD+ programs develop their own through grant funders/specialist developers seeking rules within the United Nations framework but can allow a return or to make a specific impact; market credits the development of projects that can attract their own in the international voluntary market. finance under voluntary standards to nest within their jurisdictions. Also, countries can provide for a share of the • Ghana. Integrate FS ASM activities into an existing payments they receive for emissions reductions achieved government emission reductions program; it appears within their program areas to go to stakeholders/project there is the possibility of the avoidance of mining developers contributing to emission reductions within impacts being integrated into the Ghana Cocoa those landscapes under benefit-sharing schemes. REDD+ Forest Program’s benefit-sharing plan that exists and provides for the distribution of benefits to Certain compliance markets will also accept the emission farmer groups, traditional authorities, and hotspot reductions developed under voluntary certifications. intervention area communities (GoGH-GFC 2020). For example, the international Civil Aviation’s Carbon It is understood that the program benefits from an Offsetting and Reduction Scheme for International Emission Reductions Payment Agreement signed Aviation (CORSIA) accepts “Verified Carbon Units (VCUs) with the Forest Carbon Partnership Facility’s Carbon issued to project-level activities under a jurisdictional Fund. programme following Scenario 2 of the VCS Jurisdictional and Nested REDD+ framework” (ICAO 2021). Also, it is Therefore, the general recommendations are as follows: understood that credits from VCS-certified projects that • Together with an organization supporting the miners comply with national requirements can be purchased in on the ground, work with government in certain order in to comply with national carbon tax requirements. instances to integrate into an existing government emission reductions program/benefit-sharing It should be emphasized that the development of scheme; initially, funding could come from grant voluntary projects can be pursued with specialist project funders (public, philanthropic) with an interest in FS developers that can also provide links to offset buyers, ASM, but the aim would be to generate a sustainable and private, public, or philanthropic finance. source of carbon finance for FS ASM through country programs (Ghana, Peru). Different tracks should be pursued in different countries dependent on the circumstance of FS ASM. A summary • Together with an organization supporting the miners of the recommended track in each case study carried out on the ground, work to develop a stand-alone/nested under this project is as follows: voluntary project under a voluntary standard (for example, VCS/CCBS); initially, funding could come • Colombia. Develop a stand-alone/nested project from grant funders with an interest in FS ASM or under a suitable voluntary standard (for example, the specialist providers looking for a return or to make FOREST-SMART MINING - ASM 65 a specific impact; the support organizations and a coordinated program of targeted outputs to achieve specialist developers should engage government to scaled-up adoption of the standard and its supporting nest the project as far as possible; the aim would be capacities. Achieving forest-smart best practices is to generate a sustainable source of carbon finance particularly relevant for technology critical elements for FS ASM through the voluntary carbon market, such as cobalt or tin, which are often extracted in forest or perhaps compliance markets (Colombia) or from landscapes and essential for the transition to the green payments made to the jurisdiction for reducing economy. emissions (Colombia, Liberia). In both countries, there could be the possibility of private finance The institutional sectors for potential funding outlined in from downstream buyers of gold or diamonds with chapters 5.2.1 through 5.2.5 represent opportunities that a sourcing relationship to the site, region, or country can be regarded singularly as specific opportunities, or where the FS ASM project would operate. they can be considered as potential partners in a strategic composite program of collaborative engagements • Development funding, perhaps from a grant, would where key sectors are identified to work together at both initially be needed in Ghana, but it could then come the national and local levels to bring about FSM. from the Forest Carbon Partnership Facility Carbon Fund and, more generally, results-based payments A project successfully implemented at national scale for jurisdictional performance (for example, through in Mongolia during 2013–2017 exemplifies this Emergent in their role as the broker of sales for collaborative cross-sectoral approach: Funded by jurisdictions for the LEAF collation). However, in the Swiss Agency for Development and Cooperation the other instances, grant funders/conservation & (SDC) and The Asia Foundation, the ESEC II Project saw development funds/specialist project developers, the development and demonstration of the Frugal perhaps with a particular interest in mining impacts, Rehabilitation Methodology (FRM) as a key tool for could provide initial funding for development, ASM formalization through a participative process that with a sustainable source of carbon finance for FS engaged government, civil society, and the ASM sector ASM being generated through future credit sales. at all levels (Stacey 2016a, 2016b; Stacey et al. 2018). Credit sales would likely be through the voluntary At the end of this period, through the cooperation of carbon market at this stage, but they could perhaps key government ministries, the FRM was incorporated be through compliance markets (Colombia) or into ASM legislation within the country’s Minerals Law. from results-based payments made to the broader The FRM arising from that process is adaptive and jurisdiction for reducing emissions. Examples of foundational and sits at the core of the FS-ASM Standard project developers are Vertree, South Pole, Everland, developed and adapted to ASM in forested landscapes, Fauna & Flora International, and Conservation through this World Bank FS ASM project. International. Corporations/funds often sit behind such organizations. Relevant sectors and organizations indicated in chapters 5.2.1 through 5.2.5 could take the lead in initiating A more in-depth feasibility study could assess in each and developing a more broadly funded program that instance the viability of suggested initiatives, for example, would address capacity building on key fronts while the development of voluntary projects under a voluntary helping ASM entities take on the FS-ASM Standard standard like the VCS. within an improved, receptive, and supportive legislative environment. 5.2.6 Potential Funding Packaging for Strategic Collaborative Development of FS ASM at Scale The complexity and diversity of attempting to bring about and scale up behavior change toward FS ASM may merit a cross-sectoral, partnership-based, and multilayered approach to funding and designing programs. Such programs need to be designed to help upgrade national legislative frameworks, design appropriate incentives, and deliver training programs for achieving forest-smart best practices at scale. Such an effort would require sufficient resources to design, develop, and implement 66 FOREST-SMART MINING - ASM Source: © Pixabay, Plantar Agricultor Ghana FOREST-SMART MINING - ASM 67 6. GENERAL CONCLUSIONS & RECOMMENDATIONS 6.1 Adoption of FS ASM in Global • Support scaling within the selected pilot countries Processes and seed the development of pilots in new countries through interested partners (for example, Global A number of concrete entry points are available to the Advisory Panel members and other global standard- World Bank and other influencers to support and inspire setter processes, noting existing possibilities in Côte the adoption of the Forest-Smart Artisanal and Small- d’Ivoire, Democratic Republic of Congo, Guyana, and Scale Mining Standard (FS-ASM Standard) in global Sierra Leone); processes. The key recommendations are summarized below. • Coordinate the sharing of lessons between the FS ASM pilots and their stakeholders; Take an intentional curated approach to seeding and scaling adoption of the FS-ASM • Lead the integration of lessons learned from the pilots Standard beyond engaged standard setters into the FS-ASM Standard by 2024; and and pilots (2023/4) • Design and implement a communications plan to expedite the seeding, scaling, and impact of the Having a convenor who could curate, support, and build standard, including publishing the standard and economies of scale across the community of standards, promoting it to relevant audiences. initiatives, and pilots working to adapt and adopt the standard would enhance the likelihood of its adoption. This convenor could Support integration of the bolt-on FS-ASM Standard into processes of other standard setters and initiatives working in responsible • Be responsible for building the FS ASM training mining and sourcing program, guidance, and market and benefits studies (see below); Standard setters and other initiatives need guidance on how to integrate the bolt-on standard into their • Build an inventory of and develop relationships with processes. They would be assisted by efforts to make the existing and prospective pilots of the standard in the business case and facilitate the adoption process. case study countries and elsewhere, as the basis for a strategy for seeding and scaling FS ASM into diverse processes; For making the business case, two major actions are financing a market study and a benefits study. The market study would explore the interest from different • Curate, support, and integrate the existing pilots with stakeholders to obtain FS-ASM conformant material. these other opportunities; Understanding the extent of and basis for interest from mineral buyers and their willingness to support the • Centrally steer and support country collaboration on implementation of the standard by ASM would help forest-smart mining (FSM) seeding and scaling akin to miners and standard setters make an internal case to the planetGOLD model; adopt the FS-ASM Standard. A benefits study could be carried out alongside the implementation of the pilots • Lead engagement with national ministries interested to ascertain the added value (financial, reputational, in adopting or integrating the standard into existing and so on) that FS ASM brings the ASM entities, their regulations, as well as with ASM associations and stakeholders, and any frontier standards incorporating responsible mining/sourcing initiatives; the requirements. This will support standard setters and 68 FOREST-SMART MINING - ASM other initiatives to make the business and impact case for The provision of training to ASM entities, nongovernmental adoption of the FS-ASM Standard into their own systems. organizations (NGOs), and governments on (a) what It would also enhance understanding of incentives for is the carbon and biodiversity finance opportunity for miners to pursue FS ASM. ASM, and how it works, and (b) how to conform to the FS-ASM Standard. This could involve delivery of trainings FS ASM would be expedited if the adoption process was either in person through practical implementation and facilitated by an overall convenor, who would ensure demonstration with selected ASM groups and sites or success and glean lessons learned to evolve the bolt- remotely via an online digital platform or a software app. on standard and inform the development of additional At the outset, physical face-to-face training on site is supporting documents that will fast-track seeding and likely to be far more powerful, effective, and convincing scaling. This would involve (a) working closely with than online digital approaches, which could be regarded standard setters engaged as part of this project to peer as an effective arena for scaling up. review and guide the process of integrating FS ASM into their standard, in alignment with the implementation The resources required for producing an effective, and coordination of the other pilots planned as part of meaningful app for principles, criteria, and indicators (PCI) this project; and (b) carrying out regulatory assessments would not be insignificant, and it would be a challenge of FS ASM readiness of key jurisdictions where standard to ensure the app would deliver sustainable, viable setters or other responsible sourcing would like to pilot outcomes. Therefore, it would be good for the app to be FS ASM, following the methodology used for this project based on a seeding effort of practical demonstration of (as compared to GemFair, United Nations Development forest-smart best practices. Programme, Zahabu Safi, and so on). Efficiencies could be gained by planning this into the Address programmatic gaps to facilitate pilots. For example, there could be a central program for adoption of FS ASM practices by ASM in line designing the overall FS ASM training program, and each with the bolt-on standard of the pilots could have a media workstream integrated into their existing workplans. The global program could Standard setters have identified several areas where they support each pilot with their own training through would need external support. These include concrete centralizing development of some of the materials, guidance and support with training. and it could gather the additional materials each pilot would generate to create a body of open source training materials for publication and redeployment elsewhere. The provision of concrete guidance for miners on how In addition, it would plan and use the pilots to gather to execute each criterion of the FS-ASM Standard could multimedia to use in future trainings—for example, to include developing case studies and examples of how demonstrate implementation of the PCI and progress to conform. For example, the standard says what needs in protecting forest values. These videos and training to be achieved but does not guide miners on the how. materials could be made available through the DELVE A handbook akin to how the Organisation for Economic Exchange in the first instance, “a knowledge exchange Co-operation and Development’s Tool on Environmental network by artisanal and small-scale miners for artisanal Due Diligence in Mineral Supply Chains supports and small-scale miners.” 1 implementation of the OECD Due Diligence Guidance for Responsible Business Conduct could work—for example, directing miners to publicly available guidance There is also a growing opportunity to circumvent the and case studies that already exist to illustrate what a issue of illiteracy among many ASM groups and sites requirement could involve in practice. This would be and take advantage of growing smartphone ownership supported by developing a catalogue or inventory among ASM owners, operators, and workers through of best-practice FSM ASM case studies and tools, and the transfer of some good-practice guidance and years potentially also stand-alone guidance on (a) how to of distilled experience from a written format and into be circular in artisanal and small-scale mining and (b) an augmented reality/mixed reality setting and literally restoration and rehabilitation, perhaps in partnership show management and workers what needs to be done, with United Nations agencies under the banner of the UN Decade of Restoration and building on the Frugal Rehabilitation Methodology (FRM) and the wide set of 1 Daniel Franks, email to Estelle Levin-Nally, October 6, 2021. ASM restoration projects and programs blossoming “The network enables sharing and peer support through around the world just now. WhatsApp groups, online discussions and selected training opportunities. Recognized ASM leaders from six global regions facilitate the network with an international support team.” FOREST-SMART MINING - ASM 69 supplemented by verbal instructions in an appropriate Preparedness of ASM Entities for FS ASM local language. This could in effect create a smartphone Implementation app that could deliver site-specific technical and environmental guidance in a visual form. This app would While piloting the standard in all four countries is show in a visual form the steps necessary to improve considered feasible and recommendable, it is notable performance. This approach is not necessarily about that the ASM entities that already had exposure to ASM developing new content; rather, it is about finding a new standards in the past are better prepared to understand way to augment and supplement the existing training and implement additional topics and requirements pathways. Green Horizon Environmental Consulting has (that is, bolting on the FS-ASM Standard) than miners been exploring a partnership with a major tech firm to for whom even the concept of a standard itself is match fund the development of such an augmented something new. The ASM entities in Colombia and reality/mixed reality setting. Ghana, which had already undergone training toward conformance with the top-level Fairmined Standard, Furthermore, a human rights–based approach would present the highest readiness for adoption of the FS-ASM support targeting vulnerable groups in this training. For Standard. The ASM entity in Peru demonstrated a good example, the Association of Women in Mining Africa understanding of standard concepts because several could be capacitated to train women miners in why other ASM operations in the department of Puno are and how to do FS ASM and environmental monitoring, already certified by Fairmined or Fairtrade and share their and the Amerindian Peoples Association could train experience with their peers. The ASM entity in Liberia, Indigenous miners in the same. where no ASM standard initiatives have been working, is the least prepared. The analysis of their gap assessment A suite of supporting tools and methodologies, if even suggests an underestimation of efforts required to developed, could expedite the adoption and impact of achieve conformance with ASM standards in general. the standard. For example, it would be helpful to be able to do the following: Possible Linkages to REDD+ and Voluntary Carbon Standards • Convert the feasibility study methodology designed as part of this project into a publishable blueprint Carbon feasibility assessment for the ASM entities to empower other organizations to scope possible in all four countries centered around a reasonability FS ASM pilots and programs and encourage/enable assessment as to whether the recent history and extent adoption of the PCI, so seeding and scaling of FSM. of forest loss lends itself to the development of a carbon- financed forest conservation initiative. • Understand what existing Verified Carbon Standard (VCS) project methodologies (the basis of the carbon The assessment suggested for all four pilot sites that the accounting for projects implemented) are applicable typical size of ASM operations and licenses is a possible to FS ASM and what methodologies might need to barrier. In Ghana, for example, the size of a license area be developed to implement such projects; undertake for small-scale mining cannot exceed 25 acres. For such methodology development if required. small areas, the cost-benefit relation of engaging with a forest carbon initiative is unfavorable. Peru, which allows • Capacitate, motivate, and enfranchise governments for ASM licenses up to 1,000 hectares, is better positioned. into bringing about FSM by developing a human Even there, most ASM operations are smaller, such as the rights–based approach to managing ASM in Key pilot site, which owns mining rights of 300 hectares. The Biodiversity Areas or crafting a brief on if/how the pilot site of Colombia is probably the only one better protection of forests can help with the fulfillment of positioned; it belongs to a peasant community that human rights in the ASM sector and communities. owns larger, multipurpose community land and so is able to manage its natural resources, including carbon assets, at the landscape level. However, even there, 6.2 Adoption of FS ASM in National Fondo Acción, an NGO that has implemented REDD+ Processes projects in the region, raised concerns that a REDD+ project would need to be implemented at scale. The site The feasibility assessments for piloting the FS-ASM assessments suggest that it might not be feasible to fund Standard in the four target countries of Colombia, Peru, FS ASM through carbon finance as a stand-alone project Ghana, and Liberia reveal certain commonalities as well at small mining sites despite their potential for carbon as differences. storage, and without addressing other impacts on the forests. Probably to be economically viable, any initiative 70 FOREST-SMART MINING - ASM to integrate FS ASM into an emission reductions program benefit-sharing system so that payments for results would need to involve the collective engagement of in the broader landscape can be used as incentive. the miners in the area, which will require investment in Similar to Colombia, informality is a key issue, but a convening, coordination, and relationship management. clear stratification of the mining sector by scale is in place. Affordable nature-based solutions such as FRM, Furthermore, for all pilot sites and countries it would need as proposed in the FS-ASM Standard, might similarly to be confirmed that a suitable carbon methodology for help lower the entry barrier into the formal sector. a project where mining is a driver is available under any voluntary carbon standard operating in the area. If no • Ghana. The country has a well-developed REDD+ such methodology exists, it needs to be developed.2 strategy led by the Forestry Commission. It recognizes ASM and large-scale mining in forest reserves as drivers Linkages to National Legislation of deforestation and identifies the improvement of mining regulations as a strategic response option Stakeholder consultations in all four countries resulted as well as a potential source of funding (GoGH- in positive feedback with regard to alignment of the FS- GFC, GhREDD+, and FCPF 2016), but has not come ASM Standard with national legislation. In all cases, the out with a deliberate strategy to address it (see the standard appears to go beyond legal requirements and forest carbon assessment in chapter 4.2.4). Results of therefore finds good acceptance. the Country Regulations Analysis give credence to the fact that most of the existing legislations within the ASM mining subsector encourage forest-smart The FS-ASM Standard will certainly serve as a source mining practices and no significant modifications of inspiration for regulators. The extent to which it can are required for the implementation of the standard and should be incorporated into national legislation, in Ghana. The main issues are monitoring and however, needs to be assessed more deeply on a compliance. country-by-country basis. In a first approximation, the country studies revealed the following: • Liberia. Liberia is a highly forested country with low levels of ASM development and formalization, but it • Colombia has already made significant progress in its also has good REDD+ readiness (see the forest carbon REDD+ readiness (see the forest carbon assessment assessment in chapter 4.2.5). While government in chapter 4.2.2). Completion of the benefit-sharing capacity may be limited, there is political will to system for REDD+ and rules on nesting, together with support the formalization of the ASM sector and the methodologies that allow to account for and claim advancement of community forests. As such, Liberia forest carbon credits by forest-smart ASM operators, makes a strong candidate for uptake of the FS-ASM are seen as important enabling factors for facilitating Standard, especially with a focus on avoiding ASM the implementation of the FS-ASM Standard. Technical development in forests of high conservation value. and environmental regulatory instruments that do not differentiate by the economic capacity of mining operations (ASM, large-scale mining) are one of the All of the gap analyses revealed a considerable need causes that exclude 85 percent of ASM from the formal for training and capacity building, to enable miners to sector. Adoption of the standard’s approach, based conform to the standard. Therefore, the potential for on the FRM as an affordable, socially acceptable, and adoption of the FS-ASM Standard into national legal ecologically viable nature-based solution for ASM, is frameworks depends on the capacity of national and seen as an opportunity to overcome this barrier. local authorities (a) to procure or provide extension services for training of miners in the application of the standard and (b) to monitor and enforce compliance • Peru. Peru has already made good progress in with the requirements. REDD+ readiness, but the forest reference emission level (FREL), safeguards information system, and in particular the benefit-sharing system are not yet As long as these capacities appear not to exist—given finalized (see the forest carbon assessment in chapter the prevalence of informality in the ASM sector—it is 4.2.3). This provides an opportunity to integrate the recommendable to not push for verbatim incor- avoidance of ASM impacts into the country’s REDD+ poration3, which would most likely result in “dead” 2 The task of this assignment was to develop an instrument to integrate forest-smart mining into ASM standards. The task for such an assignment would most likely be to integrate, vice versa, ASM into forest carbon standards. 3 The FS-ASM Standard was designed under the premise it would be bolted on to ASM standards. Such voluntary sustainability standards take a very different approach than lawmaking. FOREST-SMART MINING - ASM 71 law. More recommendable would be to promote the That notwithstanding, during stakeholder engagement principles, such as the FRM, as a framework for design, it became clear that not only miners but also their planning, and physical actions that an ASM entity can stakeholders require support, training, and capacity undertake to maximize impact avoidance within the building. It is recommended that an authoritative scope of its ability, minimize operational impacts, and blueprint of training materials and training metho- maximize rehabilitation effectiveness. The actions need dologies be developed that can then be adapted to the to be designed to be economically affordable, socially different country contexts. Leaving the responsibility acceptable, and ecologically viable. Uptake and adoption to develop such training materials and handbooks to of the standard is unlikely to be achieved through each of the more than 80 ASM countries—or even incorporation into legislation alone. The development worse, to each implementing stakeholder—not only of various capacities—institutional as well as technical— will cause enormous confusion through widely varying is needed too. Critically, policy developments need to interpretations but also will represent an enormous be encouraged through the presentation of effective duplication of efforts. See chapter 6.1 for greater and ASM-targeted incentives to bring about behavior guidance on this point. change. Each legislative and policy context will require the identification of such incentives that are appropriate It is further recommended that a cross-sectoral colla- to situation. borative approach is considered in designing and developing any national or regional FS ASM program. Linkages to International Law Training and other capacity-building investments are likely to be more cost-effective if delivered at scale across Although sovereign states have the rights and a given forested landscape. responsibilities to legislate and regulate activities within their borders, international law has implications for Tailored Messages and Briefs for Different how natural resources and human rights are governed Audiences in Selected Countries at the national level. Forest-smart mining will be more achievable where local and national policies and The development of a global communications strategy regulations align with international law. Key international with tailored messages and briefs for different audiences instruments to align with include international in selected countries is recommended to increase uptake investment treaties, international human rights law, and of the FS-ASM Standard. Briefs could serve the purpose environmental conventions and treaties. of capacity building and training for miners or enabling stakeholders to implement FS ASM. The communications Capacity Building and Training Needs strategy could be coordinated globally and be localized in partnership with local implementing partners, such as All four feasibility assessments concurred in the Solidaridad in Ghana or Diamonds for Peace in Liberia. appreciation that implementation of the standard’s requirements is feasible under the condition that miners receive support, training, and capacity building. This confirms the two-pronged approach taken during standard drafting, to develop PCI for ASM entities (section B of the standard) and guidelines for ASM stakeholders (section C) and closely link them by specifying for each PCI requirement for miners the enabling responsibilities of stakeholders. 72 FOREST-SMART MINING - ASM Source: © Pixabay, Colombia Santa Rosa FOREST-SMART MINING - ASM 73 REFERENCES ACET (African Center for Economic Transformation). Accessed November 8, 2021. https://fairmined. 2015. Local Content and Value Addition in Ghana’s org/fairmined-revision/. Mineral, Oil, and Gas Sectors: Is Ghana Getting It Right? https://commdev.org/publications/acet- Aubynn, T., et al. 2010. “Mainstreaming Artisanal and 2015-local-content-and-value-addition-in-ghanas- Small-Scale Mining: A Background to Policy mineral-oil-and-gas-sectors-is-ghana-getting-it- Advocacy.” Draft Report. Ghana Chamber of Mines. right/. Accra. ARM (Alliance for Responsible Mining). 2008. 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FOREST-SMART MINING - ASM 77 78 APPENDIXES Appendix A: ISEAL Credibility Principles versus FS-ASM Standard Development Methodology In 2013, ISEAL launched the Principles for Credible and Effective Sustainability Standards Systems (Credibility Principles) following extensive global stakeholder consultation. The principles, recently updated in 2021 (ISEAL 2021), provide an international reference for defining the credibility of sustainability standards. They are a tool for assessing the impact potential of standards and communicating the core values that lie beneath them. The methodology for developing the Forest-Smart Artisanal and Small-Scale Mining Standard (FS-ASM Standard) was designed to align as close as possible with the ISEAL Credibility Principles. ISEAL Credibility Principle How our methodology supports this Sustainability impacts A credible sustainability system has a clear purpose to drive positive social, The FS-ASM Standard has a clear purpose to drive positive social, environmental, and environmental, and economic impacts and to eliminate or remediate negative impacts. economic impacts. It clearly defines and communicates its sustainability objectives It defines and clearly communicates its scope, its specific sustainability objectives, and and approach to achieving them. The standard focuses on a significant sustainability its strategies for achieving these objectives (its theory of change). The system focuses impact, deforestation, forest degradation, and climate change. It seeks to address on the significant sustainability impacts in its scope. It seeks to address the root causes root causes of sustainability issues and deliver wider systemic impacts. Moreover, the of sustainability issues and deliver wider or systemic impacts. It reflects current scientific standard has been derived from the FSM study researched and written for PROFOR in evidence and international norms when relevant. It is adapted to local or sector-specific 2017–19, the Frugal Rehabilitation Methodology, and additional research carried out conditions where this helps improve impact. throughout this project. As such, it reflects best scientific understanding and relevant international norms. Collaboration A credible sustainability system identifies governments, businesses, and civil society The FS-ASM Standard has been designed and consulted with the Global Advisory organizations, including other sustainability systems, that are working toward Panel as well as local experts in selected countries. It has been designed toward shared shared sustainability objectives. It actively seeks alignment and respectfully pursues sustainability objectives and alignment with other national, private, or international collaboration with others. It establishes partnerships and shares learnings to improve processes, with a vision of publishing under a Creative Commons license, which would its efficiency and its direct or systemic impacts. permit diverse standard setters and sustainability initiatives to adapt and adopt it into their own collaborative processes. Value creation A credible sustainability system strives to create value that fairly rewards the effort and The criteria are as specific as possible while being flexibly written to enable easy resources that it takes for users to participate in the system. It has a viable business adoption and/or adaptation to the diverse standards that are relevant in the minerals model, and it operates efficiently, minimizing costs for users and reaching more users world. by reducing other barriers to access. It supports users to implement its tools, and it FOREST-SMART MINING - ASM empowers users by demonstrating a clear business case for participating in its system. The FS-ASM Standard has been ground-truthed as part of the site visits for four case studies, thereby checking the adaptability of its criteria and indicators to different local conditions. To ensure that the guidelines are realistic and achievable for ASM entities, the team has performed a “reality check” through consultations with miners and local stakeholders, which have been further validated in site visits. Measurable progress A credible sustainability system has tools that are relevant to achieving its sustainability Rigor has been ensured through each standard setter’s own governance process. FOREST-SMART MINING - ASM objectives, and these tools allow progress toward objectives to be measured over time. We will consider whether the “bolt-on” FS-ASM Standard should offer three or so It collects and analyzes the data it needs to measure, understand, and demonstrate the measurable performance levels to allow schemes to adopt the low, middle, or high bar progress its users are making toward these objectives. requirement(s) according to their own objectives and market position, and measure progress. Stakeholder engagement A credible sustainability system is inclusive and nondiscriminatory. It empowers The development of the FS-ASM Standard has been led by experts, as envisaged by the stakeholders to participate in decisions and hold the system to account. It involves terms of reference. A Global Advisory Panel comprising people with diverse mineral, a balanced and diverse group of stakeholders in decisions that will affect them. It geographical, and human rights interests and diverse expertise as well as diverse local strives to understand the context and perspectives of stakeholders who have been stakeholders representing miners, governments, and civil society organizations was underengaged or underrepresented, and it creates opportunities to ensure their involved and consulted on the approach and content of the standard. This will increase participation in decision-making. It provides clear and transparent feedback on the credibility of the bolt-on standard and increase the likelihood of its adoption as stakeholder input and concerns. It has fair, impartial, and accessible mechanisms for standard setters have had had a role in its design. resolving complaints and conflicts. Impartiality A credible sustainability system identifies and avoids or mitigates conflicts of interest The consortium was organized with Levin Sources, which is not a standard- throughout its governance and operations, particularly when it comes to assessing setting organization, as the lead partner to avoid potential conflicts of interest its users’ performance. Transparency and stakeholder engagement help ensure the between the Alliance for Responsible Mining (ARM) and other standard setters. system’s integrity can be trusted. Furthermore, the team leaders have distinct responsibilities to help manage any potential conflicts of interest; Estelle Levin-Nally of Levin Sources has managed external relations for the project and relations between the partners, while Felix Hruschka of ARM has overseen project management and internal operations. Levin Sources has a Conflict of Interest Policy, which also applies to the project. 79 80 ISEAL Credibility Principle How our methodology supports this Transparency A credible sustainability system makes important information publicly available and After the inception workshop in September 2019, the project team had multiple easily accessible while protecting confidential and private information. It enables bilateral calls on the project and what it intends to do with interested organizations, stakeholders to understand and evaluate the system’s processes, decision-making, such as standard setters and responsible sourcing initiatives. results, and impacts. Stakeholders have the information they need to actively participate in decisions or raise concerns. Reliability A credible sustainability system designs its tools so that these can be consistently The open nature of the principles, criteria, and indicators (PCI) resulting from the project implemented and assessed. It ensures assessments of users’ sustainability performance provides a ready-made bolt-on FS ASM–specific standard that standards bodies can are competent and accurate, and that these assessments support any claims it allows consider including and applying. The project will save time and effort for other actors users to make. (not only standard setters) to use it when sourcing or engaging with ASM in forest conditions. Truthfulness A credible sustainability system substantiates its claims. Any claims the system or The PCI include examples of claims that can be made at different levels of compliance its users make are clear, relevant, and can be checked. They enable customers and to promote truthful communication about the application of the forest-smart mining other stakeholders to make informed choices. The scope and design of the system criteria. is accurately reflected in any claims, ensuring these are not misleading. Claims about sustainability impacts are backed up with data and evidence that are publicly available. Continual improvement A credible sustainability system regularly reviews its objectives, its strategies, and The indicators provide a framework for understanding the impacts of the criteria and the performance of its tools and system. It evaluates the impacts and outcomes of measuring and demonstrating progress toward their intended outcomes. its activities. It applies the lessons learned to improve. It responds to new evidence, stakeholder input, and external changes, adapting its strategies to improve its impacts The indicators are tied to the sustainability objectives. and remain fit for purpose. FOREST-SMART MINING - ASM Appendix B: Summary of Standard Strategies Appetite and pathway for FSM gaps in the standard/initiative Initiative appetite to pilot FSM PCI Revision cycle Next steps incorporation of FSM GemFair The extensive business-as-usual GemFair is interested in exploring this Yes. Not yet If the World Bank is expectations set on miners (e.g., paying topic further. decided. involved in regulatory their workers, obtaining financing, GemFair is presently carrying out a reform in Sierra Leone, FOREST-SMART MINING - ASM paying their licensing fees, adhering to restoration and reclamation pilot. the consultants who our minimum standards, etc.) means are carrying that out Opportunity for regulatory reform to create forest protection is not yet a priority for should speak with greater incentive for all ASM license holders participating ASMOs. GemFair to address to carry out reclamation. the reclamation Deforestation and afforestation are disincentive issue. not currently explicitly covered by the GemFair ASM Standard, but many of the environmental requirements that are covered by the standard would help minimize forest degradation. Carbon stocks are beyond the current scope of the GemFair ASM Standard. Fairtrade The Fairtrade Gold Standard has extensive Deforestation and the environment are Potentially, but funding is a challenge. Currently under Live pilot the FS-ASM environmental requirements, covering three top of the agenda for consumers and The market needs to be willing to absorb revision until Standard in a Fairtrade of the four forest values. companies. Fairtrade is committed to a the extra cost and invest in the journey; 2021 – next site (if funding social justice agenda, of which climate otherwise, it is very challenging for review cycle in available). However, these are mostly development justice is a core part. Fairtrade is therefore Fairtrade as a small player. 2025. requirements, and no guidance is given in very interested in how they can work in Integrate forest- the standard or auditing criteria on how to this space. smart PCI and meet them. considerations of There is also little consideration of the indirect impacts the indirect impacts of mining on the of mining into the environment, let alone forests.... Fairtrade standard. 81 82 Appetite and pathway for FSM gaps in the standard/initiative Initiative appetite to pilot FSM PCI Revision cycle Next steps incorporation of FSM Fairtrade (continued) ...Carbon stocks are not referenced in the standard. However, Fairtrade does have a climate standard assessed by FLOCERT and a new scheme for farmers, workers, and miners to receive carbon credits. Fairtrade does not have carbon credits available for their mine sites yet, but they have the capacity to comply, assess, and receive the credits. Fairmined The Fairmined Standard has 16 extensive ARM is highly interested in exploring the ARM is interested in incorporating the It started in Validation and environmental requirements and there possibility to propose the inclusion of FSM PCI in the current work with miners 2019 and it discussion of the are already some requirements specific FS-ASM criteria in the Fairmined Standard in environmentally rich and fragile continues next Fairmined Standard to forest protection. However, these are 3.0. areas. While mercury continues to be year. 3.0 proposal with the mostly development requirements, and an important challenge that already Fairmined Standard no guidance is given in the standard on The current Fairmined Standard is the focus of countless projects and Committee. how to meet them. Particularly, there revision is a perfect opportunity to interventions, the forest-smart mining are opportunities to enhance some of test the “bolt-on” approach of the FSM framework offers an opportunity to go Planning and the environmental requirements and for criteria, especially considering the high beyond mercury and apply a practical launching the ecologic certification to leave room to make expectations of performance related environmental management approach in international them more forest smart. with Fairmined being a best-practice forest areas such as the Amazon region, Fairmined standard for ASM. ARM is now drafting the Congo basin, the biogeographical Standard 3.0 public ARM has the progressive Sustainable the Fairmined Standard 3.0 to present Chocó region along the northwest Pacific consultation. Mines approach that ARM is taking (CRAFT it to the Standard Committee, ensuring coast of South America, and the forests toward Fairmined), the FS-ASM would also alignment of the process with the ISEAL Pilot tests of the new of Central America. Following the first be integrated progressively, with its basic Code. standard version with promising experiences, ARM is keen to elements (highest risks) applicable for small-scale mining include the concept of forest-smart mining ASM with lower capacity and sustainability organizations and the and FS-ASM criteria pilots in future funding performance, while its fuller scope being proposal of transition applications and will try to include some applied with mines closer to achieving for already certified actions recommended in the FS- organizations. FOREST-SMART MINING - ASM Appetite and pathway for FSM gaps in the standard/initiative Initiative appetite to pilot FSM PCI Revision cycle Next steps incorporation of FSM the Sustainability Leaders status – or ASM criteria assessment carried out in Approval of changes compliance with the Fairmined standard Chocó as a part of this assignment, in the by Fairmined Standard with a strengthened environmental aspect. Sustainability Plans of the participating Committee after the mining organization. However, resources consultation. are limited for a complete implementation of forest-smart mining within an existing Publication of project that focuses on other objectives. Fairmined Standard 3.0 and a transition FOREST-SMART MINING - ASM period for mining organizations already certified with the standard. planetGOLD The program has developed a set of criteria High appetite from stakeholders and the Maybe 2022 onward. Midterm review Engage with the that include elements on environmental program. next year due UNEP Midterm commitments. to begin at the Review (MTR) of The leadership (GEF, UN agencies) are end of 2021. planetGOLD global Carbon stocks are beyond the current very interested in coupling protection project to consider scope. of biodiversity, addressing deforestation, including forest-smart etc. with their mercury efforts. PCI in the planetGOLD midterm review. Country-level teams and artisanal and small-scale miners are interested, Continue but they are also very focused on the engagement with immediate job at hand, the immediate Conservation priorities of completing their projects. International, the lead for planetGOLD phase Many stakeholders (e.g., potential 2, which will have a downstream buyers) are very interested stronger emphasis as part of the overall story of responsible on biodiversity. We gold production. should do this once the first public draft of the PCI is released and ready for piloting (i.e., start of 2022). .. 83 84 Appetite and pathway for FSM gaps in the standard/initiative Initiative appetite to pilot FSM PCI Revision cycle Next steps incorporation of FSM planetGOLD (continued) ...Continue engagement with individual country projects that are taking the lead and controlling all activities at the country level. There may be appetite among them— including countries for which we have no developed workplan, road maps, and budgets—to consider how to include FSM in their existing activities or to engage with the planned pilots in countries that overlap. A published blueprint on how to scope for an FS ASM project based on the methodology followed for this World Bank FS-ASM Standard project would facilitate this type of seeding. The planetGOLD global project can facilitate contacts with each country project. FOREST-SMART MINING - ASM Appetite and pathway for FSM gaps in the standard/initiative Initiative appetite to pilot FSM PCI Revision cycle Next steps incorporation of FSM LBMA The latest version of the LBMA Responsible LBMA is refreshing a toolkit for refiners In the short term, LBMA could play the role RGG version 9 FSM could be Gold Guidance (RGG) (version 9) introduced that are sourcing from ASM and would of convenor, connecting GDL refiners with to be released considered for environmental and social criteria in refiners’ like to include FSM PCI as part of the forest-smart members looking to pilot the in November inclusion in the next primary supply chain for the first time. It toolkit. In addition to this, LBMA plans PCI. 2021. iteration as it is a now includes the boycott of material from to undertake extensive consultations in clear material risk to World Heritage Sites. 2022 with stakeholders (including Levin In the longer term, LBMA is open to Next revision companies. FOREST-SMART MINING - ASM Sources) to examine ways to increase considering inclusion or recognition of the is first half of Carbon stocks are beyond its current scope. direct sourcing by LBMA refiners of ASM PCI into its responsible sourcing framework. 2023. material. CRAFT The CRAFT Code has eight requirements According to the Creative Commons ARM is actively applying the CRAFT Code The CRAFT Use lessons learned relevant for the FS-ASM Standard in open source license terms of the CRAFT within its Sustainable Mines Program, Code 2.0 was from pilot application the Module 5 requirements, which are Code, ARM as the code maintainer has which aims to facilitate the connection launched one on the ground and intentionally broad and generic in their very limited control over who uses the with formal markets and bring partners to year ago after study the incentives wording. However, they can become code, for which purpose, and under invest in mines´ progressive improvement the second for the miners to very site specific with the required which conditions. However, to ensure through Mines Sustainability Plans. round of public apply the FSM risk assessment. They have therefore consistency in the CRAFT application, Considering that some of the projects are consultation criteria, particularly a high potential to accommodate the version 2.0 introduces a new chapter in forested areas, ARM is eager to pilot (October for schemes, such as identification of forest-related risks and (Volume 3) on guiding principles for the FSM PCI elements (in Colombia, Peru, 2020), which the ARM’s Sustainable therefore to implement forest-smart CRAFT Schemes, on how schemes are Guyana, Suriname, Honduras,). All the is very close to Mines Program. measures as part of the Improvement Plans. expected to interact with ASM producers mining sites mentioned are gold ASM. the start of a and what claims may be made related new revision Evaluating relevance, to the usage of CRAFT. At this level, there cycle. ISEAL interest, and exploring could be an opportunity to add FS-ASM recommends opportunities and criteria to the Craft Code for specific a standard- funding for “FSM applications, or in other words to “branch” setting branch version of the main code. organization CRAFT.” shall review In the future open a standard at source CRAFT Code least every revision, convening five years for the Standard continued... Committee, ... 85 86 Appetite and pathway for FSM gaps in the standard/initiative Initiative appetite to pilot FSM PCI Revision cycle Next steps incorporation of FSM CRAFT (continued) relevance expanding the scope and for for new members effectiveness with relevant FS in meeting ASM experience, its stated and opening the objectives. discussions for the amendment in the standard. Additionally, incorporating lessons learned from the CRAFT branches and implementation. FOREST-SMART MINING - ASM FOREST-SMART MINING - ASM 87 88 FOREST-SMART MINING - ASM