National Mining Policy 2006 - Part 3

Mineral agreements
Special agreements with large investors are a common practice in many countries including the oil and petroleum sector of Pakistan . Allowance given to parties through special agreements is extremely commendable for many reasons.

Firstly, it defines the rights and obligations of parties with respect to each other thus recognizing that they are free to choose the rights and obligations they wish to undertake provided.

Secondly, these agreements extend concessions to large investors with respect to their mining activity. This practice is commonly used in the petroleum sector. A similar provision may also be extended to mining activity.

Thirdly, these agreements elaborate details on specific regulations and could also be used to fill gaps in the prevailing rules and regulations. Therefore, it is highly recommended by the consultants that 'special arrangements' must be backed by force of law and specific provision must be added to the Mining Act.

Rules/ regulations must be positive in their essence and effect. It is noted that prevalent provincial rules contain retrograde and regressive provisions (e.g. Rule 97 of NWFP Mining Concessions Rules, 2005). Similar provisions, being not investor friendly, were removed long ago from petroleum rules.

Foreign companies may be allowed to invest openly and restrictions over equity rights held by them may also be removed. Provincial rules need to be amended to give foreigners better rights.

Besides, the condition of confining small scale mining to Pakistani companies (or persons) too, needs to be removed to improve competitiveness.

Success of mining in Chile is largely attributed to investment friendly rules. Brazil and Mexico suffered due to laws restricting foreign participation in mining.

Security of tenure

It is essential that investors' confidence be enhanced by the right measures, e.g. conditions for terminating license/ lease should be clearly enumerated in the provincial rules and must strictly be adhered to. The holder must be allowed to fully exploit its rights pursuant to license/ lease conditions.

Renewal of lease may be done as a matter of right under well defined criteria. Petroleum rules allow for automatic first renewal. Chile , Mexico and Venezuela too allow automatic renewals.

More than one mineral activity in one area may be allowed to different companies at the same time. However, this calls for formulating rules to address many issues that are bound to crop up due to this.

Competitive bidding should be adopted where many applicants want to work in one area. The process should not only be transparent but also judicious.

Data Cadastre

The primary objective of any economy is to attract investment. Foreign investors will only come and invest when there is a tangible product on record to be commercially exploited.

There is need to maintain a clear and updated data cadastre. The present registry of mine licenses/ leases is outdated and does not convey information in an easily comprehendible manner.

It is important that the data cadastre be digitized and data made available online putting potential investors at ease with the information they want. Computerization will also reduce involvement of mining departments and put the information just a click away for all investors around the globe.

It is suggested that Ministry of Petroleum may make it mandatory over oil companies to provide detailed reports about their exploration activities.

Mines Act 1923

Mining Act has long been outdated and needs review. Focus has to be on open-pit mining and all related laws.

Access to land

Many a times, the stakeholders are unable to take over the (land) area leased for mining. The surface (land) owner(s) often obstruct license/ lease holders who often do not even get the right to enter the land granted to them for mining.

Four principle features generally affect mining operations, namely:

1. Geologically favorable locations are almost invariably remote and backward;

2. Size of land holdings is generally small, often there are many landowners within one lease;

3. Such lands are generally not irrigated ones; and

4. Agricultural or any other yield from the land is generally lower compared to out put of mining.

It is proposed that rules and regulations be devised to take care of interests of both - the mining lease holder and the original land owner. The Licensing Authority should have judicial power and assistance to summon land owners for working out the agreement.

Policy implementation

It was not until 2002 that National Mineral Policy 1995 was implemented. Provinces generally transformed only those policy terms into rules, which suited them and left many untouched. It is now recommended that provinces must adopt the policy in entirety.

Reconnaissance Licence

To enable mining companies to reconnoiter large areas in a short time using modern techniques of satellite imagery etc an RL will be granted for 100 to 10,000 sq km for one or more minerals. Unless stipulated otherwise, the license will be non-exclusive for 12 months and will not be renewable.

However, the licensee will have the right to an exploration license over 10% of the area under an RL provided that criteria for the license and other laws are met.

In case of more than one applications, no licensee will have the right over 10% of the area. In case of overlap the decision will be based on open bids. RL shall be non-exclusive, however the limit of area as a matter of right can be increased beyond 10% for EL provided that the licensing authority is satisfied with the performance of the license holder.

Provincial government shall be responsible for safety and security of investors. M/o P&NR will execute special agreements and provide sovereign guarantees to any investor.

Exploration License

Exploration licenses (EL) will not be granted for areas exceeding 1,000 sq. km and for no more than three years. Subject to satisfactory compliance of EL conditions, it will be renewed for no more than three years over 50% of the area under original EL.

Applications for ELs/ renewals shall be granted/ refused in 120 days.

EL shall not, in the first two years, be assigned or transferred to any party, other than to an affiliate and not for more than 50% area under the license. Assignments to an affiliate must be approved by the Licensing Authority.

Provincial government shall ensure safety and security of investors. M/o P&NR will arrange special agreements and provide sovereign guarantees to any investor.

MDR License

On completion of a full feasibility, if the EL holder can demonstrate that the deposit, though potentially viable, cannot be commercially developed, due to depressed prices or other reasons, he may, in 180 days before EL's expiry, apply for a Mineral Deposit Retention Licence (MDRL).

The applicant will have to demonstrate that exploration had progressed as far as practicable and that the applicant is able and willing to comply with MDRL terms and conditions.

Application for an MDRL will be considered within 180 days and may be granted for a period not exceeding two years. It may be renewed for no more than one year. However, the licensee must justify annually to the Licensing Authority the basis for continuation of renewal of the MDRL.

In the event of another company applying for a mining lease over a deposit covered by MDRL, the licensee will have the right of first refusal to obtain a mining lease. If the licensee is unable to match the terms offered by the third party the MDRL shall stand terminated.

The licensing authority shall ensure the sincerity and business seriousness of the applicant.

The holder of EL or MDRL may apply for a mining lease over a maximum of 100 sq. km. However, granting titles for over 50 sq. km will be approved by MIFA.

Provincial government shall be responsible for safety and security of investors. M/o P&NR will arrange for special agreements and provide sovereign guarantees.

Mining lease

Holders of ELs or MDRLs may apply for a mining lease over a maximum of 100 sq. km. within his EL or MDRL along with detailed information on technical and financial resources, work program etc. The application will be accepted or declined in 120 days.

Ordinarily, the LA shall take conversion from EL/ MDRL to mining lease as the applicant's right unless the LA has reasons to refuse. The LA will not refuse an application for an ML unless it has given the applicant a reasonable opportunity to modify proposals or mining plans or make representation or otherwise remove the grounds for refusal. ML will be granted for 30 years or mine's estimated life. An ML may be renewed for not over 10 years or the life of the mine whichever is less. The lessee will be required to mine according to good international practices, provide acceptable working conditions and take measures to protect health, safety and welfare of employees and the environment.

A lessee shall have the right to assign an ML with LA's consent, which will not be unreasonably withheld or delayed.

A lessee shall have the right to market and export minerals/ products according to Pakistan 's requirements. Price for any purchases by government shall be fair market price, which shall be determined by agreement on the basis of specified criteria and, failing agreement, by reference to a mutually acceptable expert/ arbitrators.

Provincial government shall ensure security of investors. M/o P&NR will arrange special agreements and provide sovereign guarantees.

Environment

With increasing focus on environment, Pakistan wishes to pursue sustainable development consistent with environmental priorities. Companies will be expected to ensure that mining is done in environmentally acceptable and safe manner and that such operations are properly monitored.

Accordingly, mining companies should be required to:

Prevent and minimize environmental damage and to make good any damage;

Submit to the LA and Chief Inspector of Mines an environmental impact assessment (EIA) and environmental management plans for each stage of operations;

Do site rehabilitation as necessary;

Comply with laws and internationally acceptable environmental standards;

Ensure adequate compensation for injury or damage to property caused by mining operations.

Universally accepted principals will remain a constant guideline;

Pollution prevention will be diligently adopted.

Agreement with govt

Rights and obligations of

both the investors and the governments (provincial, federal) need to be well documented. To provide due comfort and security of rights, the prospectors/ investors should get fiscal incentives to encourage investment in mining and to regulate it effectively.

Accordingly in future, mining including obligations under licenses and leases particularly with foreign investors will be reinforced through a comprehensive agreement.

Skilled manpower

It would be appropriate to utilize existing training facilities at:

1.Geo-science Lab, Islamabad . Batches of 20 geo-scientist per annum can be trained on all geology related subjects with focus on applied geology. Staff of GSP, existing corporations and research professors from academia can act as trainers.

2. Punjab School of Mining, middle level supervisors and mine surveyors are already doing diploma level courses in mining technology, mechanical, electrical and surveying. More courses can be started here. Experienced mining engineers and research professors should be engaged as trainers.

3. Existing PCSIR facilities in various cities should be used to impart training in value addition chain.

Data generation

Quality and reliability of data is very important. It should be mandatory for each organization dealing with solid minerals to share geo-data/ information on production, productivity, costs, employment levels, lease/ license related data and many other aspects.

Presently 64 minerals and rocks are being mined in Pakistan . 23 important minerals showing their resource size and average annual production is shown (as a sample) in Table 1.

Survey, exploration strategy

Preparing geological maps, discovery of minerals, geophysical and geochemical surveys and identifying explora-tory targets are federal government's responsibility. Detailed exploration and grants of concessions and their regulation is the exclusive domain of provi-ncial governments.

Availability of geological maps and related data on integrated surveys are the bench marks for founding the conceptual base for any investment portfolios in mining. Whatever the reasons, Pakis-tan's over all achievements are far below satisfactory levels.

Status of geological and geophysical mapping and exploratory drilling is shown in Table 2.

It is alarming that only 33% of the country's total area is geologically mapped to the scale of 1:50,000. Thorough knowledge of geology and mining potential are basic requirements for investors determined to do systematic exploration.

Survey, exploration

Providing modern maps is the most important service that GSP should be doing. Many mining companies operate largely in a digital environment, therefore GSP should facilitate this at the soonest.

Initially high potential areas should be picked for this as suggested by the German consultants (1993).

GSP is on the verge of a personnel crisis. 85% of its trained staff is poised to retire in the next five years. GSP needs to be equipped for the task.

A Remote Sensing Centre may be set up in GSP. This technology saves time and money. Maps prepared by various mining and geological departments of governments and universities may be checked and added in the inventory of GSP.

Data generaton

Mining industry has peculiar business concerns. It is an ongoing process, a never ending chain. From discoveries to exploitation, projects are established on available data. The ore body as delineated today will be expanded with additional inputs.

Past data will be used today. Data generated today will be useful in future. An ore considered to be un-economical in the past, is quite likely to become feasible today for many reasons. Treatment of a mine keeps changing with additional data.

Presently mining data in Pakistan is scattered, disjointed and not available in conducive shape and form. Typical examples are the mineral data system at GSP headquarters, Quetta ; and at National Geo-data Centre, Islamabad .

Neither has the data compiled in the end users' language. Inventory of established reserves is more or less the same as was 20 years ago.

Conserving minerals

Minerals are non-renewable resources. Their conservation is vital to sustainable extraction and uses. We should in future allow only those methods, which optimize mine-ability, avoid selective mining and are based on long term planning.

A long term view based on production and use including export potential may serve as perspective for conservation; this only will ensure protection of future generations.

We should also train manpower for underground and surface mining including conventional, mechanized and advance mining. This calls for

intensive training to enhance professional and interpersonal skills to bring a paradigm shift.

Small scale mining

About 90% of mines in Pakistan are run by small companies. They are not mechanized and hence are labor intensive. This is a blessing in disguise as small operators generate jobs in remote locations.

However, they also have several handicaps, which have led to non progressive mining practices. Resultant contribution of mining to GDP is not more than 1%.

Once these small operators are adequately facilitated and motivated to introduce adaptable technologies, mining will grow and small mines of today may become large mines of tomorrow.

Small-scale mining (SSM) can improve through:

1. Capacity building by exposure to advanced practices and corporate culture at all tiers with focus on skill enhancement of labor.

2. Dedicated and softer credit facilities.

3. Ensuring cheap rates and rentals of machinery and equipment.

4. Providing timber nurseries for its use underground.

5. Establishing labor colonies to suppress their moving away.

6. Providing power, water and roads to mining camps.

7. Facilitating SSM for utilizing mine waste in any allied industry as raw material. This will also protect environment.

8. Facilitating transfer and development of technologies needed for various operations.

9. Providing easy mine inspection.

10. Changing inspecting agencies' role from coercion/ policing to facilitating.

11. Fostering corporate and cooperative culture for merging small units into big units.

12. Harmonizing relations among stakeholders by giving them representation on all forums and committees.

13. Bringing all taxes under one roof and also rationalize them.

14. Giving mine operators representation in district governments specially in mining areas.

15. Imparting professional, technical, managerial and business training to stakeholders.

16. Forming 'chambers of mines' at regional and federal levels.

Financial support

Level of mining in Pakistan is primitive and labor intensive for want of capital needed for mechanization. Absence of infrastructure and up front investment is a barrier to development. Institutional fra-mework to provide these facilities is absent.

Exploratory drilling is a risk capital and is not within the reach of mine owners.

Government's policy to keep away from risk capital, which mining is all about, is an additional set back. New investment, however, is inevitable.

The need for financial support from commercial banks or a special fund created for this purpose is imperative. In their absence exploratory and development programs are hindered for want of sustainable supply of capital.

State Bank of Pakistan can make it mandatory for banks to allocate, say 5% of funds, for mining sector. For this the banks will have to take on professionally qualified and experienced geo-scientists examining/ vetting credit requests of mining company.

Pakistan 's future mining policy should focus on three points, say a panel of experts who have drafted a comprehensive proposal to guide the government about what the policy should be.

The three points highlighted in the proposed draft are: Support small scale mining (SSM) through funds, concessions in import duties and developing infrastructure faci-lities in potential areas etc; facilitate setting up of machinery renting pools; expand training facilities for various tiers of workers.

The proposal also calls for Federal Ministry of Petroleum & Natural Resources to begin to attend to the needs of 'solid minerals' too.

Infrastructure dev

Mines are generally located in contiguous blocks, most of which do not have infrastructure facilities. Mine acce-ssibility is thus usually below desirable levels. Transporta-tion suffers in terms of time and money.

These facilities, in most mining areas, need to be addressed on priority. They are capital intensive and their cost can be shared with mine owners besides local communities.

Investment on new discoveries and establishing of mining are capital intensive and not within reach of ordinary mine operators. Funds from government and 5% credit facilities under SBP instructions to banks may be the first steps to launch a documented operation.

Mining sector's location (usually far flung, inaccessible) is a great setback. The government may undertake such facilities by imposing a sort of Octroi on dispatches. However local population may be exempted.

25% of royalty should be set aside for such programs. Industries are generally close to big cities and infrastructure and social amenities are already available. In case of mining, cities have to be brought to the mines. This is a tall task requiring full government support.

Any investment on developing infrastructure to facilitate mining amounts to creating jobs for rural population and overall increase in economic activity through productive mines.

Strengthening Institutions

Mineral policy will be effective only when implemented. This calls for organized institutional framework and coordination between various departments and agencies. Provincial Departments of Mines & Minerals do meet some guidelines of ideal structure.

However, geo-scientists with requisite qualifications and field experience are generally not in decisive positions there. Intensive training in the country and abroad of staff is, therefore, inevitable and so is giving the departments machi-nery, equipment and support services.

Almost all provincial dire-ctorates, inspectorates and GSP suffer from these weaknesses.

MoP&NR, heavily occupied by oil and gas has hardly any soft corner for solid minerals. In any case this ministry too is not adequately staffed to discharge its designated functions.

Mineral policy clearly stresses institutional framework as per Aus-Aid Techn-ical Report for NMP implementation. Each Department of Mines & Minerals should be headed by a secretary with a geo-scientist at the next lower formation.

Role of public corporations is important as a trend setter and a role model for the private sector. Proposals to privatise them need to be reviewed to avoid dislodging of experienced and trained staff. They should be retained as master trainers for private sector's capacity building.

The current policy could not bear fruit for want of coordination, lack of implementation and facilitation between various stakeholders and federal and provincial departments/ corporations. An experienced scientist with PR potentials and grid-context may be chosen for this position.

This man will be answerable directly to the province's Secretary Mines & Minerals and will be ex-officio secretary MIFA. His liaison with all stakeholders should be effective and deliverable. A similar post should also be provided in the federal ministry.

New arrangements call for creating Mineral Division in M/o P&NR too to act as a line functionary in all mining matters for supervision, monitoring, coordination and control.

The existing staff needs:

01. Increase in numbers.

02. Capacity building and in service training in Pakistan and abroad.

03. Exposure to new requirements and bringing paradigm shift as a facilitator

04. Inculcate work culture, induce employees to continuously move forward.

05. Perceive visionary programs and design monitoring tools.

06. Link performance with incentives and choice posting.

07. Fair compensation for good work through added perks etc.

08. Inculcate sense of ownership through representation in committees, boards, seminars, delegations going abroad and public exposure.

09. Improve output, productivity, enhance safety, research to contribute to national economy should be linked with recognition and cash awards.

10. Education, training as an on going process for geo-scientists as students in advance courses and trainers for junior colleagues.

11. GSP must grow a fresh crop of experts in view of many high level retirements due in 5 years.

12. Establish geo-data center under GSP as its output is already tardy.

13. Re-organize and strengthen M/o P&NR

14. Implement mineral related programs and agreements.

15. Create a post of Director Coordination, Implementation & Facilitation.

Present policy was a multi disciplinary output. It failed to deliver for want of effective coordination, lack of implementation and facilitation bet-ween various stakeholders and related provincial and federal departments/ corporations.

A well connected, experienced scientist with PR potential may hold this position. This man will work directly under Secretary Mines and Minerals of each province/ territory/ region and will be ex-officio secretary MIFA.

Similarly Mineral Division should also be created in the federal M/oP&NR. This division will act as a line functionary on all matters related to minerals for:

A. Supervising, monitoring and controlling the functions of GSP, public sector corporations and geo-data centre.

B. Coordination and follow up on actions of MIFB regarding

defined activities.

C. To coordinate with provincial governments on all matters.

Equipment, machinery

Mechanisation is inevitable for mining industry's growth. Mine machinery and equipment, specially for coal and underground mining, are comparatively expensive and not manufactured locally. Some of the equipment needs to be flame proof for use in underground gassy mines.

Road building machinery (bulldozers etc) is also expensive and hence its purchase for one mine is not quite viable. Dumpers and shovel loads used in large mining operations too are not locally fabricated and are globally very expensive.

Government must, therefore, support this much neglected sector's needs by creating machinery pools for renting mining machinery. Currently these facilities are not available and hence pace of development has not been satisfactory specially in case of small mine operators.

Here are some options to address this issue:

1. All earth moving machinery in the pools of Agriculture Departments may be rented out for mining on the same rates as charged from farmers.

2. Companies manufacturing these equipments may be encouraged to arrange franchising in Pakistan or induced to offer more competitive rates.

3. Arrangements for local assembly/ manufacturing at Heavy Mechanical Complex or elsewhere should be developed.

4. The country needs to encourage local arrangements for boring or shaft sinking machines (1-2 m dia) capable of cutting medium hard rocks down to 200 meters.

5. Manufacturing of water tube boilers, essentially a very expensive pre-requisite for coal fired power plants, should be developed locally. But till this happens, their duty free imports (after being licensed for 10 years use) should be allowed.

Failures, success stories

Mining has many success and failure stories. Saindak is the only project where failure was turned into a success. All other projects, which failed once, have not had this turn around.

Some of the more prominent examples of failure are:

Hazara Phosphate (Kakul) - Lack of infrastructure, bad management, lack of PR with the sole buyer.

Hazara Phosphate (Tarna-wii) - Lack of infrastructure.

Kalabagh Iron Ore - High cost of technology, international politics, low grade ore.

Saindak Metal (when it was under SML) - High cost of infrastructure, lack of expertise and low cost : benefit ratio.

Sheikh Munda Coal Fired Thermal Power Plant, Quetta - Lack of sustainable supply of coal, low price of oil and WAPDA's affinity on clean fuel.

Daud Khel Maple Leaf Cement, Pak-American Ferti-lizer and their coal fired self generating unit - availability of piped gas at their door

Jamshoro Thermal Power - Non uniform coal quality, use of coal as run of mine and un-washed, deficient planning.

Pesminco - Size of ore body did not match investment portfolios.

Kumhar-Sherwan (Abotta-bad) Magnisite project - High cost of technology.

Dharyala Potash - Lack of technology in drilling.

Sor Range Coal Mines - Geological challenges and lack of data.

Degari Coal Mines - Un-manageable depth.

Mining, Coal Washing Plant at Sharigh - Political interference, and was based on improper sampling.

AJK Ruby - Remote location, lack of funds, and lack of infrastructure.

Gem Stone Corporation (NWFP) - Bad management.

Thar Coal Power Plant - WAPDA backed out of agreed power tariff.

Success stories

All salt mines - fully developed infrastructure, in-house training of manpower.

Revival of Saindak by Chinese - commitment to responsibility.

Revival of Dudhar lead, zinc by Chinese - commitment to responsibility and capability for a wide range of operations.

Very little of Pakistan 's minerals potential earns any export dollar. Rock salt is perhaps the biggest in this list. Marble, granite etc have big potential in Europe , but very little actual exports, while gems and precious stones are being exported through back door.

Substantial efforts have not been made to undo the factors obstructing minerals' exports. These are lack of infrastructure support, high freight -adding up to high logistics charges.

Skilled manpower

Prosperity index of any nation is a function of trained manpower. Pakistan as a whole and specially its mineral sector are the worst under this heading. Difficult locations, lack of social amenities and communication links from mine to market are the principal factors obstructing growth in numbers.

Skill enhancement avenues are limited. There are no institutions in the country for professional training even to meet current skill levels. Supply of mid-line supervisors too is inadequate. Punjab School of

Mines is the only institution for diploma courses in various aspects.

Unless training facilities are reinforced, mining will not have enough middle level managers. Engineering universities in Lahore , Jamshoro and Peshawar produce 70

mining engineers annually. But they generally try to get into other disciplines of engineering rather than sticking to mining.

Conserving minerals

Minerals are non-renewable, their conservation is vital to sustainable extraction and uses. We need a conservatory regime to emphasise and allow only those methods which optimize mineability, avoid selective mining and are long term. The following measures can be helpful in this regard.

iUpgrade extracted minerals under high techno-economic parameters for maximum recoveries of concentrates and metals.

iMaximize use of metals by recycling.

iUse substitutes of metals where expedient by changing consumer habits.

iRecover residual contents from slimes, tailings and old dumps.

We should develop a long term view about production, use/ exports, and potential. This would help conserve minerals and ensure their protection for future generations.

We should provide trained manpower in all disciplines for underground and surface mining including conventional, mechanized and advance mining. Training facilities for capacity building of government officers, small mine owners and their staff should also be arranged.

In brief, intensive training to enhance professional and interpersonal skills is inevitable for a paradigm shift.

Small scale mining

In Pakistan mining is synonymous with small scale mining (SSM). About 90% of mines are leased to small owners. Their low financial and technical capacity is a hard fact. The level is primitive and labor intensive for want of mechanization.

They are hence labor intensive, which is a blessing in disguise. It creates lots of jobs in remote areas. However, this too is a harsh fact that due to low capacity, mining has not taken off.

Absence of infrastructure and investment are barriers to development. Integrated exploratory and development programs are thus hindered for want of capital.

State Bank should make it mandatory for banks to allocate some, say 5% of their deposits, for easy financing of mining ventures. Reserves and proven data, certified by licensing authority, should be treated as collateral.

This investment will be proactive, leading to poverty alleviation and sustained employment and overall increase in economic activity through productive mines.

Absence of infrastructure, credit facilities, mining machinery, trained manpower and the tendency to make fortunes in the shortest time, have led to non progressive mining practices. Resultant contribution to GDP is not more than 1%.

Once small mine operators are facilitated and motivated, today's small mines may turn out to be large mines tomorrow.

Working of small scale mines can improve through:

i Exposure to advanced practices and corporate culture at all tiers and focus on skill enhancements.

i Dedicated and soft credit facilities.

i Supply of machinery on cheap rates/ rentals.

i Developing timber nurseries for growing timber for underground use.

i Establishing labor colonies to suppress labor migration.

i Providing electricity, water and roads to mining areas/ camps.

i Facilitating use of mine waste in allied industries.

i Facilitating transfer of technology and development of appropriate technologies in shaft sinking, water management, substitute of timber, exploration/ development and exploitation techniques.

i Facilitating mine inspection.

i Changing inspectors' role from coercion/ policing to facilitating.

i Providing easy and fool-proof mechanism for dispute resolution (boundaries at surface by LA and underground by Inspectors.)

i Providing one-stop shopping for toposheets and other literature at cost.

i Fostering corporate/ cooperative culture for merging small units into big units.

i Transparent and uniform application of rules through digitized cadestre, time bound response.

i Legitimate access to area on paying ren t.

i Harmonizing relations among stakeholders by taking them on all forums and committees.

i Review, refine and rationalise taxes and bring them under one umbrella.

i Include mine operators in district management, specially in mining areas.

i Establish institutions/ academies for professional, technical, managerial and business courses for all.

i Providing a candid forum of chambers of mines at regional as well as federal level.

Safety, health, welfare

Mining is inherently a dangerous and rough profession. It requires a very high degree of discipline to eliminate danger. Here safety is regulated through Mines Act 1923 and its subordinate laws. However, despite statutory protections, accident controls are not effective. More and more workers are abandoning the profession.

Keeping in view the alarming situation on safety and also to make the system effective, following measures are suggested:

?Enhance safety measures with a target of reducing accidents by 1% yearly.

i Run training and skill development programs

i Facilitate mine owners on using machinery and safety equipment and in rescue and recovery.

i Undertake withdrawal of underground samples for checking on environment Keep testing safety equipment and gadgets

i Suppress spread of occupational diseases by cross matching engineering and medical controls underground.

i R&D for finding substitutes to mine timber

i Suppress ingress of water in mining areas

i Facilitate mine owners on use of explosive, electricity and boiler

i Undertake labor welfare programs to suppress migration and improve quality of life.

i Take measures to safeguard against abandoned and orphaned mine sites against risks to environment, human health and safety.

Displaced populations

Underground mining poses very little environmental/ ecological threats. On the contrary, open pit mining or open cast surface operations involve dislodging massive volumes of rocks. This has a destructive sequence followed by refilling of pits.

Mining generally occurs at isolated locations and barren lands. Very few persons are therefore displaced even if exposed to open pit mining. Compared to dams/ canal or other industrial projects, mining is habitat friendly.