ENVIRONMENTAL PERMITTING AND COMPLIANCE FOR MINE SITE DEVELOPMENT IN UZBEKISTAN AND THE CIS

摘要

Mining project development, permitting, environmental regulatory and compliance issues in Uzbekistan and the CIS are every bit as complex as those in the western world. The vast array of environmental permitting, monitoring and reporting regulations for mine project development and operation in the CIS are based on existing Soviet environmental regulations and policies which have remained in place after these countries gained independence from the former Soviet Union. The approach to mine project permitting in the CIS differs from the western world. Similar pre-feasibility, baseline data collection, and environmental monitoring requirements allow the project proponent to coordinate preparation and submission of documentation to support project permitting for Uzbek regulatory requirements with environmental requirements imposed by financial institutions and western environmental compliance structures. Implementation of generally accepted western environmental best management controls and monitoring into mine design, construction, and operation will not, however, ensure automatic compliance with Uzbek environmental regulations. Uzbek environmental compliance requirements that differ from western requirements include: 1) development and maintenance of an environmental database constructed specifically to address annual, biannual and quarterly statistical reporting requirements for emissions of "environmental pollutants" from the facility into air, surface water, ground water and soil; 2) preparation and submittal of specific permits for water utilization, hazardous waste storage and disposal, landfill construction and operation, and stack emissions inventories; and 3) procurement of approvals from the Uzbekistan State Committee for Nature Protection (generally analogous to the US Environmental Protection Agency). This paper outlines and summarizes the regulatory requirements for mine site permitting and the procedures for environmental monitoring and reporting during mining operation in Uzbekistan and the CIS.