Monday, 5 May 2025

Regulatory outcomes and the mining sector: implications for Indigenous interests

 

Whiles I am a beggar, I will rail and say there is no sin but to be rich;

and being rich, my virtue then shall be to say there is no vice but beggary.

Henry IV, Part 2, Act one, Scene two.

 

New research published in the Journal Resources Policy (link here) examines the impact of the various elements of the overarching institutional prerequisites for mine approval via a comprehensive analysis of 409 mining applications subject to regulatory approval in Australia between 2000 and 2020.

The authors, Lisa Nicole Mills, Jennifer Stewart and Graeme Auld are resource policy experts based in Carleton University in Ottawa. The Abstract of their paper states (inter alia):

In this paper, we examine the pressures which affect business risk through the multiple dimensions of the “licence to operate,” in the case of federally regulated mines in Australia. Studying 409 mining applications that were under regulatory review, approved, or withdrawn between 2000 and 2020, we use competing risk hazard models and linear regressions to examine how measures of business risk (longer times in review and more conditions) and choices to withdraw are affected by: the attributes of the mine, competing rights claims and land-uses, levels of oppositional mobilization, changes in political parties in power, and market prices. We found that new projects, and those that triggered an independent assessment of their impact on water, were likely to experience longer reviews. Mines where agriculture was the competing land use also faced longer reviews, and mine proponents were more likely to withdraw their proposal. Contrary to our expectations, the mobilization of opposition to a mine was associated with faster time to approval, but also a higher number of conditions.

In section 2.1 of their article, the authors identify three broad elements of the regulatory process governing mine approvals in Australia: the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) which applies to nine potential matters of national environmental significance; the processes required to obtain secure mining title which are state based; and the provisions of the Native Title Act which apply to lands with either determined native title, or subject to claim. The empirical analysis undertaken was limited to processes under the EPBC Act.

The analysis considers interactions among licences to operate through the lenses of civil society mobilization, electoral and party politics, and competing land-uses as these combine to affect the business risk experienced by mine project proponents through the EPBC Act regulatory approval process and outcomes. I don’t propose to attempt to summarise the details of the statistical analysis and refer interested readers to the article itself. Not will I focus on the outcomes apart from the one of most interest to readers of this blog, namely in relation to Indigenous claims (emphasis added).

A third insight from the analysis concerns the role of competing rights claims and land-uses. The data indicated that Indigenous land rights claims did not have any bearing on the length of time to approval, withdrawals, or conditions; indeed, proposals to mine on land without any claims tended to take longer to be approved than those on land with claims: but this association was not statistically significant.

Further, the authors found that:

Higher levels of civil society mobilization pushed regulators in apparently different directions. When mobilization was high, more conditions were imposed upon the mine's operation, a finding that is consistent with literature that suggests social pressure may increase regulatory requirements… However, mines that faced mobilization were not subjected to longer approval times; and, in the case where mines faced opposition from actors who would be negatively economically affected by the mine's development, approval times were shorter.

The overarching conclusion of the analysis (references removed) is that

Unlike early work on social licence to operate that conceptualized social pressures as working in synergy with regulatory processes, often leading to higher requirements or even beyond compliance behavior, we provided evidence that regulatory licences can serve as a trump card to advance a project. In this respect, our analysis offers caution for those that view economic licensing [ie investor approval] and social licensing [ie community and social approval] as substitutes for, or at least complements to, regulatory licensing.

For my purposes, this research offers at least preliminary or provisional evidence that longstanding tropes embedded within Australian politics in relation to Indigenous land rights are mistaken and wrong. Those tropes, which underpinned the rationale for denying Indigenous interests a veto over mining on their lands, were that land rights would be anathema to mining development and indeed to the nation’s economic security. The experience of the past two decades is that those fears have not eventuated. That experience strongly suggests that the promulgation of those fears was designed to benefit the minerals industry and to maintain the structural exclusion of Indigenous interests within Australian society.

Having said that, hidden behind these issues, and embedded in the current institutional architecture of native title and land rights, are a set of public policy issues related to the equity of the current financial policy frameworks which

(i)            privilege native title holders of land which lies above mineral deposits over those Indigenous groups who do not have access to native title, or those native title holders whose land does not lie above commercially viable minerals; and

(ii)          with only some exceptions, fail to ensure that the funds which flow to native title holders and Indigenous landowners are disbursed within frameworks which privilege accumulation over consumption (or to put it another way, which fail to ensure that future generations will benefit from the compensatory negotiations undertaken by the current generation). If there is any merit in the arguments of many scholars (and Indigenous activists) that colonialism has ongoing impacts, and that intergenerational trauma is a reality, then any argument against intergenerational benefit provision for beneficial payments arising from mining on Indigenous land disappears.

These are public policy issues because it has been governments that have devised the institutional arrangements that underpin the implementation of native title rights and land rights, and while the issues identified above may not have been intended or even recognised, they are now of very real significance. I use the term ‘hidden’ because these issues have been largely submerged in the public debates over Indigenous land rights over the past five decades. With the turn to economic empowerment as an overarching priority in the Indigenous policy domain (link here and link here) it is time that these issues were given greater profile and attention by policymakers and Indigenous advocates.

 

5 May 2025

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