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Episode 4: Strategic Projects and UNFC

Episode Details

Featuring: Ben Lepley – SLR Consulting Limited

This episode will discuss the practical application of UNFC to raw material projects. We’ll specifically look at Strategic Projects – a cornerstone of the CRMA – where the use of UNFC is mandated.

Guest’s Background

Ben Lepley

Ben Lepley has over 12 years’ experience across mineral resource geology and ESG, specialising in embedding responsible environmental, social and governance practices into mineral exploration and mining projects, alongside advancing geoscience education and industry capacity-building.

Episode Transcript

A transcript of the episode is available below, should you wish to read along.

Alex Fuentes In this episode of the UNFC podcast, we’re going to be drilling down into the practical application of the United Nations Framework Classification for Resources or UNFC with the European Union’s recent Critical Raw Materials Act, a UNFC assessment’s become mandatory for companies seeking to have their project as designated as Strategic.

Chris Stockey To help us navigate this evolving landscape, we’re very pleased to have Ben Lepley from SLR Consulting with us today. Ben’s expertise with UNFC has been helping clients with their CRMA Strategic Project applications, which of course involves this component. We’re thrilled to explore this unique insight with Ben.

Welcome to the podcast.

Ben Lepley Yeah, thank you both and it’s good to be here. So yeah, Ben Lepley and I’m from SLR. As we said, I was a geologist for a long time, working in resource geology for mining companies and exploration companies. And then I saw the green light and moved towards the environmental, social and governance ESG world.

And I’m helping exploration mining companies still, but look at their environmental and social impacts and, how to manage them.

Chris Stockey Awesome.

And I guess through that finding of the green light and everything along, you know that particular and very key element of the metals and mining sector, how did that bring you to the CRMA and UNFC?

’cause I guess that’s some of the first circles that you and I met in personally as well.

Ben Lepley Yeah, so obviously through my ESG work we have to look at legislation and the CRMA was a big one that landed that we knew it was gonna have quite big impact on exploration and mining companies, particularly in Europe, but also worldwide.

And in terms of the UNFC side of things, you know, that’s something I’ve always been interested in, but it’s always been in the background because very few companies, if any, actually were using the UNFC to report and classify their resources and reserves, particularly in the mining world.

So I knew about it, but it was never really something we used. But it was only until the CRMA came out and everyone said, “oh, we’ve gotta use the UNFC now”. We thought, well, we better read up on what that actually is and how we actually implement it and help our clients through that, that complicated world.

So yeah, that’s how we got into it and we’ve managed to help a few of our clients to navigate the Strategic Project application process, which was quite tricky at times and particularly ’cause it was the first round and maybe they had a few teething issues and complexities of the application form, et cetera.

But eventually we got there.

Alex Fuentes How did you find and experience going through that with your clients then?

Ben Lepley The actual process itself of writing the form was extremely difficult. Because it just for technicalities on the way the form was created was awful. But the, you know, the information that was they were asking for was not difficult.

And, you know, our clients have that information to hand and we were able to synthesize it into the to the relevant parts. I think some of the difficulties were trying to work out exactly what they wanted because you can read all the words and you can understand the words, but what is that they’re actually trying to get out of you?

Was the kind of nuance that we were helping with. ’cause you know that they were very capable of writing this themselves, but you had a defined character count, for example, which meant you could only write a certain amount. You couldn’t put any images in, you couldn’t put any tables in. So you had to explain with words.

You know exactly how you’re gonna meet the requirements they’re asking for a Strategic Project. So that was a real challenge really. And it turned out in the end, the, of the three companies that, that I helped overall none of them got approved unfortunately for various reasons. But there were some key themes running through it, which I’m sure we’ll touch on.

Alex Fuentes Can I quickly dive back because I think actually we should possibly go over what exactly a Strategic Project is in the context of CRMA. Could you flood some light on that?

Ben Lepley Yeah. So a strategic project is a project that’s deemed a flagship project for the EU in terms of being able to fulfil a gap that currently the EU cannot or does not have the ability to fill at the moment.

So these are generally projects that are. In advanced exploration stage and nearly ready to go. But have got a few hurdles to get through and they’re ones that are gonna contribute materially. So they’re gonna, they’re gonna provide a significant amount of metal for a specific critical mineral.

And they’re also gonna be completed using all the, you know, environmentally and socially friendly methods. And, you know, that’s a key theme running throughout the CRMA is that projects need to be developed sustainably which is great to see, obviously. So yeah, really it’s about fulfilling gaps that the EU doesn’t have and trying to wean ourselves off some of the other sources around the world, which maybe tend to dominate.

And it, it depends on the commodity as well. ’cause something like rare earth elements, which we don’t really have any operational mines in Europe, you know. Even if it can contribute a small amount of that, that raw material, that is significant. Whereas something like copper, which maybe we have a lot more of and we have operational mines, you know, it needs to be something quite significant to, be considered as a strategic project.

And I guess we saw that, you know, with a lot of lithium projects being being granted a Strategic Project status. ’cause again, we don’t have the supply within Europe at the moment.

Chris Stockey Yeah, absolutely. And I think you touch on, you know, you touched on the critical minerals point. There’s also this wonderful world in the critical minerals list to the EU of the strategic minerals, which is different from a Strategic Project even though a strategic minerals list can be looked upon.

You know, there is some, within the Strategic Project, it’s a subset of our critical minerals. You touched on there were challenges in the form. It’s you know, a brand new process. It is a teething issue. Ultimately, I think everybody involved you. Is rarely, is relatively understanding that this was a whole new process for a whole new body and everybody is an actor involved, but of course fringing on industry, there’s an element of people are used to their familiar processes.

What, you know, you mentioned on just the formatting of the document, but in terms of content, what were some of those points that were really hard to speak to within that?

Ben Lepley I think some of the key things, you know, particularly for the projects I was working on, again, which were more advanced exploration they didn’t have a lot of things in place and they couldn’t prove it.

So, things like offtake agreements, which were considered to be something, not a requirement to have a signed contract in place, but something where you have talks ongoing, or you know, you have a list of potential off-takers. So that was quite hard to demonstrate. But also some of the sustainability criteria.

So the sustainability standards that it requires you to follow because their expiration projects, they’re not as geared up towards exploration projects as they are operations. So things like IRMA, Towards Sustainable Mining, Copper Mark, et cetera. They’re really geared towards operations.

So when you are trying to convince the panel and the experts who are reviewing them that you have everything in hand, and yes, you will in the future adhere to all these sustainability criteria is difficult because they haven’t signed up to one at that present time. They’re not sure which one is most relevant at the time.

Those are probably some of the key challenges, I would say, as well as just some of the unknowns and the whole point of this really was of Strategic Projects is to help with the permitting process, which as everyone knows, can take a horrifically long time. So part of it was trying to fast track projects through the permitting process.

But you had to really try and explain in the form how long things are gonna take, why you needed Strategic Project status to help you advance those timelines. And that’s all about the capacity of that government or the authority in that country. You know, in their ability to actually process the applications and have the relevant experienced people.

So in some cases it’s just a big unknown which is one of the reasons they were applying in the first place. So, a few challenges there.

Chris Stockey That’s quite an interesting point about there’s that kind of like jurisdictional coupling and decoupling going on in this, in the permitting process and in those sustainability standards as well.

You know, data granularity can be a big part of specific standards. And that can really feed into that kind of maturity journey, but data granularity isn’t necessarily representative of sustainable performance in many ways. You know, that, you know, naturally we love a, we like to understand how, you know, with metric tracking, but it’s not everything with respect to it.

In terms of the UNFC piece fitting into the Strategic Project application, because that’s part of both the application process and then the kind of monitoring element. What was the experience of taking clients through some of those processes? Because again, this is something that’s new to a lot of the minerals sector, certainly the industry side of it.

What was that like?

Ben Lepley You know what, I obviously had to educate myself before the client, which was, as long as I was one step ahead, it was okay. But going through all those documents, and really it was about converting their existing reporting of mineral resources and reserves into UNFC. So using some of the ones that are used widely.

So the JORC code, CIM requirements in Canada, SAMREC in South Africa, et cetera, PERC in Europe. So if they already had an in, the cases that I was dealing with, they already had reported resources and reserves that we could use the basis, you know, that it was then going through that bridging document that was created.

Going from the, what are termed as CRIRSCO umbrella of organizations, which includes all those I just mentioned. And bridging between that and UNFC. And when you boil it all down, you know, there’s, there’s a lot of similarities, obviously. It’s just some of the terminology that’s different and, there’s things like, you know, degree of confidence in your resource and what’s in the ground that’s directly translatable. There’s the technical feasibility side of things, which is, again, directly translatable even though it’s, you know, slightly different terminology. And then I guess the key thing that’s different is the E axis which I think most people were quite concerned about.

But the UNFC does give a lot of good guidance and it gives you criteria and sub criteria in order to assess which kinda level you’re at. And it was quite prescriptive in that regard. So unlike some of the other codes actually, I think it’s a lot more prescriptive in terms of what you actually have to report on and how you convert things from the existing JORC code or whatever into UNFC terms.

Alex Fuentes That’s a really fascinating insight I feel into, I guess the three axes F and G being the technical feasibility and the geological knowledge and the eas-, the, I don’t wanna say easy to map, but like much more simple and clear possibly to map between CRISRCO codes and UNFC, but then you’ve gone onto the E axis, which is it the dreaded E axis perhaps?

Yeah. How did you sort of feel the balance was there between E, F and G and I’m very much in this case focusing on where does E fit and how do- where are you mapping that from? Or are you having to generate that from scratch? That information required for E?

Ben Lepley Well, yeah, that, that’s where it does bring in a lot more information from other sources. So your JORC report or your report of resource and reserves will have a certain amount of information, but it probably won’t have everything, thinking about things like social license to operate, you know, that a key part of it. You know, does your project have acceptance in the local area. These are topics that, that should be assessed in those reports anyway to some degree, but they’re not quite as obvious and blatant as the UNFC tries to make them. So yeah, as well as the environmental and social you also have the economic side of things and that can be, that should be, again, included if you have reserves in particular, but for some of the ones that only have resources reported, you might not have the depth of knowledge on the economic side of things which may impact your ability to come up with the correct kind of E number.

I think it just, one thing as well is that on going back to the form, and I don’t wanna tear it to pieces, but one of the most annoying things was you could only put one categorization in for the entire project. Right. And for any resource or any project out there that has resource and reserves reported, there are often more often than not, there’s several categories reported. So this could be, you know, measured in the case of inferred, probable and proven for the reserve side, but you had to choose one which was your one that you put on the form, right? And you could you also had to include a UNFC assessment form separately from the actual application form, which did allow you then to go into a bit more detail, but I had a few communications with the EU about this or the European Commission, and they said, yeah, basically just whatever’s the most dominant one go for that. So it could be that you have a small amount of measured resource which is the highest level of confidence you have.

And then no indicated, and then loads of inferred, for example. And in that case, you’re kind of stuck thinking, well, it’s quite unfair really to call it all inferred, even though that’s the dominant one. But could we call it somewhere in between? Maybe, you know, and that was one thing that, that caught us all out, I think, was the ability to not have that.

But going back to the actual, you know, process of selection of Strategic Projects. The UNFC was only used as a kind of, as a baseline, like here you are now. I think you mentioned earlier, Chris, you know, it’s something that will be monitored in the future and obviously projects change as more data becomes available, as the economics change, as the environment, social environment changes and projects will be expected to move through different UNFC categories as a result.

So it is just used as a basis, and even if you had a low score according to the UNFC in your application form, it wasn’t then as if you would be kicked out for, for having, you know, a project that was never gonna get anywhere, because that’s just the current status. You would have to explain how are you gonna get to the next steps?

And that was another part of the form was really understanding, yes, here we are right now, but here are the next steps to get to the next level. Be that completing a feasibility study to get the F axis up. Be it doing a lot more stakeholder engagement and advancing your environment and social impact assessment to get the E score up for example.

Chris Stockey That’s really interesting point. So there’s actually, there, there’s a member they used to work for the UNFC that I’ve always enjoyed talking to about this. And there were other people who first sort of really introduced me to the complexities of UNFC, but in their eyes they used to describe UNFC as a tool.

That’s really a scenario analysis tool. And I always end up calling it snakes in three ladders in 3D which is essentially, you know, part of their view of how the tool could be used effectively is this not just the progress monitoring of a project, but to start thinking about some risk management perspectives in terms of what is it that could happen to knock you down categories and what could accelerate, you know, your snakes and what could accelerate you up them, your ladders.

I thought it was quite interesting the way you kind of touched on social license and, you know, others all talk about, social acceptance or shared value creation opportunities, that kind of social element of sustainability. And maybe they’re being everything talks about quite neatly and as if it’s a very tangible thing where it can feel quite difficult to articulate the social element of sustainability sometimes do, as I’ve just proven in that slight pause there. What do you- are there any pieces of guidance or kind of, you know, broadening it out from UNFC or things that you’d like to see integrated in, into that conversation to see it become more of a part of the E axis or easier to integrate, or even just easier to articulate within it?

Ben Lepley You know, there’s a lot of standards out there that are being used across the board, and I mentioned a few of them already.

You know, IRMA, and TSM and whatever they have best practice in there and they have what they’re expecting you to have, if you want to be a high achiever, and if you want to get a good kinda mark in those standards, as it were. So there’s so many different standards out there, which can help a company in terms of what’s expected as a best practice.

And I think across the board. You know, it is improving in terms of companies understand, in order to get their mind permitted, they’re gonna have to put a lot more effort into talking with communities and getting that social acceptance included and , that was one of the main criticisms that, that I’ve seen across, you know, across some of the NGOs and other groups who are concerned about the CRMA was the fact that if you become a Strategic Project, do you get precedents over that land, for example?

And I’m thinking, ’cause a few of my projects I worked on up in Northern Sweden and in Scandinavia, you know, where you have indigenous people living there, the Sámi. The Sámi peoples, you know, they were one of the very vocal groups who was saying, well, you know, “we have access based on, you know, very old legislation that we are allowed to freely, you know, to roam these lands with our reindeer, for example. Will these projects now be getting precedent over our activities just because they become Strategic Projects?” And that’s a real deep concern. And one that I don’t think has been fully addressed since then. So that’s something I’m quite cautious about in terms of, you know, celebrating Strategic Projects.

And we, you know, we’ve seen some of the other projects, I won’t name them, but there’s been some huge social kickback against some of the projects that are now approved. And how are they going to navigate that? You know, that landscape where there’s massive social opposition to certain projects.

And just because it’s being deemed Strategic does not make a difference for the people that live there, you know, so that, that’s something I’m keen to follow. But yeah, I think again, making sure that that there are standards that are being used across the board and make sure those standards are applicable for exploration projects as well as mining projects, as a- would be a key step forward.

Things like environment, social impact assessments, which for most jurisdictions now is a requirement in order to get a permit to operate. The level of quality of those needs to be, you know, standardized or, you know, a certain level needs to be achieved before they can get those status. I think so we’ll probably come onto the challenges of projects outside the EU in a bit, but that’s one of the key challenges I see there as well.

Chris Stockey Yeah, I think you, you raise a point, it reflects the broader CRMA in strategic projects. You kind of called them the flagship of the, the act in many ways. And I suppose they are, they’re a point that everyone saw and really resonated with that. Uh, they’re part of that economic fast track, let’s get into permitting being sped up.

You know, I’m sure the EU wouldn’t, would say that a Strategic Project reflects the opportunity to speed up rather than it, you know, saying it’s a pre-approved project, but it is still something everyone will watch as part of that. Particularly those first groupings come through. Before we go onto the wonderful world of outside of the EU, ’cause as you rightly say, strategic projects aren’t just limited to the EU.

And also we’re talking about UNFC, you know, more broadly to some extent, Alex, I know you were talking about or had some interesting insights from other interviews about different commodities or different applications of UNFC as well.

Alex Fuentes Yeah, I mean, I guess obviously you’ve focused on, I suppose you’ve said they’re all extraction projects are all exploration.

Like do you do you have your thoughts on UNFC’s application to beyond that, talking about, you know, from the, maybe to the refinery stage, different place in the value chain to even secondary raw materials recycling and the like?

Ben Lepley Yeah, so that’s an interesting point and the whole point of the UNFC was to standardize it across, you know, a number of different resources, right? So that is one of the key reasons it’s being used in this context because there are multiple resources and types of material extraction that are being used. So in order to make that under one house, UNFC was really the only tool that had that ability, which is why some of the terminology in it as well is a bit foreign to some mining people because it’s mainly being created with a focus on mainly downstream activities and refineries, like you say, and maybe recyclers as well. So it does just make things harder sometimes for the mining companies. But in terms of, you know, things like refineries, you know, I think that the E and the F axes are very similar in terms of, you know, there’s a project location, there’s gonna be a feasibility of that project that goes up through the different technical readiness levels as they’re called in the UNFC.

And it’s the, I think it’s the G one that’s slightly different in the case of some of these other ones. So what the degree of confidence that you have in creating the products essentially. So that for me, because I’ve never worked in it, unfortunately, I don’t have experience of it, but I’m thinking in terms of if you’re a, if you’re a scrap processor, for example, you know, how do you guarantee the quality and the consistency of the feed stock where’s it gonna come from?

What was the environment and social, you know, attributes of that material. You know, are they from a credible source? Do you know how they’ve been collected and how they’ve been delivered to site, et cetera. So I think that those are some of the key challenges. And the, one of the projects I worked on was actually a tailings reprocessing project.

So it’s, it was slightly different to the normal kind of mining exploration, remit. But it’s kind of similar in terms of you’ve got a deposit in the ground you’ve drilled it out, you kind of understand the size and the scale and the grade of it, et cetera, and then you’re scooping it out and chucking it in a plant , to put it very you know, very simply.

But that was slightly different as a result because it was a, you know, rehabilitating a site, which previously was considered, you know, environmentally degraded because of the deposition of the tailings at the time, you know, didn’t have any lining, for example, you know, so there were potential impacts with groundwater and other environmental pollution sources.

So that was slightly different. And yeah, I guess there, there are for all the different. Processing types and project types. There are different challenges, but yeah, for me that G Axis was the one that I think, how do I actually, you know, go about dealing with that.

Alex Fuentes That’s some great insight.

And yeah the idea of and I guess you mentioned at tailings project, but I feel stuff like this is really, I mean, talk about maybe Strategic Project, as a flagship thing, but I think for a lot of people it’s really looking at this recycling, substitution, secondary raw materials, anthropogenic raw materials.

That’s where I think almost the CMA is most exciting possibly to some people? I dunno. I feel another area is of course, the CRMA has a reach beyond Europe, in fact, in the country we’re all in right now, the UK you can get Strategic Projects in non-member states. What do you think about this development of these non-member states?

Ben Lepley Yeah, it’s, I mean, it, it’s great in terms of, for them they needed it basically, didn’t they? Because everyone’s well aware of the fact that Europe has a defined geology that’s been there for, you know millions of years, sometimes billions of years. There’s only a defined number of projects that are gonna be there, that have been found, and there’s been intense exploration all over the continent.

And I’m sure there are projects that we haven’t found, you know, particularly deeper ones that take a lot more effort to find. But you know, the major projects have probably been found nearer surface anyway, so they needed to look elsewhere in order to make sure some of those targets they set in terms of the proportion of mined material and proportion of processed material meets their targets. So yeah the countries, I think there’s 13 projects that were selected when they’re outside the EU including the UK as well as some other parts of Europe, which aren’t in the EU, but then Australia, Brazil, some Southern Africa.

So some of the key challenges I see there are obviously the control, so the EU doesn’t have control over those countries. So how are you going to ensure that, particularly things like the sustainability criteria are equivalent to what the EU would expect. So things like environmental impact assessments, again, you know, the quality of those ’cause that varies considerably where you are in the world in terms of the requirements of the national legislation. You know, how is that gonna fit in with EU legislation, which is probably more stringent than a lot of those places, although maybe, you know, Australia, the UK might be slightly different to that.

So that’s one challenge I have. And then some of the projects , if you’ve got something in Eastern Australia, I think it is, you’re bringing that material halfway across the world. You know, that’s a long way. So ensuring that the sustainability in terms of things like, you know, greenhouse gas emissions and other pollution along the way, you know, making sure that fits with what the EU wants to see as well.

I think it is a bit of a challenge. And then the key thing I think over everything is permitting. And it’s the same for the EU states, right? That all of them have to completely change their systems in order to fit in with this system. So all the permitting regimes, which generally are years long are trying to get it down to 24 months, I think their target is, to try and get projects permitted.

You know, that two year period is already gonna be challenging for most EU states, and I think a lot of countries are now are desperately trying to work out how they’re gonna do that in terms of capacity, in terms of number of people. Who’s gonna fund it, et cetera. Lots of questions there, but then the same applies to all these other third countries.

So, yeah. Do they have the capacity, do they have the, the, the right training to be able to process those applications in the timeframe required? One of the hurdles that my clients faced, and one of the reasons they were all rejected in the end was the ability to get into production by 2030.

Or around 2030. So that was a key requirement in terms of the CRMA and that was a downfall of lots of applicants, as I understand. Being able to demonstrate you are going to be able to be into production by 2030, and that obviously includes additional technical work environmental, social impact assessment. Again, you know that these things take a long time, but then the permitting part of it as well, and if that’s included, it, it can take a lot longer. So, it was difficult to see that because one of the whole points of becoming strategic project was to expedite, you know, quicker permitting.

So if they’re struggling to, to get the permits already you know, that that was one of their main reasons for doing it in the first place.

Chris Stockey Yeah, it’s interesting you mentioned that ’cause that’s, that feels to many who would’ve not have had that experience going through it. It feels a bit chicken or egg.

It’s basically do have you already got to a position where…

Ben Lepley I wrote chicken and egg down here on my notes? Yeah!

Chris Stockey Do you, so can I just ask ’cause you’ve opened a lot of questions in my head, but did you get that as specific feedback following on from that application process?

Ben Lepley Yeah, so we, we got an assessment report back from them as well as a letter saying, “sorry, you’ve not been chosen and these are the reasons”. And then you got a brief summary of what the experts had fed back. So when the application went in, it was obviously vetted by people in the European Commission. In terms of completeness, and then when it’s… So it’s vetted by the European Commission.

Then it goes onto the expert panel, and then they have. I think it’s something like, ’cause I actually applied to be an expert review and I was actually not able to in the end because I’m not an independent. So I kind of got to see some of the background to this. And you had three days to review each project essentially.

And that would be, there were four main areas that environmental and social, there were economics, there was geology and then there was technical feasibility. I believe those are the four categories. So you had, and then each expert then had three days. So you had this three day review, which I guess is a decent amount of time to get through the documentation, but it’s still limited. And there was no discussion at all between the reviewers and the and the project proponents, which I think is a, another key flaw in the process.

Chris Stockey That’s really eyeopening that level of what, what’s sat behind it? ’cause I don’t think that when the projects list was released, there were a lot of people who went, I’m trying to see if there’s a trend here and what’s been selected and why.

And you know, it led to some degree of discussion of I can’t make sense of it for a lot of people. And I think actually some of that information you’ve just talked about in terms of what the processes behind makes sense, does help contextualize it. And the other word that, as you were talking earlier, you kept saying the word capacity and I think that really resonated with it with this 2030 point you were raising because there are people who have critiqued Strategic Projects and the UNFC role in that as well around that fast tracking of permitting and a concern, very validly that it will lead to rushing. As a result, there’s oversight and that is how in a sector like metals & mining, there can be, you know, really negative repercussions that come out from it. So that capacity piece when you know, is really interesting, both from an EU perspective, other nations as well, about what the traditional permitting timelines are.

I know you kind of alluded to it, would you just mind from your experience telling us what the traditional permitting time lines normally are to really give anybody who’s not familiar with them, that context of quite how much this is a replacement? I know that’s how long’s a piece of string!

Ben Lepley Exactly, depending on which country you are when you’re doing it, et cetera.

I think something like that, on average across the globe, it takes 17 years on average to go from discovery to full permitting if you are doing it continuously. So that is a long timeframe and for something that needs money each year, you know, who is actually putting that money to it? I mean, it’s craziness really the risk involved in mining projects anyway.

But, you know, most projects thinking about. Scandinavia in particular where I do a lot of work in the European context, it’s generally, you know, two to four years can be quite a normal kind of timeframe. ‘Cause you not only have you got things like mining, mining permits themselves and mining licenses, concessions, whatever they’re called in that country.

We’ve also got environmental approvals, which is generally based on the impact assessment. And the impact assessment needs a certain length of disclosure period where that it needs to have consultation from stakeholders, including communities local authorities you know, project workers, et cetera.

And that consultation period can be extremely long the project proponent needs to go back and potentially make adjustments. They might have to reapply even if they’re successful. And we’ve seen that with some of our clients.

They can be appealed and if they’re appealed, that can add another year on, you know, in terms of going through all the courts. And they might be appealed in one court, but then have to, you know, that gets rejected and then passed up to the next level of court, to the Supreme Court. And so it goes on and depending on how much resistance there is, again, from the general public and from concerned stakeholders, that time can really just keep going at infinitum.

Chris Stockey And I think this is an interesting point and it again gets into an, you know, in another episode we had a really interesting conversation with Tom by about this, the difference between what is the point of UNFC Strategic Project application is it’s not necessarily got a role in being entirely investor related, even though of course.

Fast tracking a process as it feels. Of course, it has a massive interlink there, but again, there’s that, you know, what’s UNFC about? What’s the strategic project about? Is that operating at different policy level to where traditional resource, reserve estimates have been going? And it leads to this almost what’s the classification about, and who’s it for? Almost, in terms of like, who is the stakeholder being considered in, in these decisions?

Ben Lepley Because yeah, I guess generally, when, when you’re doing CRIRSCO related, assessments, it’s all about the investor. And really that’s what you’re trying to do it for is to show people, here we are.

Here’s our project, here’s why it’s wonderful, please invest in our project. So yeah that, that’s definitely from the CRIRSCO go side of things, the main focus. But yeah, the UNFC, like you say is slightly different.

Chris Stockey Absolutely. I think. Yeah. I wonder, would you say, ’cause in my head, listening to yourself speak, we’ve got, you’ve touched on that breadth of different standards, processes, different things going on all around the world, and we are almost trying to, we’ve got different materials, we’ve got different resource codes, we’ve got different permitting processes, we’ve got different timelines, we’ve got different stakeholders. We’ve got different elements of the value chain.

Do you see. UNFC is having any potential role in the ability to standardize or unify and bring that together in a systems kind of approach, or do you think that’s too far for the wonderful world of UNFC.

Ben Lepley I at the moment, I just don’t see why companies would. Because the codes are all changing and being updated, and a lot of that is around the ESG aspects and sustainability aspects, because quite rightly in the past you know, it hasn’t been considered as important, but now it’s being recognized that, oh, actually we do need to beef this up a bit. So when you report resource reserve, you do need to now have a lot more information about those aspects. So I think that was one thing where it was lagging behind, but now it’s maybe catching up.

And you’ve gotta remember as well that again, that these companies are using specific codes to report with on specific in specific jurisdictions. So if they’re listed in Toronto or in Canada somewhere, you know, they have to adhere to those rules over there. So they have to report using the CIM guidance and form NI 43-101 as it’s called.

So, if they were gonna do UNFC, they would, that would be additional, they would have to do both. So I don’t see how it can take over that, particularly the exploration and mining world when these companies already have to report, if they’re listed in certain areas they have to report using one of those codes that already exist, but hopefully.

Now we’ve had a bit of exposure to it and like probably most people, you know, we haven’t used UNFC on a specific project basis. And I know the BGS and, you know, some of the other geological surveys across Europe have used it in terms of trying to assess the countrywide resources in the ground and get an assessment of the varying qualities of projects.

And I understand it from that perspective, and I think that’s one, one area it probably will continue to be used. Because it does have you know, the standardization, and it’s a lot more prescriptive, as I said earlier. But for individual projects and exploration and mining companies, yeah I don’t quite see it happening just yet.

Sorry, UNFC!

Alex Fuentes No, that’s fine. I think that this, we are all about transparency and being honest and frank here, and I don’t think we wanted to have some sort of hive mind of group think so have having these actual very realistic perspectives is lovely. Frankly but like, honestly from, I dunno, did you, do you think that it will improve?

Do you think things will actually go forward then because it’s clearly, as you say, early days, it’s not really being applied to, at a project level currently, can you see it evolving and adapting? I’m trying to, maybe, I’m not trying to force a bit of optimism in here, but there is, you know, there is a potential, I think a way forward here and I think it’ll be interesting to see how we get to, let’s say 2030, which I think you mentioned the timing of it all quite bit.

And I think that’s, I mean, that’s big for the Sustainable Development Goals and big for the CRMA.

Ben Lepley I think it’s gonna depend on the success of the CRMA and the Strategic Projects. ’cause if they’re a success, you know, the UNFC will go hand in hand for that. And people will start to recognize as it, as a, something that, that could and maybe should be used for a lot more projects and particularly with the standardization across the different, you know, mineral extraction techniques and, you know, refineries recycling, et cetera. Being able to standardize for a country to understand its resources. Again, that’s why you know, I guess at a government level is a lot more useful to them. But yeah, I think if the CRMA does.

Is successful and starts to see these Strategic Projects kick forward and really start to make inroads into the supply deficit, which is the whole point of it again, is, you know, trying to wean ourself or wean the EU off of China and other dominant sources. If it is successful, then yeah, maybe the UNFC rides that wave and becomes successful as well.

That’s positive!

Chris Stockey And I think thank you so much for joining us today, Ben. ’cause it’s been really insightful to get that industry perspective particularly, and that’s something that’s been missing from these conversations. So I think there’s nothing left to do but to say thank you so much for coming on and sharing your perspectives.

We’ve got work to do in this space, but it’s a process and looking forward to seeing how it evolves. But thank you so much for coming on.

Thank you so much for joining us on this episode of the UNFC podcast, exploring all of the practical implications of actually submitting Strategic Project applications with Ben Lepley. In the next episode, we’ll be exploring the CRIRSCO and UNFC relationship with Ed Sides. See you on the next episode!

Matthew Grimshaw The views, thoughts, and opinions expressed by guests or contributors on the podcast are solely their own and do not necessarily reflect those of the hosts, Satarla, and Critical Productions.

Any statements made should not be interpreted as endorsements or official positions. Listener discretion is advised.

UNFC Podcast Episode Resources

General resources

Episode 4 resources

CRIRSCO (Committee for Mineral Reserves International Reporting Standards):

The Copper Mark

The Initiative for Responsible Mining Assurance (IRMA)

Towards Sustainable Mining (TSM)

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