"Annex 2 SNF opinion
2022-06-21
Target M 1573-20
Second opinion for Talga's graphite mine application dossier
Amalina Natur- och Miljökonsult has on behalf of people in the local community in the Vittangi area carried out a review of a couple of documents regarding Talga's application for a graphite mine at Hosiorinta/Hosiojärvi, i.e. Nunasvaara södra (aktiblaga 19 and 115).
Amalina Natur och Miljökonsult is a nature conservation consultancy founded in Luleå in
1999. The company undertakes nature conservation assignments over large parts of
Sweden. It is run by Jan Henriksson, who now has over 30 years' experience of nature
inventories in Norrbotten. Jan has specialist expertise in forest ecosystems and has
performed many nature value inventories according to the Swedish Standard (SIS 2014).
Second opinion on the Nature Value Inventory
One of the supporting materials in the application is a nature value inventory, file
appendix 19. Nature value inventory 2015-2019 at Hosiorinta (Nunasvaara), Kiruna
municipality. On behalf of Talga.
According to the natural value inventory report, it is made in accordance with the
"Swedish Standard (SIS 2014) with the addition of Natural value class 4. It will be carried
out on 10-11 June 2015. In 2019, a nature value inventory was also carried out along the
gravel road that leads to the area.
Amalina notes that the natural value inventory is deficient and deviates so much from the
requirements of the standard that it can NOT be considered to have been made according
to the standard.
The main shortcomings are:
• Too little time for inventory in the field
The inventory area (for the area inventoried in 2015) is just under 700 hectares.
Using two days for field inventory, i.e. 350 ha per day, is too little.
• Missed natural heritage sites
According to point 0.3 of the standard, the purpose of an NVI is "to identify and
delimit the geographical areas in the landscape that are of positive importance for
biodiversity and to document and assess their natural value." Point 4.3.1 states:
"The field inventory shall include all potential natural value objects identified in the
preliminary work. The surveyor shall also search the survey area and look for
additional natural value objects that may have been overlooked during the
preliminary work. Each part of the inventory area should be visited on site, except
for areas that can be easily surveyed and assessed from a distance or in current
surveys.
aerial photographs and which clearly lack positive importance for biodiversity... and
'The field inventory shall be sufficiently accurate to identify all
geographical areas of positive importance for biodiversity down to the
minimum mandatory mapping unit (see Table 1). These areas should be recognised as
nature value objects. All natural value objects that can be identified from the results of
previously conducted relevant inventories should also be delineated, regardless of size.
Smaller objects that the operator discovers and that can be reported without
significant additional work should also be reported."
The NVI reports 12 natural value objects. Already after Amalina carried out a few
minutes of remote analysis (i.e. map and/or aerial image interpretation), it was
found that there were a number of missing Natural Value Objects, which was later
verified by a couple of short field visits. In total, around 30 relatively large areas
missing from the NVI have been identified. These are located both within the
operational area and along the road from the E45 motorway to the investigation
area.
It is particularly noteworthy that in principle no natural value objects have been
presented within the operational area itself. This is in spite of the fact that there are
marshes/swamp forests without traces of drainage, rich in old trees and dead wood,
i.e. environments that are in principle completely intact. Neither Lake Hosiojärvi nor
the m a r s h l a n d immediately north of the lake have been classified as Nature Value
Sites.
Since the NVI has the addition of Natural Value Class 4, in principle all the following
biotopes must always be included as NVOs:
- Marshes/wetlands
- Mudflats/ponds/ lakes
- Older forest stands
- Sand environments
- Streams/rivers/rivers
•
Deviation regarding protected species
According to paragraph 2.16 of the standard, a conservation species is "a species
that indicates that an area has natural value or is itself of particular importance for
biodiversity" and is clarified as: "Conservation species is a collective term for
protected species, red-listed species, typical s p e c i e s , responsibility species,
signal species and keystone species. In this standard, however, keystone species
are handled separately and are thus not included in the concept of conservation
species.".
Amalina's assessment is that the NVIN focuses entirely on protected species and
red-listed species. The Swedish Forest Agency's signal species do not seem to have
been used at all.
•
Too few encountered conservation species/ sites for conservation species
The short field visits that were carried out quickly established that there are plenty
of habitats for red-listed species that are missing from the NVI.
Four previously undiscovered red-listed species were noted: dark coal lichen (NT),
short-shafted spike (NT), white-shafted black spike (NT) and blue-grey black spike
(NT) were found.
It is noteworthy that most of the sites now identified are within the operational area.
Amalina Natur och Miljökonsult's assessment is that there should be 100s of
undiscovered habitats for red-listed species within the inventory area.
It should be noted here that an in-depth species inventory focusing on red-listed
species was carried out on 27 September 2018. This inventory must therefore be
considered insufficient.
• Missed Natura 2000 habitats
Paragraph 4.3.1 of the standard states: 'The field inventory shall identify any Natura
2000 habitat types that exceed the minimum mandatory mapping unit (Table 1) but
they do not need to be delineated'.
In general, information on various Natura 2000 habitat types is lacking in the
NVI. Among other things, Amalina has noted that at least the following habitat
types occur in the area: 9010 (Western taiga), 7140 (Open bogs and fens), 7230
(Reed beds), 3160 (Bog lakes).
This is particularly important in Lapland, where there are many Natura 2000 habitats
outside protected areas. When classifying the biotope value of a nature value site,
which is used to determine the area's nature value (class 1 - to class 4), the presence
of Natura 2000 habitats is one of the assessment criteria. An adequate Natura 2000
habitat type means that the biotope value of the area must be classified as at least
significant. This in turn means that the area falls into one of the natural value classes
1, 2 or 3.
Comment on Annex 115
A quick perusal of Exhibit 115 revealed several details that were not correct. Here are two
examples.
Tallbit
Chapter 3.1 states: "Of the breeding species that occur ... the ... pine beetle ....
strong national, regional and local populations."
In the most recent red list, the pine marten is listed as vulnerable (VU) due to a severe
population decline. It is not true that the species has a strong population, although the
species still has its strongest foothold in Torne Lapland, it is far from common here.
It goes on to say "What these species have in common is that they do not have particularly
stringent requirements for their breeding sites but accept all kinds of forest and/or wetland
areas".
The species' species fact sheet,
https://artfakta.se/naturvard/taxon/pinicola-enucleator-
102125 states:
"The pine grosbeak breeds mainly in old, moss-rich coniferous forest with
elements of birch and grey alder and usually with a rich field layer in the form
of lingonberry and blueberry bushes. It occurs from northern Dalarna and
northwards through the inner parts of Norrland, northwards to northern
Norrbotten - Torne Lapland.
The area of regular occurrence has been greatly reduced and 90% of the
population now occurs in Norrbotten County. The species is estimated to have
declined by 25-75% over the past 30 years, a decline that has continued over
the past 10 years. The population's rate of decline is estimated to be greater
than at the time of the red listing in 2015."
And
"During the 20th century, the southern limit of the pine beetle's known
distribution has continuously moved southwards. However, there is no direct
reason to believe that this is a real expansion, but probably the species has
previously
escaped attention and was simply overlooked in large parts of the country. It is
actually more likely that the species has declined during at least the latter part of
the 20th century as a result of increased encroachment by modern forestry,
which in many cases has completely destroyed
good nesting environments,
mainly in the form of primeval coniferous forest stands."
This means that the pine beetle in no way accepts all kinds of forest habitats but is more
or less linked to natural forests.
Tjäder
Chapter 3.1 states: "Of these 49 species, ... capercaillie ... is not affected by t h e planned
extraction of graphite ... as the habitat is not the species' natural breeding habitat."
The species' fact sheet states: The capercaillie is a distinctive coniferous forest bird that
mainly occurs in forest areas larger than 300 hectares where there are enough suitable
habitats for it to feed throughout the year. The species prefers mature sparse or open forest
with elements of aspen and a dense field layer of blueberry bushes in a mosaic with swamp
forests, marshes and other small wetlands.
The capercaillie mainly occurs in areas with a large proportion of mature, relatively sparse
pine forest.
that is at least 30 years old, and preferably at least 60-70 years old. It avoids large clearings
and other open areas. Swamp forests and marsh edges are very important environments,
especially for the hens and chicks. The hens raise the chicks
in areas with good access to
shelter and food in the form of insects, usually in areas with a mosaic of moist
blueberry spruce forest, marsh edges and swamp forests. However, birds of
different sexes and ages utilise different environments at different times of the year.
That there would not be marsh edges and swamp forests suitable for capercaillie chicks is
directly incorrect. During field visits on 2022-06-18, it was found that such areas exist,
not least in a stretch in a west-east-northeast direction about 200 metres north of Lake
Hosiojärvi.
Summarising conclusion
The completed natural value inventory has major s h o r t c o m i n g s . The deficiencies are
s o extensive that our assessment is that it cannot be used as an adequate basis for the
environmental assessment. There are so many unreported natural value objects and s o
many undiscovered occurrences of conservation species (including red-listed species) that it
is not possible to adequately assess any conflicts between natural values and species
occurrences against the planned activities."
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Now I've made so much effort with the layout and he still messed it up withr.
