In the era of regional autonomy in the field of mining still occurs so frequently Exploration IUP issued by local government was the first who conceived and carried out by holders of IUP is looking for consultants who can prepare environmental impact analysis. compilers of EIA consultants in Kalimantan was quite a lot, but consultants who really understand about mine I think it is still small. The evidence that supports the truth of that statement is quite a lot and even the reality that many of the EIA document has been approved by the commission Amdal District.
Back to the question of when prepared EIA document, I am often heard and witnessed a fairly lively debate both at district and provincial commissions Amdal. The EIA consultants in Kalimantan generally many argue that EIA documents can be arranged at the beginning or end stages of exploration activities. Opinion that it is not far wrong if we only based on existing regulations in Indonesia.
Decree of the Minister of Environment No. 17 of 2001 on Types of Business Plan and / or Activity equipped with Mandatory Environmental Impact Analysis that is currently been revised by the Decree of the Minister of Environment No. 11 Year 2006 states that the mining areas mandatory for EIA include general mining business with the permissions of (KP) the extent of> 200 ha.
In such provision is not written clearly what stage exploration or exploitation permits are so many who have permission just to interpret the mining business (KP) which is more than 200 ha of required EIA so that once the consultants appeared KP Exploration, which until now has not been certified as a compilers of Amdal field direct mining persuade employers to prepare EIA.
Besides these conditions the consultants also apparently read Appendix I Ministerial Decree No. EMR. K/29/MEM/2000 1453 November 3, 2000 and Law No. 4 Year 2009. In Attachment 1 of the Energy and Mineral Resources Decree stated that the requirements for application for Exploitation KP include: Feasibility Study Reports and Documents Amdal. In article 39 paragraph (1) of Act No.. 4 Year 2009 stated that in the exploration IUP must include provision for at least bla.bla. blah and Amdal.
Based on some of these regulations the consultants apparently also concluded that the EIA document prepared at this stage of exploration activity with exploration activities without regard to the preparation of reports and technical feasibility study has been completed or not.
To assess whether the regulations and the opinion of the consultants is true or not true let us try to understand the stages of the technical phases of activity that should be passed on Exploration IUP.
At the exploration stage there are 3 (three) stages which must pass the technical exploration of the preliminary, semi-detailed exploration and detailed exploration.
At the stage of preliminary exploration activities are usually done is interpetrasi or Landsat imagery and geophysical surveys (both activities can be carried out and may well not), geological mapping, outcrop surveys and taking sediment samples and test drilling (scout drilling).
The results of this activity based on the criteria contained in the resource and reserve classification SNI or SNI classification of coal resources and mineral reserves of mineral resources is the data / inferred coal classification.
At the stage of semi-detailed exploration activities are frequently performed test pits or trenching or drilling with a grid system, the location of tititik drill / test pit / trenching regularly with a specific distance intervals, eg 800 x 800 m or 500 mx 500 m.
At this stage the data obtained are of mineral resource data / classification Designated coal.
At the stage of detailed exploration activities are often undertaken to target for both open pit coal or ore minerals include primary drilling spaced drill point that more meetings of 100m X 100 m or 200 x 200 m (depending on geological conditions), topographic mapping minimum scale of 1: 2,000, geotechnical studies and laboratory analysis course which aims to determine the quality of minerals and -likelihood of significant impacts what if mine is really open.
Geotechnical studies are usually not required to mine gold or alluvial zircons. As for the underground mine should be augmented with a study of rock mechanics.
The results are detailed exploration of mineral resource data / coal measured classification.
Technical feasibility study is the focus feasibility study is to determine how the mining and processing methods whose primary purpose is best so that the mine will not accident prone (safe for work) but the recovery of mining and processing of high (optimal).
In this study will be determined the types of equipment and reagent-reagent which may be used.
Feasibility study was to estimate the environmental focus significant impacts that would arise if the descriptions of activities that have been decided in the technical feasibility study done.
In this environment the feasibility study will be determined environmental monitoring and management efforts what is required for mining activities to be conducted to have a negative impact as small as possible and positive impact as much as possible.
Economic feasibility study focus was to estimate the value of income and expenses when the results of the technical and environmental studies are done,
In this study will calculated also how much value the company's profit and revenue when the State mining business is conducted.
Before the era of autonomy, the three types of feasibility study was discussed and approved by an agency of the Department of Energy and Mineral Resources, but after the era of autonomy, environmental studies are discussed and approved separately by the Regional Environment Agency so that the logical sequence of mining feasibility studies into chaos because of a technical study and economical that there should be in the hands of the Regional Technical work units is often not discussed at all because of the regional Technical Unit of many who do not know the duties and functions. If anyone knows were often confused when discussing it, before or after the environmental studies.
In response to situations and conditions as stated above I believe that before the environmental feasibility study discussed in the Regional Environment Agency should review mine that consists of technical studies, environmental and economic discussed first in the regional work units in charge of the mining field which resulted in the approval of pre-study feasibility of the regional work units.
If the environmental assessment has been approved by the Environment Agency Region and the results of pre-feasibility study of the mine has been revised in accordance with the results of the environmental assessment in the final mine feasibility study was approved by the Regional Leader of the Governor / Regent appropriate authority.
Back to the original question when mining EIA prepared, I would argue that the environmental assessment or environmental impact analysis in a logical course can only be prepared after the technical feasibility study, Based on this new study will clearly SIABIDIBANYA (Who, When, Where and Bagaimananya). Based on this study should have been illustrated in detail the mine site plans, plans of supporting facilities such as the location of overburden disposal areas, soil storage location shoots, settling pond location, location processing unit, haul-road pathway plan, mess, office, etc..
In our Indonesia, especially in Kalimantan frequent EIA document has been prepared before the technical feasibility study of sometimes even long before that which is immediately after issued of KP Exploration and SIABIDIBANYA activities so that descriptions can not be portrayed in detail.
So that the EIA document is approved to be very normative and impact may occur settling pond location was on a ridge, water sampling, benthos, air and other location that will not be disrupted mining. EIA of this kind in my opinion is misguided EIA