Health & safety The mine site and associated tailings dam are located in an area that is one of the most active earthquake zones in the world. An expert report by Dr. Richard Meehan, a Stanford University engineer specialising in dam stability and seismic risk, found that the mine is located in “one of the highest risk areas in the world”, close to the Sumatra subduction megathrust, which produced earthquakes of magnitude 9 and 8+ in 2004 and 2005, respectively. The site is also approximately 14 kilometres from the Great Sumatran Fault.

The area also experiences extremely heavy annual rainfall, and the topography of the area includes layers of volcanic ash known for their instability. Should the area experience a serious earthquake or significant rainfall, Meehan states there is an extremely high risk of tailings dam failure, sending “a wave of liquid mud downstream”, resulting in serious harm to eleven nearby and downstream villages. In an interview with Yale Environment 360 in 2021, Meehan said tailings dam failure is a ‘virtual certainty’ in the proposed location. In his review of the project’s updated EIA Addendum, Meeham concluded: “In summary, I believe that any approval of the DPM mine project as proposed would give a green light to a mine almost certain to result in a human and environmental disaster on the scale of the El Cobre, Aberfan, and Brumnidinho disasters.”

Dr. Steven Emerman, a geophysicist and mining hydrologist, has noted that the project clearly violates Chinese domestic safety policy on tailings dams. The policy, which the Chinese government adopted recently in response to tailings disasters around the world, prohibits the establishment of mine tailings dams within 400 meters upstream of a human settlement. DPM clearly fails to meet this standard and thus, would not be legal in China.

Lack of transparency, community consultation and consent, including with respect to Indigenous Peoples: Indigenous and other local communities downstream of the mine have not provided their free, prior, and informed consent for the project to go forward. Independent information about the mine and its possible impacts has been extremely limited. As detailed in the “Brief History” section of this Dodgy Deal, DPM undertook significant activities on the ground without proper approval, which local NGOs allege is illegal. The updated EIA has not been subject to genuine public consultation with affected stakeholders. The final approved EIA has not been disclosed.

Residents of Dairi have requested the Indonesian Ministry of Energy and Mineral Resources release the previous Contract of Work for DPM, but they have refused, despite a National Information Commission ruling to do so.

Acid mine drainage Lead-zinc mines are known to be high-risk with the potential for significant pollution. The mining process will extract sulfide ore which, when exposed to water and oxygen, can form sulfuric acid. This can lead to acid mine drainage, a process through which heavy metals become dissolved in water and then spread throughout the water system.

Dr. Steven Emerman, a geophysicist and mining hydrologist, reviewed the company’s 2021 draft EIA Addendum. Emerman found that DPM was designed to accommodate only a 100-year flood event, which is much less than the Probable Maximum Flood required by international standards and Indonesian guidelines (or the 10,000 year flood). In a video presentation of the findings from his technical review of the DPM EIA Addendum, Emerman stated, “I [can] say with confidence that I have never reviewed a proposed mining project that showed such callous disregard for human life as the proposed DPM mine.”

Other pollution In addition to the waste and water issues, the Dairi Prima Mineral mine is also likely to create impacts from dust and from an increase in heavy traffic passing through nearby residential and farming areas.

Biodiversity risks The DPM mine’s concession area is located in a tropical rainforest that is home to threatened animal species such as orangutans and Sumatran tigers. Acid mine drainage, pollution, and a potential tailings storage facility collapse all pose risks to the area’s ecosystem and ecology.

Issues of non-transparency to investors In  NFC's 2021 annual report, it is stated that the EIA Addendum of the DPM project “has been approved in principle” (for its changed mine plans). In June 2022, however, the Ministry of Environment and Forestry confirmed that no approvals have been issued and that the Ministry was still awaiting revised documents from DPM, while work continued on the ground. It was not until August 2022 that the permit was approved by the Ministry. The final approved EIA still has not been disclosed to stakeholders, including affected communities.