Mining Legacy, Living Landscape: A Field Study of Uranium on the Navajo Nation

In the Southwestern U.S., uranium mining powered national ambitions, transformed landscapes, and left behind challenges that persist decades later. Drawing on observations from a recent field course in the Four Corners region, Luke Danielson, President of Sustainable Development Strategies Group, explores what the Navajo Nation’s experience reveals about the legacies of mining, reclamation work, and the importance of learning directly from the places and people affected.

By Luke Danielson

Participants visiting an abandoned uranium mine near Cove, Arizona (Photo L. Danielson).

In June last year, the Executive Director of Western Alliance of Reclamation Management (WARM), Dominique Naccarato, and I were among the leaders of a week-long field course to study reclamation needs and current actions at mine sites across the Four Corners region of New Mexico, Colorado, Utah and Arizona. 

The course was organized by WARM and the Society of Economic Geologists (SEG), and gathered students from Western Colorado University, Colorado School of Mines, Colorado State University, the University of Arizona, the University of Wisconsin-Milwaukee, and more. 

While the course was based primarily at Fort Lewis College in Durango, Colorado, we visited many sites, encountering a wide range of mining landscapes and histories – from former silver mines in the high San Juans in Colorado to copper mining districts in Utah. This post focuses specifically on the legacy of mining on the Indigenous Navajo Nation. While coal, gold, copper and other minerals have all played important roles, the most frequent and visible impacts are associated with uranium mining.

a newcomer in the mining world

Humans have been mining for far longer than they have domesticated animals or grown crops. Early mining likely began 50,000 years ago, initially focused on a very limited number of materials. Over time, advances in technologies both required and enabled the production of a growing list of materials.

A relative newcomer to this list is uranium. Prior to World War II, small amounts were produced as a byproduct of vanadium or other ores. One notable usage example from this period is FiestaWare, a dinnerware company created in 1936, which used uranium glazes to produce plates with a bright orange-red hue.

A Fiesta red saucer (credit: Museum of Radiation and Radioactivity)

Mining uranium as a primary objective, however, awaited the development of nuclear weapons at Los Alamos, New Mexico during World War II. The first of these weapons was detonated in New Mexico, at the Trinity site in the Jornada del Muerto, marking a turning point not only in warfare, but in global demand for uranium. My stepfather, Frank Oppenheimer, played a role in the Manhattan Project, and was present at the Trinity Test, which he helped organize.

from boom…

After Hiroshima and Nagasaki, and the end of World War II, the world entered an arms race that drove an urgent demand for uranium. There was also the potential that nuclear technology could be used to power ships, generate electricity, and reshape modern life. The United States (U.S.) did not want to fall behind.

The federal government was concerned that supplies of uranium might prove too limited, or worse, that our nation’s adversaries might have more of it than we did. It was a (self-fabricated) crisis atmosphere, not too different from what we are seeing today with critical minerals. The Atomic Energy Commission and other agencies established a host of incentives to promote uranium prospecting and production. These measures fueled what became known as the 1950s “uranium boom” (which gave its name to a 1956 Hollywood movie).

Large uranium deposits were identified, much of them in New Mexico. The mining happened rapidly and often haphazardly, leaving behind a massive and very troubling social and environmental legacy. Some of this is described in Judy Pasternak’s book, Yellow Dirt: a Poisoned Land and the Betrayal of the Navajos. Miners dug uranium from small, poorly ventilated tunnels with dangerous radiation levels. Mill waste was inadequately contained and leached into groundwater. The resulting impacts mean there will be work for generations of reclamation specialists.

…to bust

Ironically, the success of these incentives led to overproduction. By the 1960s, government stockpiles had grown too large, subsidies were removed, and the industry moved abruptly from boom to bust.

This is a lesson in the minerals industries. Government subsidies drove the silver boom of the 1880s and 1890s, followed by a bust when the subsidies ended. The U.S. may be repeating the same mistakes in the current drive to find and develop critical minerals and rare earths.

Annual uranium production in the United States, 1947-2009. Adapted from Fettus and McKinzie, Nuclear Fuel’s Dirty Beginnings, NRDC (March 2012).

Because little attention was given to closure planning, the collapse of uranium mining left a legacy of uncontrolled environmental impacts on the landscape.  These included about three dozen uranium mill tailings sites, which have cost government billions of dollars to stabilize and remediate under the Uranium Mill Tailings Radiation Control Act.  There is a Radiation Exposure Compensation Act which provides compensation to former uranium miners and other uranium workers. RECA was expanded in 2025 to cover more workers, survivors, and specific diseases like kidney cancer and disease.

Today, there are still more than 500 federally recognized abandoned uranium mines on the Navajo Nation alone, and more than 10,000 across the western United States. Reclaiming these sites will take decades.

The U.S. Department of Energy (DoE)’s Defense-Related Uranium Mines (DRUM) program works in partnership with federal land management agencies, state abandoned mine lands programs, and tribal governments to verify and validate the condition of uranium mines that provided ore to the Atomic Energy Commission for defense-related activities between 1947 and 1970.

Remediation up close

During the field course, we met with teams from the DoE, the Environmental Protection Agency (EPA), the Navajo Abandoned Mine Lands Department, mining company Freeport-McMoRan, the Southwest Research and Information Center, and others engaged in this work.

At Shiprock, New Mexico, our group was hosted by a DoE team led by Site Manager Joni Tallbull. Shiprock is home to a major repository for mill tailings from the former Shiprock Uranium Mill, one of several such sites in the region.

Mill tailings disposal site at Shiprock, New Mexico (Photo L. Danielson, SDSG).

Originally, these tailings were placed on permeable soils in the alluvium along the San Juan River, allowing contaminants to infiltrate groundwater. Protecting groundwater is now a major focus of reclamation efforts.

The uranium milled here came from dozens of small mines, often located around Cove, Arizona. Several of these are now being remediated by Freeport-McMoRan, which did not create these legacies but is cleaning up many of them.

Abandoned uranium mine near Cove, Arizona (Photo L. Danielson, SDSG).

Our group visited several other sites managed by Jennifer Laggan, Manager for Remediation Projects at Freeport, and the team she leads.

Visit to Abandoned Uranium Mine (Photo Luke Danielson, SDSG).

The course also included some hands-on work in sampling and monitoring, including measuring radiation levels, to center policy discussions in the realities of site conditions and remediation. 

Church Rock’s enduring impacts

Participants were then hosted by members of the Church Rock community in New Mexico, located next to the largest uranium mine on the Navajo Nation. Although the mine is now closed, it has not yet been fully reclaimed. Several nearby sites still require significant remediation, and concerns over ongoing radiation exposure remain considerable.

As early as 1979, the U.S. Nuclear Regulatory Commission noted that “uranium mining and milling are currently the most significant sources of radiation exposure to the public from the entire uranium fuel cycle, far surpassing other stages of the fuel cycle, such as nuclear power reactors or high level radioactive waste disposal”.

That very same year, Church Rock became the site of a uranium mill tailings spill, the largest release of radioactive materials in U.S. history. In a 2025 blog note, Dr Chanese A. Forté of the Union of Concerned Scientists describes the release of “1,000 tons of tailings and 93 million gallons of acidic wastewater into the Rio Puerco, traveling about 80 miles downstream to eastern Arizona. People who waded unknowingly into the river immediately after the spill suffered acid burns on their feet and legs, and an unknown number of livestock (...) were also lost in the river”.

Kenyon Larsen of EPA with students at Church Rock, New Mexico (Photo L. Danielson, SDSG).

Conversations with Church Rock community members were among the most powerful moments of the field course. Participants heard firsthand accounts of family members who developed lung cancer and other diseases after working in the uranium industry, of areas perceived as no longer safe for living, and of impacts on agricultural livelihoods. 

Billboards along local highways informing people of their rights to file claims were another sobering reminder that yesterday’s choices have long lasting consequences. Some of the issues the Navajo faced are further documented in a book The Navajo People and Uranium Mining.

Meeting with community members and experts at Church Rock (Photo L. Danielson, SDSG).

The Radiation Exposure Compensation Act (RECA) is a federal program that provides one-time compensation to eligible former uranium miners, millers, and ore transporters who develop certain radiation-related illnesses. While originally limited to workers active between 1942 and 1971, recent legislation has extended its coverage to miners through to 1990 and broadened the list of eligible diseases.

Returning to the Navajo Nation

This field course highlighted the importance of learning directly from practitioners and communities about the legacies of mining and milling uranium. We are currently planning an expanded and more advanced version of this field course in 2026, anticipated to include coal, copper and other mining sites on the Navajo Nation and elsewhere in addition to uranium. We also hope this future course will involve collaboration with Navajo Technical University. If you are interested in joining a future tour, further details will soon be available at https://www.segweb.org/.

This field course benefitted enormously from the generosity, expertise and time of many individuals and organizations. We would particularly like to thank Cory Dayish and Benjamin Deans of the Division of Natural Resources of the Navajo Nation for their guidance and support.

Verra’s Carbon Standard 5.0: Integrity Through Rights and Benefit-Sharing?

Verra’s latest update to its Verified Carbon Standard marks a clear attempt to restore trust in voluntary carbon markets by introducing stronger rules on carbon rights and benefit-sharing. But will these changes deliver genuine transformation, or merely reduce the most visible forms of abuse in carbon projects? SDSG Carbon Fellow Bennett Jarvis examines whether the new standard meaningfully shifts power toward communities, or simply places guardrails around a flawed model.

By Bennett Jarvis

A ranger working in the Kasigau Corridor, Kenya, as part of a REDD+ carbon offset program (credit: Geoff Livingston via Flickr, CC BY-NC-SA 2.0).

The following blog covers the technical elements of Verra’s updated standard. For a more introductory overview of the voluntary carbon market and Verra’s role therein, listen to this interview with the author.

Edited by Anthony Bosco

Music credit: “Our Reality” By Ketsa via Free Music Archive, CC BY 4.0

In December 2025, carbon offset certifier Verra released the fifth version of its Verified Carbon Standard (VCS 5.0). Carbon market participants across the board were pleased to find that the new standard delivered on much of its promises. 

This much-anticipated update makes major changes to the accessibility of program information, digitalization of the standard body’s activities, and implementation of market mechanisms like insurance for dealing with non-permanence risks. These are all part of broader efforts across the industry to cut costs, increase operational efficiency, foster a more mature market structure, and streamline communications between various market actors as they prepare (or at least hope) for interoperability across global carbon markets. 

What headlines have underscored though are the revisions VCS 5.0 made on the integrity front; a set of issues ranging from financial transparency to benefit-sharing and community consultation practices, that actors across the market view as in dire need of improvement to increase demand, cement market credibility, and, potentially, drive ever more finance into nature through enhanced nature-based projects. 

Verra touted the updates as heralding a “stronger focus on people and communities”, the culmination of Verra’s lessons learned over recent years, and the “systematic strengthening of the foundations of the carbon market”. Some have called the update a “big win for communities” and “a major step towards carbon justice”. We’ll return to that claim after analyzing aspects of the new VCS 5.0.

The two key changes to VCS 5.0 on these fronts concern i) the right to operate and rights to carbon removals (i.e. carbon credits) and reductions (Section 3.6); and ii) standards around benefit sharing with communities hosting nature-based carbon offset projects (Section 3.17). 

If rigorously implemented, VCS 5.0 could reduce the severity and frequency of persistent abuses that have plagued Verra-certified nature-based carbon projects and better protect the rights of project-affected populations, particularly Indigenous Peoples (IPs) and customary tenure holders. However, despite progress, the standard is still too weak on critical issues impacting the rights and benefits of communities. 

The right to operate vs the right to own carbon credits

In the past, carbon project developers held implied rights to reductions and removals through their operations. In other words, if a project developer received some form of operating permit from the authorities in the jurisdiction where the project was taking place, Verra assumed the developer had the rights to own and trade carbon credits by virtue of the operational license. 

We highlighted why this is problematic in a policy report published last year; there are numerous carbon project developers that have claimed the rights to nature-based carbon credits that in actuality should belong to the communities that hold tenure over the land, forests or peatlands in question. The right to operate vs the right to ownership of carbon credits have now been separated in VCS 5.0 and must be clearly demonstrated by project developers. 

The new Verra standard states:

1.  "The right to reductions and removals might derive directly from the right to operate, from land or resource rights, or be governed by a specific regulation in the jurisdiction” (Section 3.6). This is the section which now recognizes that the right to operate and the right to permits are distinct; 

2. "Where the project may affect land or resource rights, project proponents must also conduct an analysis of such rights to identify any customary rights, overlapping claims or competing claims, and violent conflicts in the project area, and to determine whether additional measures are needed to secure the right to operate and the right to reductions and removals" (Section 3.6). 

   Though somewhat (unhelpfully) vague, this section requires at least some scrutiny of how project developers obtain the right to operate and the right to carbon credits. We however maintain our belief that carbon ownership should be linked to the tenure of the underlying carbon-stocking asset – land, forest, peat, etc. In other words, if a community owns the land, they own the carbon too; 

3. The land and resource rights in question constitute competing rights "regardless of whether the claims are recognized or fully formalized under the national legal framework" (VCS Program Definitions 5.0, pages 14 and 24). 

   This is an important safeguard because, as we pointed out in our policy report from last year, many national legal frameworks fail to formally recognize customary land and resource tenure rights of rural communities and IPs according to best practice standards like the Food and Agriculture Organization of the United Nations’ Voluntary Guidelines on the Responsible Governance of Tenure. 

Based on Verra’s own definitions, project proponents must now substantiate their legal right to carbon credits through an analysis of relevant laws and regulations and by furnishing evidence of the Free, Prior, and Informed Consent (FPIC) of rights holders prior to the project’s start date, including customary rights holders. These are notable improvements compared to previous iterations of the VCS. 

Benefit-sharing

Customary land and resource tenure holders also saw promising changes to Verra’s updated benefit-sharing framework. In the past, benefit-sharing agreements (BSAs) – the agreements negotiated between local communities and the carbon project developer – were nominally required in the event that projects potentially impacted individual private property rights. In VCS 5.0, BSAs are now required “[w]here a project affects land or resource rights holders or there are customary rights holders or IPs present in the project area” (Section 3.17.12). 

The BSA must now be designed in collaboration with these rights holders before the project start date, and VCS 5.0 now designates these rights holders as “participants” in benefit-sharing mechanisms who will receive information on projected revenues and costs associated with the project. Once the project is operating, communities that are parties to a BSA will also receive annual updates on project operating costs and gross or projected revenues (Section 3.17.12-14). 

VCS 5.0 also lists activities that cannot be included as shared benefits such as goods associated with implementing project activities, infrastructure necessary for the project, mitigation measures for safeguards, and project workers' salaries (Section 3.17.15). The logic at work there is that goods and services essential to the project’s implementation do not constitute enhanced benefits subject to negotiations. 

Lastly, the terms of BSAs must now be made public within the larger Project Implementation Agreement, “unless the customary rights holders and IPs want it kept private” (Section 3.17.17).

Though the updates to BSAs in VCS 5.0 constitute real progress in many respects, there is still much room for improvement. First, most BSAs are “negotiated” by representatives of communities that have little to no access to technical or legal counsel during negotiations.

Though project developers are required to provide preliminary information about the project, its context, and applicable laws to local stakeholders, the new standard does not require that communities benefit from legal counsel. This raises serious concerns about how project proponents will handle the information and capacity gaps that continue to plague carbon projects.

Secondly, we continue to find the lack of substantive baseline standards for the design of BSAs in VCS 5.0 seriously problematic. The few BSAs available in the public domain only provide for community benefits once carbon offset projects are profitable. The profit-sharing approach creates huge risks for communities that often commit to abandoning (carbon-emitting) livelihood activities in exchange for a share of project profits. In these situations, the welfare of communities is vulnerable to the whims of the volatile voluntary carbon market and the accounting practices of the project developer. 

VCS 5.0 does state that benefit-sharing mechanisms must "account for potential changes in benefits (e.g., a decrease in gross revenue caused by carbon credit price fluctuations)" but provides no real guidance on what accounting for this looks like (Section 3.17.14(5)). 

Equitable BSAs must abandon the profit-sharing approach and rather guarantee multiple revenue streams (royalties, land rents, in-kind benefits, and profits for example) for communities, no matter project outcomes. There is already a model for this under the Paris Agreement’s Article 6.8 non-market approaches (NMAs). 

Third, though the new requirement that BSAs be publicly disclosed is encouraging, the opt-out for rightsholders that want BSAs “kept private” is ripe for further abuse, by both project developers and co-opted community elites that may choose private gain over the public interest.

Carbon justice achieved or carbon exploitation averted?

Does VCS 5.0 achieve “carbon justice” for communities? We struggle to say yes for (at least) two reasons:

1. Though the new VCS does successfully address many real issues related to community rights and market integrity, there are still substantial gaps in the standard, as we highlighted above. At best, VCS 5.0 will reduce the frequency and severity of rights abuses caused by nature-based offsets in the voluntary market. We fail to see a fundamental market transformation; 

2. Critics have long argued that the practice of carbon offsetting itself is a distraction (subscription-based article) from decarbonization of the global economy and promotion of climate justice. Past decades have witnessed growing scientific evidence that carbon offsets fail to reduce global warming because of persistent structural issues. 

   This evidence has been all the more stark for nature-based offsets, which are non-permanent or temporary carbon removals in most cases, and thus ineffective for ‘offsetting’ real fossil fuel emissions. It’s for these reasons that SDSG, and others, are calling for IPs and local communities to instead receive financing from NMAs, which will likely produce better carbon biosequestration results and respect human rights compared to pure market-driven approaches.

To sum it up, greater carbon exploitation has been partially averted by VCS 5.0, but carbon justice may still be a long way off.

Aluminum: The Hidden Carbon Cost No One Is Talking About

Aluminum is a pillar of sustainable infrastructure and green technologies, appearing in everything from the batteries in our phones to the electric cars we drive. However, its production cannot be truly called “green” until its full climate impact is acknowledged and accounted for. Maria Guillamont, a Juris Doctor candidate at Lewis & Clark Law School and Legal Intern at SDSG, has been researching the overlooked environmental impact of aluminum – and why it matters now more than ever.

By Maria Guillamont

Mining equipment at the Comalco bauxite mine, Weipa, Australia (credit: Urbain J. Kinet / Berkeley Geography); certified pisolitic bauxite from Arkansas, USA (credit: James St. John via Flickr, CC BY 2.0); aluminum foil (credit: James St. John via Flickr, CC BY 2.0) (Montage: SDSG)

Why aluminum is everywhere 

Chances are, you’ve interacted with aluminum countless times today. Whether you checked your smartphone, drove to work, opened a can of soda, or even flipped a light switch, aluminum played a silent but vital role. 

This malleable and ductile metal is indispensable across various industries, making it one of the most-used components of our modern world. It sits at the core of ​​battery enclosures, motor housings, heat exchangers, and electrical systems. Because of its many uses, this metal is central to the energy transition. As the world scales up electric vehicle production and renewable energy infrastructure, aluminum demand is set to grow substantially – with projections suggesting an increase of 40 to 50% by 2050.

Aluminum market growth projection until 2035 (source: https://www.rootsanalysis.com/)

The scale of this industry is already massive today, dwarfing the production of other ‘transition metals’: 

Source: Maria Guillamont

Aluminum production is more than ten times the volume of all these other materials combined. Because the industry is so vast, it is imperative that its environmental footprint is known and accurately reported.

Where the damage begins: bauxite and rainforests

Aluminum does not exist in nature in its pure form; it is refined from bauxite, a reddish ore found mostly in tropical rainforests. Around two thirds of global bauxite reserves are located in Guinea, Australia, Vietnam, Indonesia and Brazil, specifically in regions that house some of the world’s most biodiverse ecosystems and large tropical forests. This overlap means that bauxite mining often has serious environmental consequences. 

Unlike many minerals that are found deep underground, bauxite primarily occurs in shallow, widespread deposits. Extracting it requires open-pit mining, which involves clearing large tracts of land or forest, stripping away topsoil, and disturbing underlying rock layers. This results in large-scale deforestation, habitat loss, and the disturbance of carbon-sequestering soils. Some of the environmental and social issues around aluminum production have previously been explored by SDSG. 

Image Source: https://www.hikewest.org.au

The scale of projected land disturbance in regions of high conservation value is staggering: 

• In Guinea, bauxite mining is projected to destroy over 445,000 hectares (or 1.1 million acres) of natural habitat within the next two decades;

• In Australia, proposals could disturb up to 100,000 hectares of land in the Jarrah forest, a biodiversity hotspot with endangered endemic species;

• In Indonesia and in Brazil, similar projections show several hundred thousand hectares at risk in each country due to active sites and mining licenses granted.

The carbon cost and the accounting gap

Here is the crux of the issue: rainforests are our most powerful terrestrial carbon sinks. The Amazon alone used to absorb about 5% of global CO₂ emissions each year, but its ability to sequester carbon is degrading due to climate change and deforestation. When these forests are cleared for bauxite extraction, we don’t just lose trees: we release the carbon stored both above- and below-ground into the atmosphere, contributing significantly to climate change. Not only that, but we also diminish nature’s ability to absorb future emissions. 

As part of my research at SDSG,  I reviewed 20 academic and aluminum industry articles related to Greenhouse Gas emissions in the bauxite/aluminum sector. The review reveals a troubling trend: this loss of carbon sequestration capacity is almost entirely absent from major industry reports, life cycle assessments, and emissions accounting frameworks.

Despite the mounting evidence, deforestation-related carbon loss is not meaningfully included in emissions calculations by industry bodies like the Aluminum Stewardship Initiative (ASI) or the International Aluminum Institute (IAI).

For instance, ASI’s 1.5°C roadmap focuses on decarbonizing electricity inputs and improving smelting efficiency. However, it provides only vague assurances that emissions from land-use change will be integrated into the roadmap in the future, and fails to quantify the actual climate cost of forest destruction.

This omission is critical. According to Global Forest Watch, forests in Guinea currently remove over 43 MtCO₂e annually.  Studies looking at the average of forests’ carbon storage see that approximately 44% of all carbon stock is stored in soil, up to one meter depth. Mining for Bauxite disturbs not just trees, but also this rich underground carbon reserve.

Forest loss driven by the growing aluminum demand would therefore undermine global climate goals, yet the aluminum industry provides an incomplete picture of its carbon footprint in its emissions reports. Without this information, we have a huge gap in our understanding of the carbon cost of bauxite mining.

Redefining transparency

This gap in environmental accounting must be closed urgently; all emissions, especially those from forest and soil carbon loss, must be transparently reported and mitigated. Without this, industry reduction targets are fundamentally incomplete.

Organizations like ASI claim to promote “full life cycle assessments” and transparent reporting. Yet, by failing to account for forest carbon loss, their standards fall short of their own transparency goals. We cannot build a green future on a foundation of ‘hidden’ emissions. 

The Path Forward

It is imperative that exhaustive reporting of carbon emissions from land use changes be present across environmental assessments and carbon accounting of the Aluminum industry. As such, SDSG is working to develop a research and action initiative to quantify carbon stocks in soils and vegetation across bauxite-rich regions through a global literature review, spatial analysis of existing and planned mining in forested areas, and targeted soil carbon data collection. In parallel, SDSG intends to work with partners in bauxite-rich countries to assess legal and policy frameworks governing land use, restoration, and public participation in mining decisions. Our objective is to produce evidence-based recommendations to inform regulatory reforms to account for this gap in Aluminum environmental assessments, as well as strengthen standards to minimize carbon loss and provide practical guidance to support carbon soil conservation and landscape restoration.

Pertumbuhan Pesat Hilirisasi Nikel di Indonesia: Pelajaran bagi Negeri Kaya Mineral Lainnya

Kebijakan di Indonesia telah memberikan dukungan bagi pertumbuhan industri hilirisasi nikel. Pengalaman ini menawarkan petikan yang berharga bagi negara-negara yang ingin mengikuti jejak serupa.

Lorenzo Cotula; Brendan Schwartz

Lorenzo Cotula adalah peneliti utama dan kepala program Hukum, Ekonomi, dan Keadilan di IIED; Brendan Schwartz adalah direktur eksekutif di Sustainable Development Strategies Group (SDSG).

foto oleh adam pantouw

Di negara-negara berpendapatan rendah dan menengah yang ingin memanfaatkan kekayaan mineral mereka untuk pembangunan industri, sektor nikel Indonesia sering digaungkan sebagai kisah sukses. Sebagai produsen nikel yang besar di dunia, Indonesia telah mengembangkan industri pengolahan nikel dalam negeri yang lumayan besar secara cepat, menciptakan lapangan kerja, dan meningkatkan nilai ekspor produk turunan nikel.

Terdorong keinginan untuk keluar dari pola perdagangan yang sejak lama membatasi mereka hanya mengekspor bahan mentah, pemerintah di banyak negara kaya mineral kini ingin meniru contoh Indonesia dan mendorong industrialisasi.

Kunjungan kami baru-baru ini ke pulau Sulawesi – pusat industri nikel Indonesia – memperlihatkan gambaran yang lebih rumit. Kunjungan tersebut merupakan bagian dari proyek Advancing Land-based Investment Governance (ALIGN), yang selama dua tahun terakhir telah mendukung kegiatan memperkuat tata kelola operasi nikel di Sulawesi Tenggara.

Pemahaman yang lebih utuh tentang mengembangnya secara pesat pengolahan nikel di Indonesia dapat memberikan tilikan bagi para pembuat kebijakan yang sedang ingin menegosiasikan ulang bagaimana biaya dan hasil dibagi-bagi sepanjang rantai pasok mineral kritis.

Kembang pesat nikel

Di Indonesia, penambangan nikel telah bertambah sangat luas dalam 15 tahun terakhir. Diperkirakan bahwa, hingga akhir 2023, hampir satu juta hektar lahan dibebani izin penambangan nikel, terutama di Sulawesi dan Maluku Utara.

Saat ini, Indonesia menyumbang sekitar 60% dari produksi nikel global. Sebagian besar nikel ini digunakan untuk baterai dan baja yang digunakan dalam mobil listrik (EV).

Dengan langkah-langkah yang diambil sejak 2014, pemerintah telah membatasi dan pada akhirnya melarang ekspor bijih nikel mentah, dengan tujuan mendorong nilai tambah di dalam negeri. Regulasi juga mewajibkan perusahaan tambang untuk mengolah secara lokal nikel yang mereka ekstraksi – atau menjualnya ke pabrik pengolahan-pemurnian (smelter) lokal yang telah ada sebelumnya.

Dalam hitungan tahun, smelter-smelter nikel baru dibangun di kawasan industri yang besar-besar di Sulawesi dan Maluku Utara, terutama oleh perusahaan-perusahaan China, membangun kapasitas lokal untuk meningkatkan nilai tambah dan memperkokoh posisi dominan Indonesia (dan China) di pasar nikel global.

Pendekatan pukul rata untuk semua negara?

Kesuksesan kebijakan Indonesia dalam mendorong nilai tambah di dalam negeri telah mendorong beberapa negara kaya mineral lainnya untuk ikut membatasi ekspor bahan mentah.

Namun, efektivitas dari pembatasan ekspor Indonesia – yang diputus melanggar aturan Organisasi Perdagangan Dunia (WTO) – juga disebabkan oleh beberapa kondisi yang khas, misalnya porsi Indonesia yang besar dalam produksi dan cadangan nikel global, yang belum tentu dimiliki pada negara-negara kaya mineral lainnya.

Jika pemerintah negara lain meniru langkah yang sama tanpa skala dan daya tawar sebesar Indonesia, mereka mungkin tidak akan memperoleh manfaat yang diharapkan. Pembatasan yang tidak tepat sasaran justru dapat mengancam kelangsungan industri pertambangan negara tersebut.

Terjebak batu bara captive

Pertumbuhan pesat industri pengolahan nikel Indonesia telah tergantung utamanya pada captive coal (pembangkit listrik tenaga batu bara yang dibangun khusus untuk memenuhi kebutuhan smelter).

Meskipun memastikan akses energi yang stabil, hal ini membuat nikel Indonesia menjadi sangat sarat karbon (carbon-intensive), menciptakan paradoks pada industri yang seharusnya mendukung transisi energi.

Di samping meningkatkan emisi karbon, bersandar pada batu bara mendorong deforestasi. Contohnya di Kalimantan Tengah, di mana pertambangan batu bara meluas demi memenuhi permintaan dari smelter nikel.

Regulasi tahun 2022 membayangkan adanya langkah-langkah transisi bagi sektor listrik Indonesia untuk meninggalkan tenaga batu bara, termasuk adanya larangan pembangunan pembangkit listrik tenaga batu bara yang baru. Namun, larangan ini mengecualikan captive coal untuk nilai tambah domestik, asalkan memenuhi syarat-syarat tertentu.

Kapasitas tenaga batu bara captive yang terkait dengan nikel telah melonjak hampir lima kali lipat pada periode 2014-2023, dan diperkirakan akan terus berkembang dalam beberapa tahun ke depan, kecuali terjadi kemerosotan pasar.

Upaya dekarbonisasi rantai pasok nikel memang sedang berjalan, namun pilihan-pilihan yang tersedia terbatas karena lokasi geografis smelter yang dekat dengan tambang dan pelabuhan, bukan dekat dengan sumber energi terbarukan, dan karena smelter membutuhkan pasokan energi yang dapat diandalkan dan dalam jumlah yang sangat besar.

Sementara itu, rencana mengkonversi pembangkit listrik untuk mencampurkan batu bara dengan biomassa (‘co-firing’) akan meningkatkan deforestasi secara besar-besaran karena luasnya lahan yang dibutuhkan untuk memproduksi bahan baku biomassa tersebut.

Industri yang berkembang pesat dan regulasi yang efektif

Naik tingkat di rantai nilai (value chain) dapat membantu pertumbuhan dan diversifikasi ekonomi negara berpendapatan rendah dan menengah. Banyak dari negara-negara ini bergulat dengan ketergantungan pada ekspor komoditas dan beban utang yang besar. Kesuksesan Indonesia dalam mengembangkan nilai tambah nikel telah menciptakan ribuan lapangan kerja.

Namun, sektor ini tercoreng oleh banyak kecelakaan kerja. Dan, di Sulawesi dan Maluku Utara, penambangan dan pengolahan nikel telah dikaitkan dengan dampak sosial dan lingkungan yang luas, termasuk deforestasi, sengketa lahan, polusi udara, dan pencemaran air. Dampak-dampak ini merongrong penghidupan masyarakat hutan, petani kecil, dan kaum nelayan.

Salah satu masalahnya adalah pertumbuhan industri nikel yang pesat telah melampaui kapasitas untuk mengatur sektor ini secara efektif. Sebagai contoh, banyak proyek nikel beroperasi di pulau-pulau kecil, melanggar undang-undang tahun 2007 yang melarang penambangan di pulau-pulau semacam ini. Pada tahun 2024, Mahkamah Konstitusi menguatkan konstitusionalitas larangan ini.

Pada Juni 2025, kemarahan publik atas pertambangan di pulau-pulau kecil di Raja Ampat – rumah bagi terumbu karang dan kehidupan laut paling ikonik di dunia, serta daya tarik utama bagi wisatawan – memicu pemerintah untuk menangguhkan empat izin pertambangan.

Selain itu, pemerintah menguasai kembali lahan-lahan luas perkebunan kelapa sawit dan tambang nikel serta batu bara yang beroperasi secara ilegal di kawasan hutan.

Meskipun demikian, organisasi masyarakat sipil dan komunitas yang terdampak tambang terus menyoroti pelanggaran yang meluas terhadap peraturan yang berlaku, misalnya mengenai polusi udara, reklamasi tambang, dan pengelolaan limbah tailing.

Menggali pelajaran untuk kebijakan

Di Sulawesi Tenggara, beberapa organisasi masyarakat sipil, dengan dukungan dari ALIGN, telah melakukan pekerjaan penting untuk mengatasi masalah ini. Mulai dari mendorong dipatuhinya larangan menambang di pulau-pulau kecil, mendukung pemberdayaan komunitas di sekitar lokasi tambang, hingga memberikan masukan untuk revisi rencana tata ruang provinsi yang akan membatasi penambangan di kawasan hutan rindang dan kawasan yang sensitif keanekaragaman hayati.

Di negara-negara berpendapatan rendah dan menengah yang kaya mineral yang ingin mendorong nilai tambah domestik, pembuat kebijakan harus memikirkan dengan hati-hati strategi yang sesuai dengan konteks mereka sendiri. Mempertimbangkan secara holistik dimensi-dimensi sosial, lingkungan, dan ekonomi dari pengalaman Indonesia dapat menghasilkan wawasan yang berguna.

Pertama, pengalaman Indonesia menggarisbawahi kondisi yang perlu terpenuhi agar kebijakan industri tertentu – seperti keharusan hilirisasi – dapat efektif.

Kedua, hal ini menyoroti pentingnya pemerintah menjawab secara proaktif persoalan yang akan berdampak pada sektor ini secara jangka panjang, seperti urusan reklamasi tambang dan tailing, perencanaan tata ruang yang lebih partisipatif dan inklusif, pelibatan masyarakat yang efektif, pengakuan hak atas tanah, dan solusi energi rendah karbon.

Seturut dengan itu, pemerintah sebaiknya mempertimbangkan pilihan-pilihan energi sejak awal, seperti menempatkan smelter dekat dengan sumber energi terbarukan, untuk menghindari terjebak dalam pola yang tidak lestari yang pada akhirnya dapat memperlemah daya saingnya secara global.

Terakhir, pengalaman Indonesia menggarisbawahi dampak besar dan dilema untung-rugi yang kompleks yang dapat timbul dalam proses industrialisasi – serta perlunya kapasitas, regulasi, dan penegakan hukum negara yang efektif sepanjang rantai pasok mineral.

SDSG Comments on Xcel Energy's Proposed Gas Infrastructure Plan

On January 20th, SDSG submitted written comments to the Colorado Public Utilities Commission (PUC) in relation to Xcel Energy's proposed Gas Infrastructure Plan (GIP), which is the company's proposal for expanding its methane gas network to deliver more gas to commercial and residential customers in Colorado. SDSG, along with numerous other Colorado based organizations, opposes the GIP as currently designed. Our comments focused on three major issues:

1) Colorado's state legislature passed binding "Clean Heat" targets for large-scale gas utilities, requiring a 41% reduction in Green House Gas Emissions by 2035. The gas network expansion in Xcel's GIP would make it nearly impossible for Xcel to meet those targets. Meaning either i) the State of Colorado would need to abandon its climate targets; or) Xcel would need to abandon its gas network infrastructure to meet the targets, creating expensive stranded assets that ratepayers would be reimbursing for decades to come. That's lose-lose.

2) There are numerous viable energy alternatives (so-called NPAs "Non-Pipeline Alternatives") to methane which Xcel's GIP failed to adequately consider. These technologies, such as heat pumps, are more energy efficient and are becoming cheaper thanks to subsidies. State officials have estimated that implementing NPAs could produce nearly $1 billion in economic benefits while avoiding about $5.1 billion in climate-related costs with greenhouse gas emissions.

3) Xcel's GIP failed to adequately calculate the Green House Gas Emissions that would be emitted due to expanded gas infrastructure. Additionally, Xcel failed to provide "Social Cost of Carbon" analysis in key parts of the GIP as required by Colorado Law. These costs would amount to billions of dollars and be borne by Colorado residents and Xcel ratepayers. Proper integration of the Social Cost of Carbon into Xcel's GIP would change the cost-benefit analysis of investment decisions in favor of renewable energy projects.

SDSG's Sydney Christian appeared before the Public Utilities Commissioners to deliver oral testimony, which summarized our written comments.

The PUC is holding an Evidentiary Hearing on the merits of Xcel's GIP through January 23rd. It is expected to make a final ruling on the GIP proposal by March 25, 2026.

Denver’s “Brown Cloud”: why Colorado keeps failing air quality standards – and what can be done

Have you ever flown into Denver International Airport, hopped in a rideshare, or rode the train towards the city, gazed off into the distance only to see a hazy skyline, and a brown cloud where the Front Range should be? Welcome to America’s sixth smoggiest city! Alex Inskeep, a University of Denver Law student and SDSG Legal Intern, has been researching air quality issues in Colorado’s Front Range. He explains what is driving Denver’s smog problem, and how you can get involved.

By Alex Inskeep

Downtown Denver on 22 July 2014, with the “brown cloud” obscuring the view of the Front Range (credit: Colorado Department of Public Health and Environment).

That familiar haze – often referred to as Denver’s “brown cloud” – is more than just an eyesore. It reflects the persistent ozone pollution placing Colorado’s Front Range in violation of federal clean air standards.

what causes smog?

Ozone, the main chemical component of smog, manifests from the reaction between oxides of nitrogen (NOX) and volatile organic compounds (VOCs). Ground-level ozone poses severe health risks, from coughing to breathing difficulties, lung and cardiovascular diseases. These issues disproportionately affect children, pregnant women, older people, outdoor workers and those with pre-existing conditions such as asthma – especially among Disproportionately Impacted Communities. 

To protect public health, the Environmental Protection Agency (EPA) sets National Ambient Air Quality Standards (NAAQS). In 2015, the EPA established the current ozone standard at 70 parts per billion (ppb), measured as a daily maximum 8-hour average. According to the National Parks Services, an “exceedance day” occurs when ozone levels reach or exceed 71 ppb. If a region’s fourth worst ozone day exceeds that limit each year over three years, it is classified as being in “nonattainment”. 

The EPA first designated Denver under “nonattainment” status back in 1978; and since 2019, it has designated nine Colorado counties as “serious” nonattainment areas. 

Measuring ozone along the Front Range

Colorado’s Department of Public Health and Environment (CDPHE) measures ozone levels across Colorado and the Front Range and publishes daily ozone readings dating back to 2008. As part of my SDSG internship, I collected data on the number of exceedance days each year since 1995. The graph below shows that the Front Range region made no significant progress in reducing ozone exceedance days. Although, Colorado made strides in reducing ozone exceedance, increasing population and industry presence have thwarted such efforts.

Ozone exceedance days per year in the Denver Metropolitan Area since 1995 (source: Regional Air Quality Council).

Through analysis, during the worst months for ozone, June through August, the data shows no significant increase or decrease in the average daily amount of ozone present in Colorado since 2008. As a result, Colorado continues to struggle with nonattainment despite its efforts to curb emissions. However, progress towards attainment may face challenges under the Second Trump Administration. For example, the Trump Administration requires coal facilities in Colorado to remain open. Colorado, therefore, should look towards state regulation for the foreseeable future instead of federal regulation.

Colorado’s Air Quality Control Commission (AQCC) identifies several major contributors to ground-level ozone in the State, including oil and gas operations, vehicle emissions, industrial facilities, and background ozone. “Background ozone” refers to ozone that originates from natural events, such as wildfires, or from pollution sources outside the United States.

Sources of ground-level ozone in Colorado (adapted from Regional Air Quality Council).

While background levels dominate the amount of ozone in Colorado, sources such as oil and gas, factory emissions, and vehicle emissions also significantly contribute to Colorado’s nonattainment designation.

Colorado’s plan to improve air quality 

When a region fails to meet federal air quality standards, the Clean Air Act requires States to develop a State Implementation Plan (SIP) to outline how the area will improve air quality to meet EPA standards. If a State fails to meet its attainment deadline and does not correct its deficiencies, the EPA can impose sanctions, typically by withholding highway funds. 

In case of serious nonattainment, States must show incremental ozone reductions averaging three percent per year over three years until the area reaches attainment. Approved in 2012, Colorado’s SIP incorporates new emissions control measures through consistent updates. Recent provisions include limiting the emissions of NOX from major power plants, such as the Cherokee and Arapahoe facilities (PDF) in the Denver metro area.

Colorado’s SIP includes three essential components: (1) a demonstration that the State ultimately reaches attainment, (2) a demonstration of ongoing progress towards that goal, and (3) a budget allowing enough ozone emissions for vehicle use. 

To meet these requirements, Colorado has passed numerous laws addressing ozone emissions.

Recent legislative action 

In 2024, the Colorado General Assembly passed SB24-229, which requires the AQCC to propose rules that will reduce NOX by fifty percent in certain areas by 2030, relative to 2017 levels. The bill also mandates enhanced reporting on enforcement actions, including penalties levied against violators.

Other recent initiatives include incentives to use public transportation, such as free transit days during the summer, and updated coordination requirements between the AQCC and the Colorado Energy and Carbon Management Commission to regulate pollution control measures.

These measures reflect a consistent effort to achieve air quality regulation by improving different sectors that have an impact on ozone levels. 

Has Colorado’s air quality improved?

Since 2007, Colorado experienced a significant population increase of over a million people, coupled with a booming increase in oil and gas production. Without any regulatory intervention, these trends would have led to a significant increase in emissions. 

Instead, ozone levels have remained largely flat, which suggests that emission reductions from stricter oil and gas regulation, promotion of electric vehicles and other control measures helping keep the smog under control. 

However, constant ozone levels do not satisfy the increasingly high federal standards. State regulators now face a moving target of reducing total emissions while population and economic activity continue to grow.

How you can get involved

Public participation plays a crucial role in public affairs, and air quality regulation is no exception. SDSG has begun tracking air quality regulation. All members of the public are welcome to attend public hearings and submit comments, provided they register beforehand. 

The next meeting will be held from February 18th to 20th, 2026. The agenda includes a request for a hearing on particulate matter maintenance plan revisions for nonattainment and air quality standards. If you feel concerned about Denver’s air quality and the health impacts of smog, engaging in this process provides a direct, impactful way to make a difference. 

As Colorado keeps working to comply with clean air standards, sustained attention and participation will help determine whether the brown cloud will give way to the Front Range again.

Indonesia’s nickel refining boom: lessons for other mineral-rich countries

Indonesia’s policies have supported the growth of a nickel refining industry. This experience offers valuable insights for countries pursuing a similar path.

By Lorenzo Cotula and Brendan Schwartz

Lorenzo Cotula is head of IIED's law, economies and justice programme; Brendan Schwartz is Executive Director at the Sustainable Development Strategies Group

Read this blog in Indonesian here.

Nickel smelters in Sulawesi, Indonesia (Photo: copyright Adam Pantouw)

In low- and middle-income countries looking to harness their mineral wealth for industrial development, Indonesia's nickel sector is often touted as a success story. As the world’s dominant nickel producer, Indonesia has rapidly developed a sizeable domestic refining industry, creating jobs and increasing the value of nickel-derived exports.

Eager to break from trading patterns that have long confined them to exporting raw materials, governments in many mineral-rich countries are looking to emulate Indonesia’s model and promote industrialization.

Our recent visit to the island of Sulawesi – a hotspot for Indonesia’s nickel industry – highlighted a more complex picture. The visit was part of the Advancing Land-based Investment Governance (ALIGN) project, which over the past two years has supported activities to strengthen the governance of nickel operations in Southeast Sulawesi.

A more rounded understanding of Indonesia’s nickel refining boom can provide insights for policymakers seeking to renegotiate the way costs and benefits are distributed in critical mineral supply chains.

the nickel boom

In Indonesia, nickel mining has expanded substantially over the past 15 years. It is estimated that, as of late 2023, nearly one million hectares of land were under nickel mining permits, primarily on the Sulawesi and North Maluku islands.

Today, Indonesia accounts for about 60% of global nickel production. A good part of this nickel is for batteries and steel used in electric cars.

Through measures adopted since 2014, the government restricted and ultimately banned the export of unprocessed nickel ore, aiming to promote local value addition. Regulations also mandated mining companies to refine locally the nickel they extract – or to otherwise sell it to existing local smelters.

Within a few years, new nickel smelters were built in large industrial parks in Sulawesi and North Maluku, primarily by Chinese firms, establishing extensive local value addition capacity and consolidating Indonesia’s (and China’s) dominant position in global nickel markets.

one size fits all?

The success of Indonesia’s policies in promoting local value addition has encouraged several other mineral-rich countries to also restrict exporting raw materials.

Yet, the effectiveness of Indonesia’s export restrictions – which were found to be in breach of World Trade Organization rules (PDF) – is partly due to a unique set of conditions, such as the country’s commanding share of global nickel production and reserves, that are not necessarily present in other mineral-rich countries.

If governments replicate the same measures without Indonesia’s scale and leverage, they may not necessarily secure hoped-for benefits. Ill-suited restrictions could even undermine the viability of the country’s mining industry.

the captive coal lock-in

The rapid growth of Indonesia’s nickel refining industry has primarily relied on captive coal (coal-fired plants built to exclusively service a smelter).

While this has ensured steady access to energy, it makes Indonesia’s nickel particularly carbon intensive, creating a paradox for an industry that is supposed to support the energy transition.

Besides increasing carbon emissions, reliance on coal drives deforestation – for example in Central Kalimantan, where coal mining has expanded to meet the nickel smelters’ demand.

A 2022 regulation envisages measures for Indonesia’s electricity sector to transition away from coal-fired power, including a ban on new coal plants. But the ban exempts captive coal for domestic value addition, provided certain conditions are met.

Nickel-linked captive coal capacity has grown nearly fivefold (PDF) in 2014-23 and is projected to expand further over the next few years, barring a market downturn.

Efforts are underway to decarbonize the nickel supply chain but options are limited by the smelters’ geographic location – close to mines and ports, rather than renewable energy sources – and their need for vast amounts of reliable energy.

Meanwhile, plans to convert the power plants to mix coal with biomass (‘co-firing’) would greatly increase deforestation (PDF) due to the large plantations needed to produce biomass feedstock.

Rapidly growing industries and effective regulation

Stepping up in the value chain can help grow and diversify economies in low- and middle-income countries, many of which struggle with a dependence on commodity exports and with substantial debt burdens. Indonesia’s success in developing nickel value addition has created thousands of jobs.

But the sector has been marred by workplace accidents. And in Sulawesi and North Maluku, nickel mining and refining have been associated with extensive social and environmental impacts, including deforestation, land disputes, air pollution and water contamination. These impacts undermine the livelihoods of forest communities, small-scale farmers and fisherfolk.

Part of the problem is that the nickel industry’s rapid growth has outpaced capacities to effectively regulate the sector. For example, many nickel projects operate on small islands, in violation of a 2007 law that bans mining on such islands (the Constitutional Court upheld the legality of this ban in 2024).

In June 2025, public outrage about mining on small islands in Raja Ampat – home to some of the world’s most iconic coral reefs and marine life, and a big draw for tourists – prompted the government to suspend four mining permits.

In addition, the government reclaimed large areas of land under oil palm plantations and nickel and coal mines that were operating illegally on forest areas.

But civil society organizations and mine-impacted communities continue to highlight widespread non-compliance with applicable regulations, for example with regards to air pollution, mine reclamation and managing mine tailings.

Extracting lessons for policy

In Southeast Sulawesi, civil society organizations, with support from ALIGN, have been doing important work to address these problems – from promoting compliance with the ban to mine on small islands, to supporting community empowerment around mining sites and informing revisions to the provincial spatial plan that would restrict mining in heavily forested and biodiversity-sensitive areas.

In mineral-rich low and middle-income countries looking to promote domestic value addition, policymakers should carefully think through strategies tailored to their contexts. Holistically considering the social, environmental and economic dimensions of Indonesia’s experience provides helpful insights.

First, Indonesia’s experience highlights the conditions that need to be in place for certain industrial policy measures – such as local processing requirements – to be effective.

Second, it highlights the need for governments to proactively address issues that will affect the sector in the longer term, such as the management of mine reclamation and tailings, more participatory and inclusive spatial planning, effective community engagement (PDF), land rights recognition and low-carbon energy solutions.

In this vein, governments should consider energy options from the start, such as locating processing plants close to renewable energy sources, to avoid being locked into unsustainable arrangements that can ultimately hurt their global competitiveness.

Finally, Indonesia’s experience highlights the major impacts and complex trade-offs that can arise in industrialization processes – and the need for effective state capacity, regulation and enforcement throughout mineral supply chains.