Written submission from Jamie Hinch, Mark Hirons (CRM0037)

Prioritising the Social and Environmental Dimensions of Critical Minerals in the UK

Jamie Hinch, Sarah Raymond, Mark Hirons, Sophus zu Ermgassen, Mike Kendall

With an ambition for 10% of annual UK industrial demand for critical minerals to be met through domestic production by 2035, onshoring is key to the UK’s 2025 Critical Minerals Strategy (CMS).

At the time of writing in early 2026, attention has mostly focussed on the UK’s geological, financial, and legislative potentials and hurdles for critical minerals onshoring. Less attention has been placed on what domestic extraction and processing of critical minerals means from a social and environmental perspective.

In response to question of “To what extent are the priorities set out in the Government’s critical minerals strategy the right ones?” in the Committee’s call for evidence on critical minerals, we answer that a greater prioritisation of the domestic social and environmental opportunities and challenges of critical minerals projects is required. This also responds to the question of: “What further action is needed to accelerate domestic production?”.

Research done by the authors suggests four factors which must be prioritised in order to maximise the domestic social and environmental opportunities of critical minerals projects.

1. Ensuring a just transition
2. Understanding local environments
3. Clarifying Governance
4. Grounding Geopolitics

Authors:

This response to the Business and Trade Sub Committee on Economic Security, Arms and Export Controls’ call for evidence on critical minerals has been written by researchers at the University of Oxford.

This is an adaptation of work from an existing project, titled: ‘The Social and Environmental Dimensions of Critical Minerals in the UK: A rapid assessment, policy stock-take and research agenda’. Funded by the Agile Initiative as a Science to Policy sprint, we have produced the first synthesis of what is currently known and less known about the social and environmental challenges and opportunities of critical minerals in the UK.

The core of our team consists of environmental social scientists (Hinch and Hirons) and ecologists (Raymond and zu Ermgassen) and an earth scientist (Kendall)- all of whom have expertise in resource extraction. We also discussed a draft of this report with experts working in policy, industry, and academia.

1. Ensuring a just transition

Context:

A just transition seeks to utilise the move towards a zero-carbon economy as a means to combat inequality.[1]

There has been extensive recognition and suggestions for the role for critical minerals in a just transition.[2] Yet, in the UK, various organisations have highlighted how the Critical Minerals Strategy could go further in promoting a just transition.[3]

The need for a just transition in the UK is imperative, with industrial industries having significantly declined over the past century.[4] As a result, regional inequality in the UK is among the highest in all OECD countries.[5]

Some of these same deindustrialised regions – like Cornwall and the Northeast of England –hold the promise of critical minerals. The industrial heritage and demise of these regions are highlighted by critical mineral projects[6] and in the CMS. Reindustrialisation and the return of jobs is framed as one of the key incentives for garnering local support. As has been evidenced elsewhere,[7] the promise of jobs alone is not enough for a just transition, however.

De-industrial regions are complex. Communities in these regions often feel ‘left-behind’,[8] with economic impoverishment just one aspect of a bigger picture of post-industrial inequality.[9] In Cornwall, for example, the 2025 Pretty Poverty Report[10] highlighted how conventional poverty metrics such as the Index for Multiple Deprivation (IMD) miss out many characteristics of rural poverty.

The CMS should go further than references to jobs and prioritise a just transition through recognising the importance of the following points:

i. Employment:

Critical minerals projects can be a source of good and sustainable employment. However, uncertainties exist as to the exact nature of these jobs. Modern mining has different employment profiles to historical operations. These profiles tend towards a higher technical base and lower labour intensity.[11]

Key considerations concerning employment include:

-          Automation:

Modern mining practises are increasingly seeing human labour substituted for automation and robotics.[12] As technologies advance, it is likely that lower-skilled jobs will become in increasing jeopardy.[13]

-          Locality:

Whilst nascent mining operations highlight local job creation, this claim can be deceptive. ‘Local’ is often defined as living within a commutable distance. However, those living within the immediate vicinity of prospective operations have been noted to understand local as meaning a far smaller scale. This can lead to feelings of being misled when operations claim to be hiring local people.[14]

-          Skills:

A report by the Institute of Materials, Minerals and Mining (IoM3) makes clear the growing gap between the skills needed for building a domestic critical minerals supply chain and what the UK currently possesses.[15] Whilst it is clear investing in skills is necessary, this requires further research. Inspiration could be taken from the renewable energy industry: Celtic Sea Power’s ‘Cornwall FLOW (Floating Offshore Wind) Accelerator’ project involved a comprehensive regional assessment of the capacity, skills and workforce which would be needed across the supply FLOW supply chain.[16]

-          Re-Skilling:

Whilst re-skilling has been noted as highly important for a just transition, there has been limited research into what this entails.[17]

-          Access:

Research by the University of Exeter has shown that having access to industry networks is vital. This work highlights the importance of critical minerals projects to be engaging directly with local communities.[18]

ii. Local Services

-          Physical Infrastructure:

Mining provides a great impetus to improve physical infrastructure with resulting benefits for communities as well as industry. There is a need to improve transport links (a significant contributor to rural deprivation[19]); the capacity of the energy grid (currently seen as a major constraint for critical mineral projects[20] and over 600 renewable energy projects[21]); and build more affordable housing for workers and to combat regional housing crises.[22]

Furthermore, research has found that some of the most popular actions which mining companies can make concern the development of local amenities. The maintenance and creation of footpaths, for example, to ensure continued access to nature is a popular and low-cost service.[23]

-          Social Infrastructure:

Mining companies were often the historic heart of communities and highly paternalistic. [24] These communities were formerly richly endowed with industry-supported social infrastructure, including schools, playgrounds, parks, libraries, sports and social clubs, bands and carnivals. These sustain the identity of a place and provide environments for community support.[25] Critical minerals projects have a role to play in rebuilding this social infrastructure, with work necessary to identify a framework for this rebuild.

iii. Heritage, Memory, and Perceptions

As studies from both the UK[26] and Europe[27] demonstrate, perceptions of mining are highly ambivalent and irreducible to generational divides. Nostalgia for mining should therefore not necessarily be interpreted as a desire for more mining.

Pits and tips from past extraction might be dismissed as abandoned waste, but communities develop strong attachments to these unorthodox landscape features. These attachments are lively and dynamic, as these sites are often important sites of leisure and recreation for local communities. The prospect of removing China clay waste piles at an exploratory lithium mining operation in Cornwall, for example, is highly controversial and a major reason for local distrust of the mining operation.[28]

iv. Transparency

Perhaps the most important consideration for making domestic critical minerals projects a success in their contributions to a just transition is transparency with local communities.[29] Initial mistrust of mining projects can develop into conditional acceptance when met with transparent and accountable operations.[30]

Communities in former mining areas are often interested and well-versed in knowledge of local land (including its natural environments, ownership, permissions, and geology). Subsequently, any activity in these areas should be clearly, earnestly, and directly communicated at the earliest possible opportunity to stop the spread of misinformation. This has been recently demonstrated in Scotland, with an exploration company subject to negative headlines having not communicated the nature of their operations clearly enough to local communities.[31]

The same is true of critical mineral projects financing. Opacity concerning how projects are being funded and their viability to become commercial impact local community perceptions. If a project seems to be underfunded or lacking clarity over funding, communities are more likely to be suspicious of the operation and dubious over its potential for commercialisation. This reduces local engagement and increases fears that speculative operations will make a mess of the landscape in the exploration phase and never bring in any of their proposed benefits.[32]

2. Understanding local environments

Context:

The CMS does not reference the domestic impacts of either historic or future mining, including their interactions. This is an oversight, with mining providing many opportunities for ecological restoration as well as risk.

Research into the environmental impacts of mining is well-established and growing, with increasing interest in recent years due to rising critical mineral demand and concerns about the impacts of future supply.[33] Most research has so far been focused on direct impacts of mineral extraction[34]; however, there is growing momentum to research indirect impacts beyond the immediate mine site.[35] Key impacts include those associated with land cover change, water resources and biodiversity. In the UK, the majority of environmental impacts of mining recorded focus on pollution and contamination of rivers, including from abandoned mines.[36]

i. Risks

The UK already faces significant water pollution challenges from legacy mines[37], wastewater overflows, and agricultural runoff.[38] Recent data shows no English rivers meet good overall health standards, with most falling below acceptable ecological status.[39] Tailings storage facilities, such as those in Cornwall, pose further risks to ecosystems and human health.[40] Expanding domestic mining for critical minerals could intensify these pressures, particularly as pollutants can spread far beyond mine sites.[41] Careful management of mining waste and water systems will therefore be essential to minimise additional environmental damage.

Mining also has high energy demands and contributes to greenhouse gas emissions and air pollution.[42] Globally, critical mineral extraction accounted for around 10% of emissions in 2018, with demand expected to grow.[43] In the UK, new mining projects could increase particulate pollution and challenge progress toward net zero targets.

Beyond pollution, mining may worsen biodiversity loss and habitat fragmentation in an already nature-depleted country.[44] New sites and infrastructure could disrupt ecosystems, especially where mineral-rich areas overlap with protected or undisturbed land, highlighting the need for thorough environmental assessment and planning.

ii. Mitigation

Effective environmental planning, permitting, and mitigation are essential for responsibly expanding critical mineral mining in the UK. Establishing clear national guidelines and best practices would help ensure consistently high environmental standards across projects. Frameworks such as the mitigation hierarchy prioritise avoiding harm to biodiversity, followed by minimising, restoring, and ultimately offsetting residual impacts.[45] Industry guidance, including that from the International Council on Mining and Metals,[46] supports companies in achieving goals like no net loss of biodiversity. However, such best practices often go beyond legal requirements and remain partly voluntary, though investor expectations and certification schemes increasingly encourage companies to adopt higher environmental standards.[47]

A major challenge in the UK is the lack of standardised planning, monitoring, and permitting processes, with responsibilities spread across local and devolved authorities. This leads to inconsistency, delays, and limited transparency. Calls for a more streamlined system aim to improve efficiency and enable better comparison of environmental impacts.[48]

Where impacts cannot be fully mitigated, biodiversity offsetting (such as the UK’s requirement for a 10% biodiversity net gain) may be applied.[49] However, long project lifespans and weak performance of current offsetting frameworks raise concerns about effectiveness, highlighting the need for improved monitoring, long-term management, and stronger implementation.[50]

iii. Opportunity

The UK presents a unique context for critical mineral mining, as many landscapes are already degraded and may offer opportunities for biodiversity improvement through restoration.[51] Mining in such areas could have relatively lower ecological impact compared to high-biodiversity regions, potentially reducing global environmental harm if supply is shifted away from more sensitive ecosystems. With careful planning, restored mine sites can become valuable habitats, as seen in former quarries that now support amphibians and enhance ecological connectivity.[52] Initiatives such as the Nature After Minerals partnership and international restoration standards provide frameworks to guide effective, long-term recovery, though success depends on sustained management beyond mine closure.[53]

Mining can also create novel ecosystems,[54] where disturbed landscapes support unique species assemblages and provide refuges for specialised or endangered species. These environments can increase landscape diversity and deliver ecosystem services not previously present. However, potential long-term benefits must be balanced against immediate habitat loss caused by extraction.

Alongside restoration, developing a circular economy is critical to reducing reliance on new mining. The UK aims to meet 20% of critical mineral demand through recycling by 2035, [55] but current recycling rates remain low.[56] Expanding domestic recycling capacity, improving technologies, and managing environmental risks from energy-intensive processes will be key to achieving this goal.

3. Clarifying Governance

Context:

Clear, transparent, and inclusive decision making is imperative and yet currently, the governance mechanisms in place for critical minerals onshoring are often opaque and discretionary. The CMS should prioritise clarifying the governance necessary for ensuring social and environmental benefits throughout critical minerals projects.

Due to their national importance and multi-dimensionality, there is a need to streamline the decision-making involved in critical minerals projects:

i. Planning, Permitting, and NSIP

Planning is one of the major concerns of the UK’s nascent critical minerals industry.[57] One study found that in Europe, 74 percent of projects analysed had experienced delays- the most in the world.[58]

The slow nature of permissions and permitting presents social challenges. If projects take too long to get off the ground, preliminary community buy-in may lose momentum and allow doubts over the project to emerge. False promises will create short- and long-term issues for the critical minerals industry and local authorities alike.

The application for Nationally Significant Infrastructure Project (NSIP) status has been a response to the slow planning and permitting phase of critical minerals projects. Approved by the Secretary of State, NSIP allows for the granting of a Development Consent Order (DCO). The DCO grants a single, centralised permission for infrastructure construction as opposed to the multiple local ones which would ordinarily be required.[59]

Whilst obtaining the DCO ensures engagement with local people, it has been repeatedly criticised for inadequate integration of community perspectives. Many local publics involved with NSIP projects have been left dissatisfied and frustrated throughout the pre-application stage and regulatory examinations.[60]

NSIP status, in the minds of local communities, moves the discussion of projects away from ‘whether’ they happen and becomes about ‘how’ they happen.[61] At the pre-application phase, research on renewable energy NSIP’s found communities struggle to access channels of engagement, experience information deficits, and have difficulties asking questions on matters they deem important. The research also found communities encounter insufficient openness to comments, disrespect, and misrepresentation- with the probable long-term impact of the public questioning the legitimacy of these projects.[62] 

Other research on how NSIP projects include local communities has found challenges over who gets involved.[63] As a result, many local people are reported to find NSIP’s community engagement process intimidating and stressful; quickly dismissed as too technical.[64]

ii. Devolved Power

The desire for devolution in Cornwall has been a mainstream sentiment among Cornish publics and politics for over 20 years. Critical minerals have been a growing part of the case put forward for the region’s need for devolution.[65] As the heart of the UK’s critical minerals extraction strategy, MP’s have been calling for devolution as a means to ‘unleash the Cornish Celtic Tiger’ and facilitate critical minerals projects.[66]

Devolution has been argued to enhance democratic accountability and responsiveness, foster economic growth, [67] and better recognise regional identity.[68] Through having one channel of communication to central government, the linkages between mining and energy, housing, waste, and more can be clearly and concisely communicated. These linkages can be lost when multiple lines of communication are relied upon.

Devolution presents social and environmental opportunities. Through bringing decision-making closer to the regions in question, a better understanding of local issues can be integrated into plans for developing critical minerals infrastructure. Affordable housing, for example, is an example of an issue facing Cornwall which will also be necessary to develop for critical minerals project construction and development.

4. Grounding Geopolitics

Context:

The UK has been working closely with international actors to develop bilateral agreements which facilitate supply, research and development, and investment into critical minerals projects both domestically and abroad.[69]

The entanglement between the domestic and the international has ramifications for social and environmental challenges and opportunities.

i. Domestic Mining and International Actors

Questions remain about the extent to which deals with foreign actors will truly maximise benefits for the UK. A key issue concerns the risk involved in relying on foreign actors as major investors in critical minerals projects. This has recently been demonstrated through the case of British Lithium- whom French mining company Imerys hold an 80% stake. One of the two most advanced lithium extraction operations in the UK, British Lithium had hopes for providing 350 jobs once operational and contributing to 10% biodiversity net gain. However, in early 2026 the project was suddenly frozen and placed in a care and maintenance phase. Many employees lost their jobs overnight. Local communities are incredibly frustrated and disheartened by this, tainting their support for other local mining projects.[70]

The example of Imerys British Lithium illustrates the vulnerability of projects essential to the UK’s domestic mining ambitions, yet which do not have explicitly domestic interests at their core.

ii. International Mining and the UK

The UK’s engagements with international mining have repercussions for domestic operations. Too much attention to international projects risks domestic projects and local publics feeling abandoned and under-supported. Nascent operations have already started moving abroad to more favourable international contexts with greater financial support and lower energy costs (such as Less Common Metals moving to France[71]).

Acknowledgements

This work was funded by the Oxford Agile Initiative (NERC grant number NE/W004976/1). It was produced in partnership with the Oxford Earth Initiative.

We would also like to thank Gavin Mudd from the British Geological Survey’s Critical Minerals Intelligence Centre, who contributed strategic oversight for this project.