Freddy Brookes is a Principal Environmental Scientist with more than 20 years of experience supporting planning, permitting, environmental assessment and lender-financed mining projects across the UK and Europe. A full member of the Chartered Institute of Ecology and Environmental Management (CIEEM), he specialises in biodiversity assessment, ecological risk management throughout the project lifecycle, from feasibility studies and baseline surveys through to ESIA, permitting, construction and closure. Freddy has extensive experience applying the Habitats Directive, Birds Directive and Natura 2000 requirements to major mining and infrastructure developments. This includes supporting Appropriate Assessments, developing mitigation strategies, and understanding Article 6 derogations, including Imperative Reasons of Overriding Public Interest (IROPI) cases where projects interact with designated Natura 2000 sites. He is experienced in the application of IFC Performance Standard 6, EBRD Performance Requirement 6, EU Taxonomy requirements and critical habitat assessments, including the development of mitigation hierarchies, biodiversity offsets and habitat restoration programmes. His expertise extends to demonstrating no net loss for priority biodiversity features and achieving measurable net gain outcomes for critical habitats, helping clients deliver robust, bankable and nature-positive projects that satisfy regulatory, lender and stakeholder expectations.
What effect is the EU Taxonomy “Do No Significant Harm” process having on mine permitting and environmental impact assessment in the European union?
The "Do No Significant Harm" (DNSH) principle has emerged as an influence on project financing, environmental permitting, and Environmental Impact Assessment (EIA) practice. Originally introduced through Regulation (EU) 2020/852 (the EU Taxonomy Regulation), DNSH requires economic activities to avoid significant harm to six environmental objectives, including climate change, water resources, pollution prevention, circular economy, and biodiversity protection. For the mining sector, DNSH is altering both the content and scrutiny of EIAs by requiring a more integrated, lifecycle-based assessment of environmental impacts. While DNSH is not a permitting regime in itself, it increasingly influences access to finance, public funding, strategic project designation, and regulatory decision-making. This presentation examines how DNSH is influencing mine permitting across the EU, evaluates its implications for EIA practice, and discusses challenges between environmental protection and the EU's ambition to expand domestic critical mineral production. Case studies used demonstrate that DNSH is driving more comprehensive environmental assessments but may also increase permitting and financing complexity and project risk. Keywords: DNSH, EU Taxonomy, mining, Natura 2000, derogations, EIA, permitting, critical minerals, biodiversity, sustainability.
