Alexa Romano is an Environmental and Social Specialist with experience supporting environmental assessment, permitting, and sustainability projects across the mining, energy, infrastructure and industrial sectors. She has worked on projects throughout Africa, the Middle East, Europe and the South Atlantic, supporting developments from early-stage studies through to permitting, ESIA, construction and operations. This work focuses on helping clients identify and manage environmental and social risks while navigating complex regulatory and stakeholder requirements. Alexa has extensive experience in environmental and social impact assessment, socio-economic assessment and project permitting, working to international standards including the IFC Performance Standards and Good International Industry Practice (GIIP). This experience includes leading and coordinating multidisciplinary assessment teams, developing permitting strategies, and delivering social and economic studies, environmental monitoring programmes and stakeholder engagement activities for major resource and infrastructure projects. Experience spans both lender-financed and regulatory-driven projects, supporting clients to develop robust, practical and defensible assessments that meet regulatory, lender and stakeholder expectations.
What Effect is the EU “Do No Significant Harm” Process Having on Mine Permitting and Environmental Impact Assessment in the European Union?
The European Union's "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 paper examines how DNSH is transforming mine permitting across the EU, evaluates its implications for EIA practice, and discusses emerging tensions between environmental protection and the EU's ambition to expand domestic critical mineral production. Case studies from Portugal and Finland demonstrate that DNSH is driving more comprehensive environmental assessments but may also increase permitting complexity and project risk. Keywords: DNSH, EU Taxonomy, mining, Natura 2000, derogations, EIA, permitting, critical minerals, biodiversity, sustainability.
