The GF’s Advocacy on Mining

The Goa Foundation has been working on implementing intergenerational equity commencing with mining. This has involved advocacy with a variety of Indian and international entities on a number of related issues. We have also joined a number of coalitions as well as founded/co-founded a few. This page archives some key aspects of our work on mining in & beyond Goa.

At the heart of our work is the shared inheritance paradigm. In essence, we see natural resources, including minerals as a shared inheritance where the state is owner of these minerals as a trustee on behalf of the people and especially future generations. The intergenerational equity principle asks us to ensure our children and future generations inherit at least as much as we did. And mining is eventually the sale of the shared inheritance of minerals, and the depletion of a bunch of related inheritances.

Global Advocacy

UNEP on Mineral Resource Governance

In response to a UNEP consultation, we submitted this eight page summary of how mineral resources should be managed with an intergenerational equity perspective (2020)

Ethical Government Accounting

This is a strand of work that is potentially our most important. We are trying to change the way governments account and report on their management of inherited mineral wealth. In summary, we argue that minerals should be reported as an asset prior to extraction; mineral sale proceeds resulting from extraction or sale should be recorded as capital receipts, not revenue; and the loss, if any, should be recorded as an expense. At a deeper level, we argue for viewing minerals as a “shared inheritance”, not as a source of “windfall revenue”. Finally, we have proposed the “Goa Foundation Benchmark” for evaluating the management of mineral wealth.

The Goa Foundation benchmark has three parts: (a) sell the minerals with zero loss in value; (b) save the entire sale proceeds in a future generations fund invested in a global portfolio of low cost mutual funds; and (c) distribute only the real income as a citizens’ dividend, equally to all. It is easy to demonstrate that the Goa Foundation benchmark outperforms the Strong Pareto Improvement, as everyone is better off without any redistribution of wealth or income.

This work began in 2016 with a note that was sent to the IMF, World Bank, UN Statistics, IPSASB, INTOSAI as well as India’s MoF, MoSPI, CAG, CGA, etc. We have also joined the global Capitals Coalition.

Mitigating the Resource Curse by Improving Government Accounting (2016)

Government accounting and the Resource Curse – Response to FAQs (2017)

Letter to IMF Managing Director on the Arctic Refuge, USA (2018)

Letter to UN Committee of Experts on Environmental-Economic Accounting (UNCEEA) (2018)

This research led to an academic paper co-authored by our Research Director, Rahul Basu & Scott Pegg, titled Minerals as a shared inheritance: Accounting for the resource curse (preprint / published) (2020)

Partly as a result of our advocacy, IPSASB placed a new standard on Natural Resources in their draft Work Plan for 2019-23. Our Response to IPSASB Consultation on Work Plan 2019-23 (2018) was supported by a diverse range of organisations and individuals. The IPSASB put a new standard on Natural Resources as their top priority in their Work Plan 2019-23.

Response to IPSASB Consultation Paper on Natural Resources (2022).

We have also had some success with the IMF and UN Statistics.

Deep Seabed Mining in the Area Beyond National Jurisdiction

Under the United Nations Convention on the Law of the Sea (UNCLOS), deep sea minerals in the Area Beyond National Jurisdiction are the Common Heritage of Humankind. We believe that the Common Heritage of Humankind must be managed keeping the intergenerational equity principle foremost. We have launched a petition on this jointly with TFWN, and have also joined the global Deep Sea Conservation Coalition.

Petition on Deep Seabed Mining in International Waters (2020, jointly with TFWN) (sign as an organisation / individually)

Our comment on the draft EIS from India’s Ministry of Earth Sciences (2020)

Inter-Governmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF-MMMSD or IGF)

The IGF, hosted by the International Institute for Sustainable Development (IISD) has over 70 member countries including India. It supports governments to advance good mining governance for the betterment of communities, economies, and the environment. The IGF partnered with the African Tax Administration Forum (ATAF) in 2020 on the project titled The Future of Resource Taxation

GF comments to IGF IISD & ATAF on the Future of Resource Taxation (2020)

GF idea on The Future of Resource Taxation (2021)

GF comments on public consultation on 10 Innovative Policy Papers on the Future of Resource Taxation (2023)

Indian Advocacy

India’s management of mineral wealth

Letter to Minister of Mines on needed amendments to MMDR Act, 1957 (11.8.2014)

Letter to Finance Minister, GOI on structure of Goenchi Mati Permanent Fund (9.9.2014)

Letter to Secretary Mines, GOI with comments / suggestions on MMDR (Amendment) Bill, 2014 (4.12.2014)

Letter to Secretary Mines, GOI with additional comments / suggestions on MMDR (Amendment) Bill, 2014 (10.12.2014)

Letter to Rajya Sabha Select Committee on MMDR Amendment Bill 2015 (13.3.2015)

Comments on Approach Paper for Auctioning Coal Mines (19.12.2014)

Representation to Parliamentary Standing Committee on CAMPA, Goa Mining and Environment (6.2.2016)

Comments on discussion paper on ‘Auction of Coal Mines for Commercial Mining’ (6.6.2017)

Letter to K.R. Rao Committee on draft National Mineral Policy (11.9.2017)

Detailed note titled The Future We Need: National Mineral Policy (11.9.2017)

Letter 2 K.R. Rao Committee on draft NMP (6.10.2017)

Letter 3 to K.R. Rao Committee on draft NMP (16.10.2017)

Letter to Secretary Mines, UOI on extension of leases u/S 8A5&6 without auction (10.8.2017)

Letter to Mining Ministers on National Mineral Policy (18.1.2018)

Representation on draft NMP (18.1.2018)

Letter to 15th Finance Commission (14.2.2019)

Letter to Secretary, Ministry of Finance, GOI on FATF, PMLA, theft and illegal mining (20.7.2020)

Letter to Ministry of Mines on Proposed Reforms in Mining Sector (26.8.2020)

2nd letter to Ministry of Mines on Proposed Reforms in Mining Sector (3.9.2020)

Letter to Ministry of Mines on MCR 2016 IBC Lease Transfers (16.2.2021)

Letter to Ministry of Mines on Mineral Auction Rules amendment to encourage early extraction (17.2.2021)

Letter to Ministry of Mines on additional proposed MMDR amendments (18.2.2021)

Letter to Ministry of Coal on additional proposed MMDR amendments (22.2.2021)

Letter to Ministry of Mines on proposed Auction & Evidence of Mineral Contents Rules amendment (11.5.2021)

Letter to Ministry of Mines on Approach Paper on Draft National Mineral Index (2.12.2021)

Comptroller and Auditor General, India

Letter to CAG Goa on the urgent need for a comprehensive audit of mining and mineral resources in Goa (22.9.2014)

Letter to Additional Deputy CAG about inadequate public accounting of mineral receipts (4.12.2014)

Complaint to Principal Accountant General, Goa about inadequate public accounting of the shared inheritance of mineral wealth in Goa (14.4.2020)

Complaint to Principal Accountant General, Goa about inadequate public management of two major trust funds: the Goa Iron Ore Permanent Fund (GIOPF) and the District Mineral Foundation funds (DMFs) by Goa government authorities (15.6.2020)

Government Accounting Standards Advisory Board (GASAB)

Letter to Chairperson GASAB titled Existing government system of accounting is making India poorer (25.9.2020)

Letter 2 to Chairperson GASAB titled Existing government system of accounting is making India poorer (7.10.2020)


Organisation building & collaborations

Organisations Founded

Goenchi Mati Movement (GMM). We are a group of people advocating a set of reforms to mining, based on the twin principles of community ownership and custodianship of minerals, over our natural resources. We believe mining can be done responsibly, and keeping in mind future generations of Goan citizens, who can benefit from it too.

The Future We Need (TFWN) is a global movement to make intergenerational equity foundational to civilization, starting with minerals

Mineral Inheritors Rights Association (MIRA) is an emerging coalition of 30 diverse civil society groups, networks, and individuals in India working to ensure democracy, social justice, equity, transparency, and accountability in the extractive sector. It is affiliated to the global Publish What You Pay (PWYP) movement.

Despite the fact that the National Mining Policy, 2019, defines minerals as a “shared inheritance with the state acting as trustee,” the Indian extractive industry has yet to embrace this mandate. Overextraction, undervaluation, secrecy, and misgovernance have resulted in long-term losses for short-term gains in India. We are not only wasting valuable resources, but we are also cheating our children of the mineral wealth they should have inherited.

Together, we can ensure transparency, accountability, and intergenerational equity in India’s extractive industry.

Organisations Joined

In order to further our approach to extractives, we joined Publish What You Pay (PWYP). PWYP is the worldwide campaign for an open and accountable extractive industry. We are the only global movement working to ensure that revenues from oil, gas and mining are used to drive development. With more than 1000 member organisations and 51 national coalitions, our strength lies in our ability to coordinate action nationally and globally, maximising our collective impact, so everyone benefits from their natural resources – today and tomorrow.

As part of our work on international standards for government accounting, standards and reporting, we joined the Capitals Coalition. The Capitals Coalition is a global collaboration redefining value to transform decision making. We sit at the heart of an extensive global network that has united to advance the capitals approach to decision-making.

The Deep Sea Conservation Coalition (DSCC) was founded in 2004 in response to international concerns over the harmful impacts of deep-sea bottom trawling. Today over 100 non-government organizations, fishers organizations and law and policy institutes worldwide are working together under the umbrella of the DSCC to protect vulnerable deep-sea ecosystems.