Introduction:
(i) I feel ASM could be characterized as people/families/communities and how ASM fits into livelihood strategies. Stark examples of the relative incomes achievable from ASM compared with everyday livelihood activities (agriculture) needs to be brought out. Ultimately no matter how good community development and engagement ASM will persist.
(ii) I feel that more has to be made of the perception of ‘illegality’ as this has historically defined (and even given a legal basis for) how ASM can be treated.
(iii) Also some consideration of what is achievable – mitigation, control, avoidance on and around ASM? – and over what time frame?

Business Case:
Using CSR as a general rationale is somewhat too easy and at the field level I imagine there would be some push-back to this general all encompassing obligation created by the adoption of CSR. At the field and corporate level I think more needs to be made out of (i) recognition that “illegal’ mining is not necessarily illegal; (ii) recognizing inherent conflicts between national and local community approaches; (iii) looking at the safety and security as key drivers – companies spend a lot of money on safety and security and illegal miners are a major problem. Where conflict occurs with security forces, violence, death, etc significant negative reporting and evaluation can occur in the public field without proper understanding of what is happening and driving events at the field level. So security, safety, continuity of operations and reputation are key business drivers. Some survey data from some mines around the world re events, resources spent, lost production time, etc would be great! A ‘social license to operate’ is part of the outcomes from addressing ASM but I do not know to what extent ASM are the determinants of the “social license to operate” as opposed to a contributor to it. In fact in certain circumstances in ASM can occasionally be part of a problem in CESD as they are migrant, they have no defined rights, they settle and cause various induced impacts, etc.

Profile of ASM;
ASM are categorized as belonging to one of 4 types. However the ASM themselves are not characterized in general or specific terms. From above - ASM could be characterized as people/families/communities and how ASM fits into livelihood strategies. Stark examples of the relative incomes achievable from ASM compared with everyday livelihood activities (agriculture) needs to be brought out. Cases must of course vary but it would be interesting to see whether any profiling can occur – e.g. are ASM typically local or migrant? What is there educational level? Do they become settled? Are there induced impacts on local communities? Some profiling actually may help better understand which interventions are “better” .

Community development and business development:
(i) agree with the focus on legislation and formalization but can this be characterised as community development? Furthermore this is longer term legal and institutional change requiring support from govt etc.
(ii) resettlement, basic services, etc are not ASM specific and it is not necessarily clear that all ASM should benefit from such interventions.

Companies have specifically requested a thorough definition of the different types and characteristics of ASM, including the legal/illegal component. The definitions table appears to be aimed at the development field rather than company realities and we think it would be advisable to reinstate the legal/illegal aspect.

The Axes:
We feel that the document would be of more use to companies if the approaches and interventions outlined were situated within the mine project lifecycle – giving indication as to how and when approaches and interventions should employed. Perhaps a diagram demonstrating the project lifecycle alongside the types of interventions and approaches would be useful – emphasising early engagement to avoid reactive measures in the future.

We have found the definitions of the Axes somewhat confusing and contradictory. Whilst this type of approach may be useful in demonstrating the underlying points, care needs to be taken to ensure that the definitions of the axis make sense and are in line with the approaches outlined underneath each Axis e.g.:

• Currently Axis 1 addresses the mainstreaming of community partnerships between LSM and existing ASM, however some of the approaches listed under this axis e.g. promoting ASM sector regularisation and providing technical assistance are more focussed on ASM/LSM partnerships, rather than community partnerships. We must also remember that ASM and communities are not always synonymous; the approach in this document seems only to refer to ASM in relation to the local community.
• Axis 2 – Is this meant to be a step by step guide? If so, the document moves very quickly from the removal of ASM from company owned land to the formulation of ASM/LSM partnerships. This is somewhat contradictory – careful consideration is needed to ensure that the axes have a clear focus and that approaches and interventions appear in a succinct and understandable order.

The document needs to state more clearly how the approaches are interlinked, although there is some text to demonstrate this, a visual representation of the inter-linkages and the importance of not treating each approach in isolation may be clearer and of more use.

The Axes fail to cover some of the key issues and onsite realities:
• There is no mention of onsite security, we have to be realistic and have to offer advice on potential security measures e.g. buffer zones.
• There is no mention of human rights and the importance of companies adopting and formulating tools and programmes to implement key guiding practices into company policy e.g. Voluntary Principles
• No emphasis has been placed on the importance of the company’s internal role and responsibility

Case studies:
Whilst it is very useful to use case studies to illustrate key points, we feel that the document has been overwhelmed by the number used leading to a dilution of the focus of the document. We must remember that although case studies can be a guide of best practice, they are not generic and should not be replicated by companies point by point. We are concerned that some companies may follow the case studies verbatim and not pick and choose approaches most suited to their particular situation. Therefore we feel that the document could benefit from a more general, non place/company specific guide to possible approaches and interventions.

Companies are interested in the use of new and innovative approaches; the document should be more than just a rework of past case studies and reports that already exist.

Care also needs to be taken to ensure that the case studies used are the ones that best illustrate the point and are not out of date.

End text:
The end section provides a good summary of some of the main overarching points and begins to bring out some of the more ‘forward thinking’ approaches. It is a shame that this has not been covered in greater depth at an earlier stage in the document.

Some general comments:
• As a principal, it is the role of governments and the state to address the issue of formalization of the ASM sector – it should be acknowledged in the report that LSM can only carry out actions that are complementary to this and is unable to address all the issues surrounding ASM alone.
• The IFC performance standard on resettlement is mentioned, however the focus seems to come across as more on household resettlement. This may of course be relevant, but the economic resettlement element of the IFC standard should also be highlighted, which may be more relevant when LSM starts to work in areas that were previously artisinally mined.
• The document tends to imply that all stakeholders will want to work towards mutually agreeable solutions. However, it should be recognised that some ASM activities are controlled by criminal gangs who have a vested interest in not reaching workable accommodations. In the same vein, not all LSM mining companies may be interested in looking for solutions and, if possible, options for corralling such players into collaborative frameworks should be discussed.
• All the actions identified in the report are relevant to permanent or seasonal ASM – there are not many suggested actions that for shock-push or rush ASM. It is much more difficult to consider actions in these situations, but a discussion on this should be included in the report – and the difficulties surrounding this kind of situation should be acknowledged.
• As a point of departure a holisticapproach to dealing with ASM is being presented which we would agree with. However, for an ASM strategy to be sucessful it needs to be part of a holistic community relations and social development strategy as these issues cannot be handled seperately from the overall community approach. This should be stressed up front. The ICMM Community Development Toolkit could be referenced as resources that will help with planning engagement and consultation, management measures etc.
• Some case studies could be sourced from Goldfields Ghana (see paper ‘Live and let Live’ which Anthony Aubynn authored).
• On page 33 there is a discussion on employing ASM as mineral suppliers. The implications with regards to LSM companies not complying with international norms is mentioned as a risk, but merits more discussion. The threat of accusations of non-compliance with human rights, child labour, etc. is significant issue –and in order to overcome this many players will need to be made aware of ASM issues and participate in developing solutions.
• The issue of security considerations and how to manage these issues needs a lot more attention and we would recommend that reference is made to the Voluntary Principles on Security and Human Rights as a useful source

Specific comments
• Page 5 – the table 1.1 describes only one type of ASM (e.g. the points on ‘traditional rights to access minerals’, ‘support from local administration’ and ‘support from local communities’ do not always apply). It could also be mentioned that it is often a more lucrative form of livelihood than various alternatives. The box 2.1 in the following section does a good job of describing the different kinds of ASM. It is noted that Industrial operations "have access to national and internation media" This point is not understood and it may be more accurate to say that the are "being watched by..."
• Page 7 – In a number of cases, the perception from the ASM sector is that they are used as ‘exploration meters’ by the LSM sector. Under Competition versus Complementarities it could also be mentioned that these groups are however often mining different ore bodies and that LSM often accesses those that would not be available to ASM.
• Page 8 – the reference to the law in Ghana is outdated. The new law should be included ‘Minerals and mining law 2006 703 (see also table 2.1)
• Page 10 – the table 2.1 (ASM related laws) may sit better in an annexe (minor comment)
• Page 11 - ASM may well be discovering ore bodies but are they the kinds of discoveries that are meaningful to a LSM? It is questionable if this can be portrayed as the norm.
• Page 12 - The header “Complying with Corporate Responsibility” should be changed. Compliance normally implies regulations or obligations, whereas as CSR is more usually associated with actions that go beyond compliance, including in areas where there are no regulations. It is not the UN Voluntary Principles but rather just the Voluntary Principles.
• Page 13 – the table 2.2 is useful. It could be useful to include what the actual ASM requirements are within the different codes/standards. This would illustrate the extent of actual requirements – which I suspect are not very far reaching (e.g. the GRI MMSS requirement is only to report on any ASM programmes).
• Page 14 – the Typology of actions graph should define the Zero point on the graph as ‘a Platform to Engagement and Dialogue’ upon which all the other actions can build . All of these points should stress partnership - there is a tendancy to focus on the company and the role of governement, donors, NGOs and delivery agents and communities themselves should also be touched on even if briefly.
• Page 15 –the Nambija-Ecuador case study could better clarify why the purchasing of ASM properties worked in Ecuador but not in Nambija. Although the case study explains that the Ecuadorian context was more formalized, it might be useful to explicitly state what prevented the miners from hanging on to their concessions like they did in Nambija
• Page 15 – would be useful to highlight that developing community partnerships works for permanent and local seasonal ASM activity – other (non-local) seasonal miners would also have to be considered. And again that ASM is only one component of a broade community development strategy. Given too much focus to this issue at the expense of those who do not mine could lead to resentment.
• Page 16 the footnote on Page 18 should be moved into the main text on page 16.
• Page 17 - AGA is still considering whether it wants this case study included.
• Page 19 - Type of Interventions - add: Contribute (as a partner with government) to local infrastructure...Help NGOs - change to Work with NGOs
• Page 21 - why is "too much dependence on high-level top down approaches" a risk? What other way is there to get legislative reform?
• Page 23 Risks - add "resistance to formulization due to increased tax and bureaucratic constraints" Could also include under risks issues around risks posed by middlemen who don’t necessarily want to get cut of the network.
• Page 24 – the results of Boroo case study would benefit from further clarification of what each party gained from the agreement (what does the ‘nomralization of the ASM operations’ mean?, was the company originally responsible for ASM H&S liabilities?, how was the ongoing maintenance of H&S standards addressed?) Under Type of Interventions - what does "direct assistance" entail; Ensure and Oversee are big words and assumes the company is taking responsiblity and liability for these activities - perhaps "support" is a better word.
• Page 34 – the Mwadui case study results: reduction of running costs through outsourcing non-core business activities ... (for example , social infrastructure and parts of the former mining compound). The example in the parenthesis is not clear – what are the non-core business activities that were outsourced?
• Page 38 - table 4.1 Sample Participatory Monitoring and Evaluation. This is a good table, but needs some context – why is it included in this section and not other tools for community development?