Economic Exploitation Plan: Details and Requirements in Brazilian Mining Regulation

The Economic Exploitation Plan (PAE) is a crucial document for mineral deposit exploitation in Brazil. Its submission is mandatory to obtain the Mining Concession Application from the Agência Nacional de Mineração (ANM), as stipulated by Article 38 of the Mining Code. The PAE acts as a detailed guide to the economic viability of a mining venture, covering everything from mineral extraction to its commercialization, including stages like beneficiation and the mine closure plan. The ANM rigorously analyzes the PAE, and its preparation by qualified professionals ensures that mining projects adhere to industry standards and best practices.

The PAE’s importance extends to both the tenement holder and the ANM’s oversight. For the Mining Concession Application, the PAE is one of the required documents, providing a comprehensive technical and economic overview of the project. It must include an analysis of costs, revenues, and profitability, aiming to ensure the financial sustainability of the venture. Furthermore, the document contains vital technical information, such as the exact location of the deposit, the estimated quantity and quality of the ore, and the extraction and beneficiation methods to be employed. As per Articles 38 and 39 of the Mining Code, information like the mineral substances to be exploited, location, mining method, and mine hygiene considerations must be mandatorily included. This thoroughness makes the PAE an indispensable tool for the tenement holder to present a clear and detailed work plan to the ANM. In turn, the Agência Nacional de Mineração uses the PAE as a basis to oversee project execution, ensuring compliance with current regulations and the planned implementation of operations.

The development and processing of the PAE follow a specific procedure that guarantees its validity and legality. It is essential that a legally qualified mining engineer, with an active registration with the Regional Council of Engineering and Agronomy (CREA), prepares the PAE, assuming technical responsibility for the document. After the respective mining tenement is published in the Official Gazette of the Union, the PAE must be filed with the ANM in two copies: one original and one authenticated. The second copy must be kept at the mine facilities, available for ANM inspection. The PAE must also include the signature of the qualified professional, along with the respective Technical Responsibility Annotation (ART). Additionally, it needs to incorporate the technical-economic study of the deposit’s exploitation and the economic viability analysis of the venture. Components such as the Mining Plan (considered the technical and operational “Manual” of the enterprise), the sizing of mining and beneficiation equipment, and the Rescue and Salvage Plan are also part of the PAE.

The Economic Exploitation Plan is required when the venture involves blasting with explosives or the operation of a mineral processing unit, including comminution facilities, excluding screening in aggregate production. If modifications to the PAE become necessary, the request must be made via an application to the ANM. The modification process must be carried out through the ANM’s Digital Protocol system, by selecting the option “Submit Alteration of Economic Exploitation Plan.” The Agência Nacional de Mineração, after technically reviewing the submitted documents, will publish its decision via an abstract in the Official Gazette of the Union, validating the changes. It is important to note that the PAE must be intrinsically linked to the Mine Closure Plan, a document that details the actions for ending mining activity. This demonstrates a comprehensive lifecycle vision that guides the sector’s regulation. In summary, the PAE is a key technical and economic component that directs the exploitation of mineral deposits, ensuring project viability and compliance with ANM requirements.

Founded in 2014, ÍGNEABR operates in the mining sector, focusing on mining regulation and mineral exploration. We have solid experience in managing and maintaining mining tenements with the Agência Nacional de Mineração (ANM) and offer comprehensive consulting for administrative mining processes, including the preparation and revision of the Economic Exploitation Plan (PAE) and its modifications.

Canva/Edited by ÍGNEABR

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