Daniel Höllen

30 August

p. 5, no 4: From my perspective a supergene deposit may be found in the anthroposphere if the soil in this region is used by mankind. However, it is still a natural and not an anthropogenic resource: Not all resources in the anthroposphere are anthropgenic resources. 

 

p. 5: There is not only an overlap between the applcation of the Anthropgenic Resource Specifications and the Renewable Energy Specifications, but also an overlap between the language of Mining Economics and Waste Management which should be mentioned here as following point no. 8: "The classification of a material as an anthropogenic resource is independent from a classification as a waste. A waste does not cease to be a waste when it is recognized as a resource, but only in the very moment when it is properly recycled or reused or when the end of waste is reached prematurely according to an end-of-waste ordinance. All phrases that a waste "turns into" a resource or a raw material must therefore be avoided because they are legally incorrect, as a material can be both / all three at the same time. 

 

p. 6, no. 9: "construction minerals" is not correct, as it not a single mineral, but a whole rock that is used for construction purposes. The more appropriate term referring to rocks used for industrial purposes is "pit & quarry", so I suggest to include "pit & quarry, industrial minerals" instead of "construction minerals and other minerals". 

 

p. 8, no. 16: The term by-product should be defined and distinguished from the term waste based on the EU Waste Framework Directive. Generally, I recommend to add a no. 17 "waste" which defines this term according to the Waste Framework Directive as well, because it has significant legal and economic consequences. It has furthermore to be distinguished from the term "mining waste" which is defined in the EU Mining Waste Directive.