A number of mineralized areas actually sit under forested zones. So it's quite difficult to balance the interest of mining against preserving our first cover. The obvious solution there is tunneling. But it's costlier and more risky than open pit. It might make sense to allow open pit in non-forested areas.
Whether tunneling or open pit is chosen as mode of extracting ore, the same must be closely regulated.
LGUs must not be given power or authorized to regulate mining as what they are going with respect to artisanal or small scale mining. They are not doing small scale there because miners actually employ heavy equipment.
With small scale mining, there is way too many to regulate (just like LTFRB regulating thousands of jeepney operators as compared to regulating just a few bus companies).
Small scale miners use child labor and cyanide to extract minerals from ores. They don't have dams to leech cyanide from water before discharging to waste water to streams and rivers.
Small scale miners don't sell gold to the BSP as required by law. They are too numerous to be regulated.
Small scale miners put up and support private armies. They make or break politicians.
It's costly to conduct mining in the Philippines. Mining companies have to build and maintain roads and bridges so they can transport ore. They have to build ports close to the mine site. They also have to employ a battalion of ex-Army and Marine personnel and arm them to the teeth to ward off threats from the NPA and lawless elements. These are things that must be provided by the government but mining companies end up providing because the government does not care about them. All that the government does is collect revenues from mining. Mining companies in Canada and Australia don't have to do these.
As to requiring mining companies to put up a refining facility, mining companies don't find it viable because of the high cost of electricity. Each mining company would not put up one refining facility. If at all, one refining facility might cater to the outputs of several mining companies to support the volume required. They don't want to end up like PASAR in Isabel, Leyte.
Don't get me wrong. I'm not an apologist for big mining companies here. I just want to share some insights about mining. And from there we can build our informed opinions.