⏩ Issue 20: Alcoa

Last week we looked at Greatland Resources and found the most candid writing about community and land access sitting in the risk section rather than the sustainability pages.

This week, Alcoa, and a similar problem in a different part of the document. Alcoa mines bauxite at Huntly and Willowdale in the Northern Jarrah Forest, on a mineral lease that covers a very large part of the Darling Range. The company is currently modernising its Western Australian mining approvals under the federal EPBC Act. If its agreement to buy South32's bauxite and alumina business completes, Boddington and Worsley join Huntly and Willowdale under one operator.

The report was published in June 2026, while those approvals are still being assessed. So I read it looking for one thing: where does Alcoa say it will not mine, and what does the report tell you about those boundaries?

— Bronwyn

Source: Alcoa 2025 Sustainability Report (111pp) · Published June 2026 · Reporting period the 2025 calendar year for operations where Alcoa has management control · Prepared with reference to the Global Reporting Initiative (GRI) Universal Standards, the SASB Metals and Mining Standard and the ICMM Principles · Selected performance indicators independently reviewed under limited assurance by ERM Certification and Verification Services Inc. (ERM CVS).

Alcoa is a US-listed aluminium producer operating across the value chain, from bauxite mining to alumina refining to smelting. In Australia it mines bauxite at Huntly and Willowdale in the Darling Range, refines it at Pinjarra and Wagerup, and smelts at Portland in Victoria. It announced the permanent closure of its Kwinana refinery in September 2025.

The company reports on a calendar year, so this is the 2025 report published in June 2026.

Twenty six thousand hectares that Alcoa holds the right to mine and has said it will not.

Directly above it on the same page sits another passage. "In response to local stakeholder concerns, Alcoa revised proposed low impact exploration drilling plans, removing sections from the northern extent of our mineral lease from the proposed exploration footprint." Two voluntary contractions of a granted legal right, in one reporting year, disclosed in consecutive bullet points.

That is the most decision-useful land information in this report, and it’s not in the Environment section. It is not in Biodiversity and Rehabilitation, where the hectares and the rehabilitation ratio live, and it is not in Mine Closure. It sits in Host Communities, in a list headed "Examples of operational activities undertaken in 2025 in response to feedback received from our stakeholders", in the Australia column of a three-column spread that also covers Brazil, North America and Europe.

The location of information is sometimes surprising so it’s important to flick between sections when looking for specific detail. Reporting companies often have to make decisions about where to include certain disclosures in their reports.

This is a good disclosure and a better commitment than many. It puts avoidance first rather than management or mitigation. It locates the identification of heritage values with Traditional Owners rather than with the company or its consultants.

Now compare it with the passage above. The Mining Avoidance Zone has a number, a place and a direction of travel. It is 26,000 hectares, it is around Dwellingup, and it doubled. The heritage buffers have a method and nothing else. No count of places, no total area, no buffer distances, no indication of whether the area under buffer grew or shrank in 2025.

There may be good reasons for that. Locations and extents of heritage places are frequently confidential at the request of Traditional Owners, and publishing a map is not common. If that is the reason though, the report could say so in a sentence.

So, does the report tell you where the company will not go? Yes, it does. You just have to read the Social section to find it, which is not where readers tend to look.

The underlying message is worth noting. These are boundaries drawn by the company on ground it already holds the legal right to mine. The lease says yes across the Darling Range. Alcoa said no in two places this year, and it said no because communities and Traditional Owners compelled it to, not because an instrument required it. The report is quite open about the causation: the drilling change "directly reflected feedback received from community members", and the zone expansion "followed extensive community feedback".

The timing is also interesting. The national Environment Protection Agency commenced on 1 July 2026. The new "unacceptable impact" test under the reformed EPBC Act commences on 1 December 2026. The system is acquiring a better way to test proposals once they are made.

I think it’s fair to say Alcoa had some (a lot) work to do in this area.

Two practical takeaways for anyone reading or writing land and heritage disclosure:

1. Read for avoidance, not only for rehabilitation. Rehabilitation tells you what happens after disturbance. Avoidance tells you what a company has taken off the table, which is the more consequential fact and usually the harder one to find. In this report it is not in the Environment section at all. Search the community and stakeholder pages before you conclude a company has not disclosed it.

2. Ask three questions of any avoidance commitment. Is it mapped, is it measured, and what would have to happen for it to change? A commitment with a hectare figure and a named place is worth more than one with a method. Both are worth considerably more if the report says how they can be undone, and by whom.

Mining Avoidance Zone (MAZ). An area within a company's tenure that it commits not to mine. Voluntary, defined by the company, and not the same thing as a statutory exclusion. Alcoa reports more than doubling its zone around Dwellingup to 26,000 hectares in 2025.

Heritage buffer. A margin applied around a heritage place or value, within which activities that could compromise it are excluded. Its usefulness depends on who sets the distance and who identifies the place. Alcoa states its buffers sit outside the boundary identified by Traditional Owners during field surveys.

Mitigation hierarchy. The expected sequence for managing environmental impact: avoid, minimise, restore, and offset any residual impact. Avoidance sits first because it is the only step that prevents the impact rather than treating it.

Mineral lease. A grant conferring the right to mine within a defined area, subject to conditions. Holding one establishes a legal right. It does not by itself establish community acceptance, and the two can most definitely conflict.

Unacceptable impact. A test introduced by the reformed EPBC Act under which the Minister must be satisfied an action will not have an unacceptable impact on a protected matter. The relevant definitions commence on 1 December 2026.