The maximum designed capacity of the smelter is around 1.2 million tonnes year.

It is estimated that this smelter will produce some 60,000 tons per year, creating 800 jobs directly and 2,000 indirectly.

The second project under way is a joint venture between the Kanak controlled Société Minière du Sud Pacifique and the Canadian company Falconbridge Limited. The project will include the construction of a smelter in the North Province to process nickel from the Koniambo mountains.

In the first place, although the commentary referred to the general pronouncements on future damage in the Trail Smelter case, it did not mention that the arbitral tribunal had awarded compensation with regard to cleared land and uncleared land without taking such a threshold into account.

The first of the three projects is being developed by Société Le Nickel (the New Caledonian affiliate of the French State owned company Eramet), which is investing between 140 million and 190 million in its Doniambo smelter to boost production from 60,000 to 75,000 tons per year.

As the Tribunal in the Trail Smelter Arbitration stated in its interim award Where the wrongful act itself is of such a nature as to preclude the ascertainment of the amount of damages with certainty, it would be a perversion of fundamental principles of justice to deny all relief to the injured person, and thereby relieve the wrongdoer from making any amend for his acts.