Extracts and Comments | Discussions
PRELIMINARY COMMENTS ON THE EIA AND CMP FOR THE SWAZILAND GREENSTONE QUARRY
R.C. Boycott
Malolotja Nature Reserve
P.O. Box 1797,
MBABANE,
Swaziland
FRONT-PIECE
There is a glaring error on the very first page of this report. The Swaziland Greenstone Quarry was initiated between His Majesty King Mswati III and Michael Lee Enterprises NOT between His Majesty King Mswati III and The Republic of China.
LEGISLATION
Under the section on legislation the National Trust Commission Act of 1972 is mentioned. Specifically Section 20(2) is referred to on page 69 of the report which states that ....notwithstanding subsection (1), the Commission (i.e the Swaziland National Trust Commission) may, for scientific purposes or the improvement of the park or reserve or for other good and sufficient reason, authorize any person to do any act prohibited by this section....
It has become abundantly clear that the Commission has exercised its discretion and decided that the proposed project is undesirable as it will undoubtedly impact negatively and permanently on the natural ecosystems that Malolotja Nature Reserve was created to protect. It certainly will not improve the reserve in any conceivable way but will have quite the opposite effect.
ECOLOGICAL COMPONENT
In this brief review there is no place for nit-picking but a few issues in respect of the environmental impact assessment of the access routes and the mine site are raised.
In the report, in respect of the two access routes, the accounts on "Relative value of nature versus development" begin with "Due to the sparse vegetation cover on this track, the relative value of nature is limited". The only use intended for the track, particularly the last three kilometres to the chert site, is as a hiking and backpacking trail. This clearly has great value for nature and for the experience of wilderness.
Reserve management has, prior to the commencement of site visits which were as a direct result of Michael Lee's mining proposal, intentionally not carried out any road maintenance on the track. The whole idea was to leave the track entirely alone so that natural rehabilitation could take place. This has occurred to some degree - take note of the protea trees and other bushes that have established themselves in the track. It can confidently be stated that over the last year there has been an increase in the erosion along the track solely as a result of the increased visits to the green chert site because of Michael Lee's proposal. Therefore serious impacts have already been caused by the proposed project. It is surprising that this, one of the most obvious impacts, has been missed.
The assessments of the mammalian fauna of the access routes and the mining site are hopelessly inadequate. The report claims that the consultant did not have permission to trap or take any animal samples. This is not true as the consultant was reminded on several occasions by reserve management that he would need to conduct surveys on the mammals, particularly the small mammals. It was also mentioned that, if necessary, he should employ the required specialists to do satisfactory surveys. As an example there is no mention of serval cat, a threatened species, in the area, yet it would be dead easy to pick up their sign by collecting scats. There were never any restrictions on this.
In respect of the butterfly species the consultant was given a detailed report on those species of butterfly in the area that were considered regionally important - rare and endangered. A list of the 170 species of butterflies recorded from the reserve could have been provided if the consultant wanted it. It was never requested. Such a list would only add several more pages of text to the report and the majority of species listed are unlikely to occur in the Mgwayiza Forest and surrounding grassland.
The same argument applies to the bird list provided in the report and the assessment of the avifauna is, like the mammals, somewhat inadequate. The report mentions four migratory species of birds that occur in the reserve. There are many more, including some very important species such as the Bald Ibis, which unlike many summer migrants is a winter breeding migrant to the nature reserve. Suitable foraging areas in burnt grassland are of primary importance for successful breeding in this species. The report misses the point completely by intimating that the breeding of this species will not be impacted on because the access road is three kilometres away from the breeding site. The access road passes right through important foraging areas.
In the Environmental Impact Assessment on the access routes the report frequently mentions migratory routes for birds and animals. However, no consideration is given to, and no mention is made of, the resident populations of birds and animals that may be affected by the access route. This is a major omission in the EIA report. Road kills of birds, amphibians and reptiles will increase along any access route into the area.
AESTHETIC COMPONENT
No mention is made in the report of the visual impacts of the access route and mining site. In mitigation the report is advocating development in the area. This is contrary to the reserve policy. The area has been zoned as a core wilderness area which means the only access to the area is on foot. There should be no infrastructure whatsoever in the area including buildings, roads and tracks. It is imperative that wilderness areas within the nature reserve are maintained as such.
The last section of the access route, nearest the mining site, the proposed product stockpile area and the proposed soil stockpile area will be visible from many points along the main public access road into the reserve. This includes the Majolomba Picnic Site and Inkonjane Bungalow, a visitor accommodation unit, inside the nature reserve.
CONCLUDING COMMENT
In the No Project Option section apart from the misquote attributed to Boycott - Afro-montane forest and mist belt forest are synonymous - it is clearly spelt out that the mining site is a sensitive and vulnerable site. The same conclusion should have been reached in respect of the access routes as both options pass through sensitive areas with vulnerable species of plants and animals.
Prepared February 1999
Richard C. Boycott