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Swaziland Greenstone Mine EIA - Comments

Peta Masson

A number of submissions have been made concerning the Greenstone Mine EIA. Some of these have covered the broader issues of the ethics of mining within a protected area, Swaziland’s credibility internationally and regionally within conservation circles, should mining be allowed to go ahead, and then more detail on the social implications of the development, its effect on tourism in Swaziland and the economic viability of the mine. I feel that many of the concerns raised are valid, they illustrate the flawed nature of the impact assessment and point out real issues which must be adequately answered before decisions are taken to approve the development.

Having read parts of the EIA document, I would like to comment on the accuracy of data interpretation regarding the botanical diversity in the proposed leasehold mine area.

1. Northeastern mountain grassland.

• The Consultant refers to the veld type in which the quarry is situated as north-eastern mountain grassland.The statistics given refer to the extent of the grassland in southern Africa and do not reflect the very limited extent of grassland in Swaziland.

• This veld type is a recent amalgamation of Acock’s (1988) northeastern mountain sourveld (Veld Type 8) , Piet Retief sourveld (Veld Type 63), and northeastern sandy highveld (Veld Type 57). In Swaziland, only Veld Type 8 and Veld Type 63 are to be found along the western border of the country and they are of limited extent in comparison to other vegetation types in Swaziland.

• Veld Type 8 is widely considered to be one of the most threatened veld types in southern Africa, thus the location of the quarry site in this veld type is cause for concern.

2. Afromontane Forest.

• The significance of the forest vegetation in a regional context is not mentioned. A preliminary survey of Swaziland’s Highveld Forests (Masson 1991) drew attention to the unique nature of the Escarpment forests, the important role that they play in forming a regional link between Mpumalanga and KwaZulu - Natal forests and the increasing threat to their existence outside of protected areas.This is due to over - exploitation and, in remote areas , the clearing of forest for illicit `dagga’ growing.

3. Species diversity and conservation worthy species.

• Bredenkamp et al (1996) state that the northeastern mountain grassland is an area with many rare and endemic plant species. They note that a number of species are restricted to the mistbelt zone of high mountain peaks and summits. Rendlia altera and Festuca costata are two such species, both of which were found in the summit area of the lease area and were recorded as being dominant and abundant respectively. Instead of noting this point, the Consultant preferred to emphasize the presence of Eragrostis curvula and Agrostis eriantha, two disturbance-related species, neither of which were dominant.

• The grass aloe, Aloe chortolirioides, has not been widely recorded in Swaziland, and its presence in the area is thus of conservation importance.

• The Consultant concedes that Mgwayisa Forest is an area rich in species diversity. He also notes the presence of four tree species of conservation-worthiness and one protected species, Streptocarpus davyii. The limited distribution of S. davyii (Hilliard and Burtt 1971) underlines its protection-worthiness, even though locally it may be abundant. One wonders how many conservation-worthy species it is necessary to have in order to prevent their destruction.

• the importance of fynbos elements occuring in the proposed mine lease area is not mentioned by the Consultant. These elements are characteristic of high altitude grasslands and are found along the upper reaches of the Drakensberg mountain range, extending from the Cape Province to Central Africa. They are thus of important phytogeographical significance. Representatives of the families Ericaceae and Proteaceae, key fynbos families, were abundant in the summit area.

4. Representativeness of the survey.

• It is acknowledged by the Consultant that the survey data may not be representative of the true floristic diversity of the area. Studies conducted in the Barberton Mountainland region, across the border from the proposed mining site (Balkwill pers comm), have illustrated some very special relationships between geological substrate and species occurrence. It is highly likely that a similar relationship would occur in the proposed mining lease area , if a comprehensive investigation was to be undertaken.

• Although it is clear from the species lists collected over the short period of time that the area supports a significant number of species, the Consultant prefers to emphasize the presence of two alien species, Caesalpinnea decapetala, and Rubus pinnatus, attempting to detract attention from this fact.

5. General Comments on the Mitigation of Impacts .

5.1 Waste Management.

It is becoming increasingly important for Companies to demonstrate responsible environmental management by having stringent pollution control measures and acceptable waste management strategies. Swaziland has recently reviewed legislation concerning pollution standards, indicating a committment to meeting international requirements. It is assumed that new developments such as the proposed Mine, would have to demonstrate compliance with these standards.The EIA report does not appear to adequately address the methods of waste disposal and pollution control .

5.2 No clearance of Forest

Having visited the proposed mining site a number of times, I fail to see how the chert can be mined without disturbing the forest or removing the trees. It is practically impossible to reach the site without removing a significant amount of forest vegetation. If, by some miracle, this were possible, then the extended impact of people in the area would undoubtedly contribute to further degradation of the site.

5.3 Conservation Management of the area

The Consultant mentions that fires in the area would be speedily dealt with, should mining be allowed to occur. This is highly improbable, given that people are the main cause of fires . Furthermore, experience elsewhere has shown that combatting fires requires increased awareness and does not simply result from an increased presence in the area.

The few points raised above, I hope, place into context the importance of the area from a plant diversity perspective. I hope that they will be considered along with the rest of the submissions.

MS PETA MASSON
P.O. Box 906
Mbabane
SWAZILAND

References:

Bredenkamp G, Granger E. and van Rooyen N (1996). Northeastern mountain grassland. In Low AB. Rebelo AG (Eds) Vegetation of South Africa, Lesotho and Swaziland. Dept of Environment Affairs and Tourism. Pretoria.

Hilliard O.M.and Burtt B.L. (1971). Streptocarpus. An African Plant study. 410pp.

Masson P. H. (1991). Forest composition and conservation status in the Swaziland Highveld. Presentation delivered at the xiiith AETFAT Congress held in Zomba, Malawi.

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