Extracts and Comments | Discussions
Comments on:
Swaziland Greenstone Quarry EIA
General Comments
The environmental impact assessment does not consider the full impacts of the proposed quarrying, offers minimal mitigation to reduce these impacts, and offers no compensation whatsoever to Malolotja Nature Reserve for the permanent destruction of a portion of a wilderness area.
The focus of the EIA has not been from the point of view of the general impacts on a protected wilderness environment, but rather only on impacts on species.
The issue of the applicability of the nature reserve regulations on mining staff while within the boundaries of the nature reserve has not been considered, nor is there any provision for the implementation of these regulations.
Impacts
Impacts considered in the EIA do not take into account the effects on a nature reserve of the presence of the mining personnel within a protected conservation area for an extended period of time. The impacts of this human presence on the areas adjacent to the mining activities and the access routes are not considered.
The impacts of human waste are glossed over - they are briefly mentioned within the document, but this is not carried through to the summary information.
The impacts of the accidental introduction of alien plant species through the movement of vehicles into the area and through the importation of sand for the proposed concreted areas is not considered.
The impacts on the Mgwayiza River of the proposed level of activity within its catchment are glossed over in the EIA.
The extent of the visual impact of the quarry both during and after the quarrying has not been assessed.
The impacts on the flora of the area do not consider the point that with regard to geology that this is a unique area, and would therefore have related unique plant species. There is no mention of any botanical study with regard to potential nickel tolerance of plant species unique to the greenstone belt; there is no mention of the level of endemism of plant species to the Barberton Greenstone Belt (including Malolotja and the adjacent areas in South Africa), and there is no discussion of whether the flora survey carried out in order to prepare this EIA represents an exhaustive study of the flora of this area (which is extremely unlikely).
Mitigation Measures
The proposed mitigation measures are inadequate for the protection of the flora and fauna of the area, even excluding those immediately physically impacted by the actual quarrying.
The mitigation measures have not been assessed for their impacts. For example, the impact on surrounding areas of the proposed drainage and erosion control measures that have been proposed for the access roads may in themselves cause further erosion problems.
No attempts have been made to prescribe the manner in which the topography of the area might be altered by the quarrying and stockpiling, apart from limiting the height of stockpiles, and the proposed rehabilitation of the area post-quarry operations does not require any attempt at restoring the original topography of the area.
No attempt has been made to limit usage of the area by mining staff to areas specifically associated with the quarry operation.
Compensation
No compensation whatsoever has been proposed for the permanent destruction of a prime wilderness area within a proclaimed protected area.
No compensation whatsoever has been proposed for the increased policing that will be required by Malolotja Nature Reserve personnel in order to implement reserve regulations as a result of the increased influx of humans within the reserve.
Penalties
No penalties have been defined for any infringements of the proposed mitigation measures.
There is no proposed penalty to the mining company for infringement of reserve regulations by their workers.
Concluding comments
It is extremely unrealistic to think that the presence of approximately 200 people within a protected area for a period of time exceeding ten years will not cause long term damage to what would have been a wilderness area, even excluding the physical impacts of the actual quarrying operations. No realistic mitigation measures have been proposed to attend to this, and no compensation of any sort has been proposed for Malolotja Nature Reserve, which would lose in perpetuity a prime wilderness area.
K.P. Braun
17 February 1999