Extracts and Comments | Discussions
Final Comments on the Swaziland Greenstone Quarry EIA
Rod and Lungile de Vletter
We have read with serious concern and alarm the Swaziland Greenstone Quarry EIA, which attempts to report the physical impacts of a mining operation in the heart of the Malolotja Nature Reserve.
The EIA lacks credibility as it does not address issues of major importance: it makes no reference to the value of Malolotja as a Reserve, its place and significance within the national and regional conservation system, and the potential impact of a mining operation within the tourism and investment scenario in Swaziland and the region. Not taking into account these major factors totally invalidates the report.
It is difficult to take seriously an EIA that can say that the most significant impacts of a project that has a plans to drill and remove 16,000 cubic metres of rock over a period of 13 years in the heart of one of the region's most important conservation areas is, with all due respect to Mr. Siwela:
"Escalated erosion of the track and the possibility of dust and noise pollution in the vicinity of Mr. Siwela's homestead".
This is equivalent to saying that a coal mine in the middle of the Kruger Park would be of minimal impact because it would only impact on .01% of the geographical area of the park and not significantly threaten the Park's flora and fauna.
It goes without saying that an EIA on a mine within a national park or reserve anywhere in the world, would need to contextualize the proposed development according to the conservation and touristic significance of the area.
The report is a classic and apparently deliberate example of not 'seeing the forest for the trees'. The impact of a totally incompatible land use within a protected area has far reaching impacts beyond the mere physical ones stated in the EIA.
The impacts, which are potentially extremely serious, and which need to be examined in detail are those which will negatively affect Swaziland's:
The EIA should clearly indicate whether or not the relatively insignificant economic returns of the mine merit the overall negative impacts that would occur to Swaziland as a whole from the mine. It is estimated that the mine may contribute the equivalent of 0,7% of Swaziland's total yearly exports. This figure needs to be compared to the impact that the mine could have on future investment in the tourism and wildlife industry. If one takes the latest figures of South Africa for tourism alone, this has the potential of contributing about 14% to South Africa's total GDP (WTTC, 1998).
The statement that the "quarrying within the Malolotja Nature Reserve would not constitute an illegal action by the proponent due to the lease already granted" and that "This action would also not set a precedent for future actions in a National Reserve" needs examination. The question is not so much whether or not the lease is legal, but whether or not it should be legal. If the development is legal, what is then the value of a protected area in terms of the law in Swaziland? What are Protected Areas protected against? And to what extent does such a lease transgress the principles of the Biodiversity Convention and other conventions to which Swaziland is a signatory?
The objectivity of the EIA must be seriously called into question. The tone throughout the document favors the project, minimizes the potential impacts of the mine and even belittles the value and quality of Malolotja Nature Reserve and its management (e.g. "it seems evident that the conservation of the area for future generations is not occurring" pg. 62).
Some of the specific findings of the EIA are also highly questionable: how does one assume that the noise of the drilling will not be heard outside the Mgwayiza valley. Did anyone use a drill to establish this unlikely fact? What are the consequences of 100 workers within the reserve? To say that "Noise generation is not expected to have a significant impact on the mammals or amphibians on the forest" is absurd.
What will be the impact of in-migration to the surrounding area as a result of the quarry?
The question of investing the returns of the mining operation into biodiversity conservation in Swaziland should be looked at as a possible solution to full mitigation of impact as well as that of processing the chert locally and training of locals to produce quality jewelry etc. and exporting the chert as an added value product.
It should also be noted that Swaziland at this moment is proposing to create Tourism and Biodiversity Corridors to take full advantage of the opportunities represented by the Maputo Corridor and the Lubombo Spatial Development Initiative. This project, with costing proposed at $26 million, will significantly boost Swaziland's ability to attract international and regional tourism. However, much of this will depend on the extent that Swaziland will attract donor funding and private sector development.
It cannot be emphasized strongly enough that a weak EIA, such as the one under discussion, leading to a mining development within a Protected Area, will send a very clear signal to the private sector and to the donor community that Swaziland is not serious about tourism or conservation. We, for example, who have invested and intended to invest - all our capital into the development of nature conservation and tourism in this country, would seriously begin to look at surrounding countries, such as Mozambique and South Africa, as more attractive and secure investment options.
Furthermore, the international NGO community would investigate both the dubious circumstances in which the lease was granted, and the pathetic attempt of the concessionaire to circumvent international standards through this EIA. Swaziland would become an international laughing stock and our reputation irreparably damaged. Can the overall cost of this be measured?
The enormous financial, economic, social and ecological impacts of going ahead with the Greenstone quarry on the basis of what is presented in the EIA must therefore be properly analyzed. Under the present proposal, the concessionaire will profit enormously, and leave us with little more than a spiritual and physical hole in the ground.
We propose that the EIA in its present form be totally rejected in that the consultant who has carried out the EIA has clearly not done the work in the broader interest of the Swazi Nation. We propose that a new consultant of international repute, with clear Terms of Reference discussed at a stakeholder forum, be contracted. We propose that, because of the serious nature of this development, a donor be requested to fund the consultant, and that the responsibility of the EIA be taken from the developer.
Rod and Lungile de Vletter
Phophonyane Lodge and Nature Reserve
20 February 1999