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Comments on the Swaziland Greenstone Quarry EIA by Rex Brown

• Recognition that consideration of environmental factors is an important determining factor for sustainable development has long been internationally acknowledged. In 1992 the Government of Swaziland established the Swaziland Environment Authority (SEA) as the regulatory body charged with protecting and enhancing Swaziland's environment. In 1996 the Authority gazetted the Environmental Audit, Assessment and Review Regulations which require a wide variety of project types to have an environmental assessment conducted prior to any implementation.

• The purpose of the environmental assessment is to identify whether there are any likely environmental factors that may result in a project being unsustainable or having unacceptable negative environmental impacts. The environmental assessment process is also important for the project decision making process as it often identifies gaps in the original project design and can be useful in making a contribution to the overall success of the project.

• His Majesty King Mswati III and the Government of Swaziland are to be congratulated in their tireless efforts to attract investment to Swaziland. The investment much sought after, is dearly needed to improve the lives of many Swazis through increased economic opportunities which will in turn improve standards of living.

• However such opportunities must not be allowed if the short term gain is converted to long term environmental decline and persistent poverty.

• I acknowledge that Swaziland desperately needs all the investment it can attract, but the investment activities must be sustainable and rewarding in the long term with shared benefits. There is no logic in poisoning the headwaters of a river when that same water is desperately needed downstream for human and industrial use.

• The scenic and natural beauty of Swaziland continue to attract many visitors to the country. The tourism sector, although relatively stagnant presently, is expected to increasingly contribute to the overall GDP of the country offering many sustainable opportunities to create wealth and employment for all who participate. Initiatives such as the Lubombo Spatial Development Initiative, the Maputo Development Corridor and other proposals all aim to exploit the natural resources of Swaziland in a sustainable manner.

• The project proposal being commented upon in this letter came about after His Majesty King Mswati III and the Government of Swaziland called for an Environmental Impact Assessment to be carried out to fully evaluate the impacts and sustainability of the proposed project and to ensure that the benefits of development clearly outweigh the environmental costs.

• The project was bound to create concern both locally and internationally due to its physical location - inside a nationally protected nature reserve in one of the most scenic parts of the region. The unenviable task of having to investigate the environmental impacts such a project was made a hundred times worse by this fact. Mines and quarries are very destructive to the environment regardless where they are found. Wastes, noise, loss of land, resettlement, health and safety issues are all typical of such projects. Trying to satisfy all camps is impossible. On the one hand you have the proponent attempting to make a good financial return on capital investment from the extraction of a resource and on the other you have opponents trying to protect a forever dwindling natural resource and protect a unique part of the country from developers regardless of whether their intentions to make good the damage are satisfactory.

• My main areas of concern about this EIA report are related to:

• The socio-economic impacts

• The impacts on the terrestrial ecology

• The extraction methodology and rehabilitation, and

• General comments

• I shall try and comment on each impact in turn but acknowledge that it is an impossible task to highlight all the errors in calculations, descriptions, spelling or format contained in the report or even to comment on all possible aspects of the project. I trust other comments submitted by other people may pick up on things that I have not noticed or understood.

• Socio-economic impacts

• The EIA quite rightly attaches great significance to the mine affording employment opportunities in an area with high unemployment (if the Malolotja Nature Reserve had sufficient financial resources, it too would offer employment opportunities to the area). The project will possibly increase wealth in the area and perhaps regionally as long as those employed really do come from the area. However, the report fails to adequately address the negative socio-economic impacts that such a project will have.

• Potential negative impacts the project may have will include the risk of damaging sensitive rural livelihoods and cultures. A mine employing up to 100 people will certainly impact on the lives of those homesteads in the vicinity or along the way to the project area.

• The report makes great show of Mr. Siwela's homestead and his positive attitude to the project. This is just one interview with one member of the surrounding communities. We are told that no homesteads occur within a 4km radius of the "lease area" (due to the fact that the lease area is inside a nature reserve where occupation is prohibited) and only Mr. Siwela can be found on the road. I have travelled to the project area and during the drive there I came across several (>10) homesteads along the proposed transport route.

• What concerns me is whether Mr. Siwela can really understand the long term impact (13 years) the mine will have on his and his neighbours rural lifestyle. The Public Relations Officer (Mr. Mapalala) describes in a transcript of the meeting between himself and Mr. Siwela that on average only two vehicles per day will pass his house (the working day is 6am to 8pm giving 14 hours each day with at least two vehicles travelling past his house every hour!). Can anyone, including Mr. Siwela, really comprehend the day in and day out impact of having vehicles passing in front the homestead for thirteen years or more? If Mr. Siwela changed his mind at some point, his only option will be to move away.

• The meeting did not discuss the likely impacts on the woman folk in the area and the promiscuity that will undoubtedly arise once the project starts with a predominantly male workforce. Will his wife and daughters really feel secure with all these men (and eventually job seekers and vendors) moving around his home area? The threat of STD's and AIDS is a real threat as data coming out of the Maguga Dam project is showing. No mention of health intervention programmes for either the employees of communities surrounding the mine is mentioned in the EIA. Does the proponent think his project and employees are immune from such?

• The meeting concludes that vehicles will not go above 20 kph and that the road would be wetted and normal working hours will be adhered to. Unfortunately Mr. Siwela agrees that if these three steps are undertaken, he will be happy. Little does he know the reality!

• The EIA proposes to transport in and out all employees (from where we aren't told nor are we told if this would be a free service) yet fails to address the very real problem of job seekers who will come and camp near the project hoping for casual work. It is likely that for some employees, if forced to pay for transport or out of convenience, will opt to live closer to the project resulting in both unplanned settlements or overcrowding of rural homesteads.

• The socio-economic impact of the mine only operating for 7 months of the year (page 140) with the resultant lay off period will certainly impact on the livelihoods of those employed (unless they are getting paid for no work?). No mention is made of this rather surprising feature of the project.

• For the rural folk in the project area, the project will contribute little or no socio-economic benefit - no improved access, no health intervention and no community facilities (e.g. football pitch).

• Greenstone, we are told, is in great demand in the Far East for jewellery and dimension stone. The proponent provides some undated value of greenstone (page 89). It would be interesting to find out how much a kg or tonne of the rock is worth today (Feb 1999). Estimated values of greenstone provided by the proponent are US$1000/t for dimension stone and US$3/kg (US$3000/t) for jewellery quality stone. I think these figures need to be investigated more thoroughly. I have heard figures ranging from US$100/kg to US$1300/kg for jewellery quality stone. Using a figure of US$100/kg, a possible total profit of some US$2-5 billion over the period of the lifetime of the mine could be realised. If such huge amounts of money are possible, surely the Swaziland government should be looking to get more than a 12% royalty and some PAYE from the workers and 30-35% company tax? The potential positive economic impact on the Swaziland economy could be very significant if the mine was at least a 50:50 partnership with the government, Tibiyo or the SNTC. The Kingdom's current E350m national deficit could be wiped clean in less than one year! The use of such an argument could go a long way to justifying the environmental cost as the benefits are shared.

• Impacts on the Terrestrial Ecology

• Although the proponent manages to fill many pages and tables with data related to various species lists, I am concerned that all this information came from only a few visits during one part of the season and with very little scope to investigate in detail. This makes some of his assumptions rather weak.

• The proponent mentions several times that he was not allowed to obtain this and that sample so I wonder, with so much data not available, how can he adequately assess the impact the mine and proposed route will have on the terrestrial ecology. Generalisations and the use of SNTC publications are all well and good for some research purposes, but when investigating the likely impacts of a mine in a sensitive and protected area, without this information how can the EIA proceed and at the very least make recommendations?

• No mention is made on the impacts the introduction of non-native species either via the vehicles or the employees could have on the long term diversity of the ecology.

• The proponent says on page 62 that they "do not propose to clear the forest (Mqwayiza) or remove trees". I have been to the site and am alarmed that they can make such a statement when the forest is growing right up the cliff face! How on earth are they going to extract rock from that cliff without removing any trees (unless their definition of a tree is different to mine)? On page iii we are told the proponent "does not wish to remove any trees from the forest". Sometimes what we wish for doesn't always come true.

• The mitigation to minimise impacts on reptiles crossing the road "the driver shall stop and wait for the reptile to cross" is laughable. This is not a realistic measure to reduce the impact - who is going to monitor that over the lifetime of the mine?

• To mitigate impacts on fauna, the proponent describes how all domestic refuse will be collected in 44 gallon drums which will daily be removed from the nature reserve (page 6 and 138). To where?

• To mitigate impacts on fauna during the breeding season the proponent proposes that no quarrying will be carried out from October to February (page iii, 125 and 140). This measure sounds like it should have very serious implications on the viability of the mine - for five months the mine will not operate. Surely the socio-economic implications of laying off 100 workers for 5 months needs a mention? Perhaps a worker only working for 7 months a year will have economic implications as far as retrenchment packages or other pensionable type benefits the mine managers may offer?

• This cessation of quarrying from October to February certainly isn't taken into account in many of the timeline calculations where we are told in 1.6.3 (page 5) that the estimated reserve is 300 t/month which will yield 3600t / year (page 62) - this assumes a 12 month operation. All financial data to support the economic viability of the mine assumes a 12 month operational year. Does this imply that a faster extraction rate is intended resulting in an increased stockpile?

• Extraction methodology and rehabilitation

• The EIA admits that a open cast mine will affect landform. The removal of 150 000m³ of rock will obviously have a significant physical and visual impact on landform.

• Mining is not an ad hoc activity. It has to be carefully planned and managed to ensure the maximum use of men, machines and money is made. I am concerned that there is no reference to a "mine extraction plan" (or whatever the correct term is for a detailed description of the sequence of rock removal). Surely any planned mining operation should be accompanied with detailed extraction "drawings". That is documents, maps and figures that describe how the quarry will be worked progressively over the lifetime of the mine. The section of Quarrying methods and the supporting hand written diagram (page 5) is for the extraction of the 15m³ sample and it is not clear if the methodology described for that process is to be used throughout. We are not told whether the mine will start from above (like digging a hole) or whether the mine will work its way back from the cliff face. Mention is made in several parts of the report that waste rock material will be used as "backfill". Backfilling what and how? Is there enough physical space to backfill?

• The EIA fails to satisfy my own concern about the rehabilitation of the mine. Section 6.4 describes the decommissioning phase but only mentions that the infrastructure and stockpiles will be removed (including also "holes left on site" and "no metal or tanks will be left on site"). What about the gigantic hole in the side of the mountain? Is there going to be no effort to rehabilitate that (apart from dumping the waste rock in the hole as described on page 109)? If so exactly what is going to happen to it? No mention of reshaping it to "blend in" with the surrounding topography. No mention of trying to screen it. No mention of how it will be fenced off to protect animals or even hikers from falling into it? No real mention of how much it will cost. The EIA needs a detailed rehabilitation plan of the mine itself.

• The rehabilitation and pollution trust fund mentioned on page 147 (which also seems to be used for retrenchment training - page 127 & 141) is set at E50/sales ton (not even in US$!) and will accumulate E2.16m over the lifetime of the mine. The proponent then states "This amount is sufficient to cover the rehabilitation cost". No supporting data is supplied to assume E2.16m is enough or what will be done for that money or what will it pay for in 2013? If a sum is to be set aside for rehabilitation, then this sum needs to be determined realistically. E50 sounds too much like a thumb suck figure without the supporting evidence. The sum should not be a fixed price, but a market related US$ price (as the market price of the stone increase, so should the rehabilitation funds share). I also feel that should permission be obtained to start mining, a significant sum of money (enough to cover all the rehabilitation costs of getting the 15m³ sample out) should be deposited in a fund in case the sample fails to meet the quality expectations. No mention is really made of who is responsible for the management of this fund. I also understand that there is currently no legislation in effect in the country that allows for such a trust fund. I know we have the Kings Trust and the Enterprise Trust, but these are either special trusts attributable to the monarchs' involvement or a plain misnomer, but as far as I understand there is no legal instrument that allows trust funds and I stand corrected if there is.

• Other rehabilitation concerns include the proponents description of how rehabilitation of disturbed land will be done through the use of the stockpiled soil which will be "seeded with natural flora seeds from the immediate area" - who said they could do that? How practical is it to do that? (page 134) Are the costs indicated on page 149 for "collection of seed" and "seeding of rehab areas" realistic for 2013?

• The proponent, on page 123, finds another source for his waste material to fill in a gully on the leased area. Who was consulted about the benefits and appropriateness of using the waste rock for this purpose? It sounds like the proponent has found a convenient site to dispose of his waste material while appearing to do something to combat the gully. The proponent doesn't describe the gully at all, apart from saying it is large, or justify why they are going to close it with waste rock.

• Waste rock from the second year will be used to backfill the quarry (page 109 & 133) surely there should be a quarry operation plan for us to examine to satisfy ourselves that this is actually a feasible option. As I see it the mine is working a cliff face (immediately in front of which is a forest that will remain untouched) - where is this backfill/waste going to go? A quarry plan is needed to explain this.

• The proponent proposes to use labour to man haul the extracted rock from the mine to a stockpile area. No provision is described about what these men will walk on or whether the path through the forest to the stockpile area is going to be upgraded to a walking surface suited to the minimisation of long term injury to those men. I imagine lines of men carrying chunks of rock up hill looking like a line of ants on the move transporting the rock to the stockpile. If there are no plans to surface the path, then erosion and the consequent increase in silt loads of streams and rivers will occur. The effect of increased silt loads in the natural water bodies can be detrimental to all life forms in that water body.

• The proponent does make efforts to protect the rock stockpiles from erosion through a concrete bund type arrangement. However there is no mention that the soil stockpile will be protected or seeded to protect against, for example, wind erosion. All the that is mentioned of this unknown quantity of soil is that the stockpile will not exceed 2m in height. No indication is given of where it will even be located apart from a poorly detailed figure.

• The visual impact of that stockpile is also a concern to me. It is apparent that once inside Malolotja Nature Reserve the proposed stockpile site will clearly be viewable in the distance. No effort to screen this storage area is mentioned nor the possibility of examining alternative sites that would be less noticeable.

• Other general comments

• Where are the Terms of Reference for this EIA? These should be in the appendix so we can get a better understanding of what was required of the proponent during this study. No reference is either made to the scoping report. When was this approved and where can it be found?

• Who made up the team of EIA consultants and what qualifies them to participate in this EIA? No CV's or description of the consultants used is given.

• Only very general economic and financial analysis of the mine in relation to its impacts is given.

• Monitoring (page 147) - where are the monitoring plans and justification? Can't monitor for the hell of it as it is too expensive. What is going to be monitored? What baseline data is to be used to monitor against? As mentioned no adequate ecological surveys were carried out so what can you compare against? How can it be established whether an impact is having a positive or negative effect if there is limited baseline data? The proponent mentions that water quality monitoring (from where, what and why?) ambient dust monitoring (from where and why?), noise level monitoring (from where?), ornithological monitoring (of what and why?) and flora monitoring (from where, what and why?) will all be monitored but fails to answer where, why, how and when.

• Consultation (page 147) - the proponent describes a system for registering a complaint by an I&AP and proffers that the complainant will be "kept informed on the progress of the complaint" and "all outstanding complaints will be raised and discussed on the monthly management meetings". My concern here is that if the complainant fails to get a satisfactory resolution of the complaint, why can he take it to. I would like to see a Dispute Committee made up of mine management and other independent people or organisations that will examine and investigate the complaint and will have the authority to make binding decisions on the resolution of that complaint. The area of complaints and resolution is too grey to be left to the mine management.

• Power - a diesel generator for power (page 6 section 1.6.6) is mentioned as the sole source of power for the mine - no mention of noise levels or impacts or size of unit needed. In fact wherever noise is mentioned or the quantity of diesel needed and storage of such, this diesel generator is not mentioned or accounted for. Presumably the generator will be running 24 hours a day requiring relatively large volumes of diesel to be transported in and stored.

• Vehicle traffic - I estimate vehicle traffic to be at least 2.14 vehicles/hour with 300t/month and 1 t/bakkie making two trips (there and back) for 20 days a month and a 14 hour working day (page 104 estimates 1.6 vehicles per day). This figure does not take into account other vehicles that will be using the road daily like transportation of employees (page 104 suggest 6-7 trips per day), machinery supplies and suppliers, diesel suppliers, office equipment suppliers, management transport, tradesman and salesmen, mechanics, etc etc)

• Industrial waste - no mention of where the expected hydrocarbon soaked wood chips (page 137) from the diesel storage area are to be removed to or how they will be disposed of.

• Compliance monitoring - no mention is made of any on-site environmental officer to monitor the CMP and complaints etc. I would like to see a qualified independent person on-site to keep an eye on all activities (SNTC officials?). The area being so remote it would not be wise to allow the mine managers to monitor their own environmental standards and CMP.

• Shared benefits - no mention is made of what benefit the Malolotja Nature Reserve will receive from this mine. The Quarry Lease does mention in point 6 that the owner of the Lease Area ("Swazi Area") shall be paid a surface rental of E5000 per year which will increase 10% each year. Due to the loose physical location of the lease area set out in the Quarry Lease ("situate in Hhohho District, a south of Bulembu village") in point 2, the term "Swazi Area" would normally imply Swazi Nation Land and if not SNL then another more descriptive setting like the Malolotja Nature Reserve. Surely any surface rental should go to the Swaziland National Trust Commission as "owner" of the lease area. Apart from this Malolotja or the SNTC do not appear to be gaining anything out of this project apart from a hole in a hill. It would have been prudent for the proponent to include some benefits that could accrue to the reserve or Commission.

• The EIA fails to adequately address the national value or regional significance of the Malolotja Nature Reserve as a regional and international conservation and tourism resource that should be protected and conserved. An open cast mine in Malolotja Nature Reserve will certainly depreciate Swaziland's image as a tourist destination and a respected custodian of natural habitats. The future implications of this are unknown.

• The lease - surprisingly from an environmental consultant, the EIA does not question the legality or legitimacy of the lease. Instead the EIA tries to protect and justify why the proponent should be allowed to mine in a reserve. This brings into question the sincerity and professionalism of the consultant.

• Very little attention is given to the impacts of the mine along the transport route to the main Piggs Peak Motshane road. There are many homesteads, steep turns, a narrow bridge and a forest the road goes through. No mention is made of the upkeep and costs thereof of that road or whether it is a public or private road or whether permissions have been sought and obtained for the use of that road. All gazetted roads carry a restriction the axle weight of vehicles using it. A rural road such as the one in question was never 'designed' to accommodate fully laden 1 tonne bakkies.

• No mention is made of any medical facilities that will be available on-site. If there are, will these facilities be for the exclusive use of mine employees or open to the wider community? Providing for example, ante-natal care or medication for minor aliments of the local communities.

• A major flaw in the Terms of Reference (was there any?) for the EIA is that the processing plant, an essential part of the project, is to be separated from the mine EIA. The two are part and parcel of each other and need to be considered together. What if the EIA for the processing plant is shown to have unacceptable impacts - will the mine cease? It may also be possible that an EIA on the processing plant may have demonstrated significant benefits that would go some way to justifying the mine itself. For example, the plant could be converted into a social or recreational facility at the end of mining operations. The EIA report mentions a possible site for the plant will be nearby. Other reports have suggested it would be in Piggs Peak or Bulembu. I was pleased to see, however, that the road issue was investigated in this EIA report but this should have been covered in more detail as the environmental impacts of the road are serious as is the road safety aspect.

• A possible conveyor system to transport the rock from the mine to the stockpiling area is mentioned (page 6 section 1.6.5) yet no mitigation on its impacts is described. I see it as very likely that this will be the preferred method of moving the rock rather than man hauling it for 13 years and should be explained and or investigated.

• It is my opinion that insufficient investigation was made in locating an alternative source of the greenstone. A brief mention that this is the only area in Swaziland and South Africa (section 1.6.15 page 8) is not substantiated through rigorous investigations. Additional efforts have to made to find greenstone of acceptable quality outside of a protected area. It may not be as convenient as the source in Malolotja, but at least it will have fewer environmental sensitivities.

I provide these comments in the hope that the custodians of Swaziland's environment and other involved parties will concur with all or at least some of my comments and that this proposed development is stopped.

Should the EIA be considered worthy enough to proceed to the next step in the EIA process, that of a public meeting, I hope the above comments will be taken onboard by the proponent and a public debate of all the issues is allowed.

I also hope that with the public release of this final EIA report for the proposed greenstone quarry, the proponent is not given another chance to resubmit a revised EIA addressing the comments raised by myself and no doubt others. It is, after all, the final EIA report and if it is proven that it has failed to adequately address the issues then that is the end of the whole process.

At the end of the day a decision on whether the project should proceed or not will be a political decision which is allowed for in the EAAR Regulations section 5(7)(b) but I hope sense will prevail and that there is recognition that the EIA report does not adequately address the issues surrounding this project.

Rex Brown
26 February 1999

Extracts and Comments | Discussions