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Comments on the Swaziland Greenstone Quarry Environmental Impact Assessment and Comprehensive Mitigation Plan:

Dr. Ara Monadjem

I have restricted my comments almost entirely to the faunal component of the EIA as this is where my expertise lies. This should not imply that I agree with the other parts of the report.

I have summarised my comments in point form below:

1) The clumsy tables (2.18 to 2.21) which appear from pages 38 to 50 of the report are, for the purposes of this exercise, quite useless. These tables list the possible vertebrates and butterflies occurring in the mine lease area. The species are not arranged taxonomically, but by trophic level. This makes it very difficult to read the tables, especially since many of the species have been placed in the wrong trophic level (e.g baboon, blackeyed bulbul, olive thrush, Heuglin’s & Cape robin, redwinged starling to mention just a few!), or even in the wrong group (e.g. the climbing mice in the genus Dendromus have been placed with the birds when they are actually mammals).

But what makes the table irrelevant is that it is based on a "desktop study". It is claimed that the information was "researched from the literature in order to determine which animals may occur in the mine lease area" (page 17). However, none of the Swazi literature on the country’s plants or vertebrates was ever cited, never mind used (e.g. Compton, 1976; Kemp, 1981; Masson, 1991; Boycott, 1992, 1993; Parker, 1992, 1994; Hyslop, 1994; Monadjem, 1997, 1998 to mention just some of the more important and accessible contributions; the full titles of the references are available from the author). But, even assuming that the Swazi literature had been used, there would still have been a need for a PROPER & ACCEPTABLE ecological survey of the area (as the Mgwayiza forest, and surrounding area, is one of the least zoologically or botanically explored areas in Swaziland). Such a survey would not take "at least five years" (page 16) as claimed by the consultant; a team of competent biologists should be able to complete the task within twelve to eighteen months. And even if it would take five years, it should still be required as the area is located within a nature reserve and is deemed sensitive by nearly all ecologists and conservationists in the country (in fact, this appears to be the predominant view of most people who have visited the area).

Since the potential impacts of mining on the local fauna have been based on this table, the sections of the report (pages 66 to 71; 81 to 86; 96 to 101; 111 to 113) dealing with this subject are suspect.

2) On page 67 it is stated that "No mammals of conservation importance were sighted within the northern sector of the Malolotja Nature Reserve..". There are numerous species of conservation importance that occur there. The following are examples of mammals of conservation significance to Swaziland which occur (or almost certainly occur) within this area: aardwolf, leopard, serval, caracal, grey rhebuck, oribi, klipspringer, red duiker. The full list is longer. Most of these species cannot be expected to be sighted on a single visit. In fact, some of the species will only be recorded by other signs such as spoor or droppings. A proper survey would have revealed the presence of most of these species.

3) The list of species of "conservation priority" appearing on pages 81 to 82 (and again on pages 97 to 98; and 111 to 112) is incomplete (see comment (2) above). Again, the full list of threatened bird species occurring in the area is longer than the one presented. The threatened bald ibis is not even mentioned in this list, even though it breeds in close vicinity to the lease area (and the ibises are regularly seen foraging in the grassland in the lease area). It should have been emphasised that the brown robin has only been recorded from one other forest in Swaziland, while the orange thrush has not been recorded outside of the Mgwayiza forest. This makes the need for a proper survey even more crucial.

4) Without knowing what bird species ACTUALLY breed in the area, not much can be said about the impact on birds. The "desktop study" is of no help here. Birds are easily disturbed off the nest, regular disturbances often lead to desertion or predation. Since the northern area was not survey how can we be sure that the critically (and globally) endangered blue swallow does not breed there? This is the most endangered species of bird in southern Africa (less than 10 pairs breeding in Swaziland), and every nesting site must be given full protection. Mention has already been made of the bald ibis, brown robin and orange thrush (comment (3) above). The report mentions that mining operations will cease between October and February (was this just thrown in to make the "environmentalists" happy? Who will monitor this?). However, this is not necessarily the most critical time for breeding of birds of conservation significance. The bald ibis is a winter breeder, and actually moves out of the Malolotja area in summer. Most large eagles also start breeding in winter (June-August). Therefore, the cessation of mining in summer is unlikely to be of much use to these sensitive species.

5) It is mentioned on page 77 that the impact "on the physical and visual topography due to the construction of the storage areas will be of low significance". But the Mgwayiza Valley is visible from most view points in the southern part of the reserve. Therefore, the mine and accompanying mining activities will be visible from a large part of Malolotja Nature Reserve.

6) In connection with the law, on page 59, it is stated that ".... this case (the greenstone mine)* does not present unique circumstances as a road passing through the Hlane Game Reserve was constructed to be of service to the Simunye Sugar Estate". However, Hlane Game Reserve was not (and still is not) proclaimed under the SNTC Act, and therefore mining in Malolotja will be the first time that such an activity would take place in a reserve proclaimed under the SNTC Act (and therefore this does constitute a unique circumstance).

*The words in italics are mine.

7) Section 3.2 (No "Project" option) on pages 61 and 62 has presented a very weak argument for not mining the area. The tourism potential of the area has not been explored. Nor has the conservation significance of the area been appreciated (in light of the number of rare, endangered and endemic species present in the area, and the unique habitats of the area). In fact, the report implies just the opposite by claiming that the "..conservation of the area for future generations is not occurring..". The northern area of Malolotja Nature Reserve may possibly be the only area in Swaziland that qualifies as a "wilderness area" (in the strict sense of the word, as defined by the KwaZulu-Natal Conservation Service). The entire Malolotja Nature Reserve falls within a potential "biodiversity corridor" linking the north-eastern conservation areas of Swaziland with those in the north-west and with the Lubombo Spatial Development Initiative. This corridor has great ecotourism potential due to the large diversity of habitats and species present, as well as the scenic beauty of the area. This proposed corridor is also of regional (and global) significance as it would link up with conservation areas in South Africa, and proposed conservation areas in Mozambique. Ecotourism is one of the fastest growing industries in the world, and Swaziland stands to gain a lot from nature-based ventures. To throw away such an opportunity for a limited and short-term gain is myopic indeed. None of this was even hinted at in the report, suggesting that the consultant was not acting independently.

Dr. Ara Monadjem
Private Bag 4

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