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COMMENTS ON THE SWAZILAND GREENSTONE QUARRY ENVIRONMENTAL IMPACT ASSESSMENT (EIA) AND COMPREHENSIVE MITIGATION PLAN (CMP) COMPILED BY M D BATE (GEOVICON cc)

DATED 15 JANUARY 1999

The above EIA and CMP (‘report’) has raised several questions and concerns which I feel need to be addressed before the project should be allowed to proceed, if it should at all.

• Swaziland is a signatory to the international Convention on Biological Diversity (1992) which does not allow extractive mining to occur in protected areas. So why should Mr Michael Lee and his company, Michael Lee Enterprises (MLE) based in Sunninghill, South Africa, be allowed to proceed with the proposed mining of greenstone in Malolotja Nature Reserve (MNR)? It will set a precedent contrary to what the report says!

• The size of the lease area is suspicious, why does MLE need such a large lease area for mining the greenstone when the cliff face referred to in the report is a relatively small portion of the lease area? Are there perhaps other potential mining areas in the lease area which were not mentioned in the report?

• Details about the location of the processing plant (which have not yet being identified) leave an unanswered gap in the report. The impact(s) on the access road(s) to the processing plant have therefore not been addressed? For example, what will the impact(s) be on the existing Piggs Peak – Motshane road with extra vehicles carrying heavy loads on it once the mining process begins?

• How many people will visit or continue to visit the Reserve (especially the Mgwayisa Valley area) as a retreat from the noise and pollution of urban life, when it has a mine operating in it? This is not addressed in the report.

• As the co-ordinator of and a contributor to the Tree Atlas of Swaziland project, I am very disturbed to hear of the possibility of mining going on in the Mgwayisa Forest area. This is a representative area of a mist belt forest in the country and contains a rich diversity of floral species (as I have visited it myself). It is of significance to Swaziland and to the atlas project and should therefore be kept in the pristine condition that it is presently in. I find it hard to believe that the forest will be left in this pristine condition after 13 years of greenstone extraction. Page 62 of the report states that the ‘proponents of the project do not propose to clear the forest (Mgwayisa) or remove trees’. Who will monitor this especially as the forest emerges right onto the greenstone outcrop which the proponent is proposing to mine?

• The lease area holds the only locality in Swaziland of the Protea comptonii. The fact that this detail is not mentioned in the vegetation survey together with the fact that the proponent mentioned that sample collections were not allowed during the vegetation survey is worrying. How accurate and detailed therefore was the flora study that was carried out?

• The report states that it will mitigate the impacts on the fauna by not mining during the breeding season (i.e. from October until February). I find this a strange and an unbelievable form of mitigation. What about the economic viability of the mine to loose out 5 months of the year of greenstone extraction to breeding fauna? What about the effects this will have on the employees? Do they know about this? These issues are not addressed in the report and I find it highly unlikely that there will be someone monitoring this properly, especially after the first few years of operation once the public attention that the proposed mine is presently receiving dies off.

• ‘If an amphibian or reptile is seen on the track, the vehicle will stop and wait for it to cross before proceeding.’(page 136). I find this hard to believe, as well as ‘Personnel will not be permitted to feed or trap animals’ (page 138). Who will monitor this five or ten years down the line?

• The impact that the proposed project will have on Mr Siwela is questionable. I do not feel that ‘dust’ and ‘noise’ will be his only worries as the report indicates. What about safety and security with a potential increase in the threat of crime with the influx of people to the neighbourhood? What about the possibilities of STD’s and AIDS being transmitted and its mitigation with the influx of workers to the area?

• What about the increase in casual labour to the area. Where will they live and what impact will they have on the existing residents.

• The potential impact of the change in livelihoods of the people in the immediate area is not fully addressed in the report?

• Who will be the on-site person (environmental officer) monitoring the implementation of the CMP?

• Where will all the domestic refuse that will be collected daily in ‘44-gallon drums’ (page 132 and 133) be disposed of?

• Where are the Terms of Reference for the project as they are not included in the report?

In summary therefore, I do not feel that some important issues and concerns have been fully addressed in this report and would hope that the project would not be allowed to continue at this stage.

Ms Linda Dobson
P O Box 764
Mbabane

27 February 1999

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