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Comments | Discussions
Comments on the "Swaziland Greenstone Mine Envionmental Impact
Assessment" (EIA)
Kim Roques
The above mentioned EIA has a number of serious flaws and is definitely
notan adequate assessment of the impacts that will arise. I
support this statement with the following evidence:
- The fact that mining within a protected area undermines National law
(section 20, Swaziland National Trust Commission act 1973) and
international convention to which Swaziland is signatory (Convention on
Biological Diversity 1992) has serious national and international
implications. Arguing (as the EIA does) that quarrying in Malolotja is
legal because a quarry lease had been signed for an area loosely defined
as "situate in Hhohho District, a south of Bulembu village" is
very dubious. Even if one accepts this questionable argument it does not
change the fact that the Trust Commission act is undermined and an
international convention violated. What are the possible impacts of so
doing?
- Swaziland will be seen not to take the biodiverstiy convention
seriously with negative implications for future international assistance
and funding to this end. It is ironic that Swaziland has just completed
a biodiversity strategy through funding from this convention, which if
supported could have substantial sustainable benefits for the country as
a whole.
- Swaziland may be seen not to take the protection of its own legally
sanctioned conservation areas seriously. This could jeopardise tourism
and conservation initiatives that it has forged with its regional
neighbours South Africa and Mozambique, such as the tri-national Lubombo
Spatial Development, Maputo corridor and Transfrontier Conservation Area
Initiatives.
- Swaziland’s conservation areas may be seen to be insecure for
investment. This could limit its ability to attract donor funding and
private investment for conservation and tourism activities, something
that most parks in the country may become very dependant on.
- Mining in a Nature Reserve could set a precedent (though the EIA
denies this) and certainly a law undermined once becomes more easy to
undermine again. If compromises are made now there is little hope for
the protected areas of Swaziland when every indication suggests that in
fifteen years time social and economic pressures will be even higher.
What use will a big hole in the ground in Malolotja be then?
The EIA completely ignores these impacts which have the potential to be
extremely significant and in my view this is a very serious flaw.
- The EIA states that the proponents "do not propose to clear the
forest (mgwayisa) or remove trees". This is impossible since the
forest grows right up to the cliff face and encloses the access track
and therefore needs reassessing.
- The EIA states that it "does not cover the processing plant as
the area for the plant is still subject to negotiation and finalisation."
This is a flaw since the processing plant and mine are intimately
linked. The mine will probably not be viable and certainly the benefits
would be much reduced if the compliance certificate for the processing
plant is not granted and vice versa. Furthermore the placement of the
processing plant will influence access impacts. It is ridiculous that
they be assessed in isolation.
- The socio-economic impacts are not adequately assessed. Operating a
mine for only 7 months of the year (page 140) with a resultant 5 month
lay off period has many social and economic implications that have not
been considered. There is certain to be inmigration of people in search
of jobs with resultant social, economic, health and environmental
impacts that have been neglected. It seems to me that the local people
of the area have not been adequately informed of the potential impacts
that they may suffer. Certainly it seems that the number of vehicles
passing by their houses (2.14 vehicles/hour and 2 1t bakkie trips/day)
is underestimated (what about all the transport pertaining to services,
supplies, skilled personnel etc., or will it all be on site? If so the
impacts of such need to be assessed).
- The proponent mentions that soil sampling and animal trapping was not
permitted indicating that in some instances a desk top assessment was
necessary. It is not surprising that these actions were not permitted in
a National Reserve and suggests that the EIA is incomplete.
- The comprehensive mitigation plan is inadequate and SNTC should be
properly compensated for it’s loss.
In conclusion, the benefits of this project to Swaziland are substantial
but so are the "costs" and although the proponent concludes that
an environmental compliance certificate should be issued, the EIA has some
serious flaws that result in the negative impacts being significantly
underestimated. When one analyses the project based on the globally
recognised criteria of sustainability, equity and efficiency, it becomes
clear that the greenstone quarrying in Malolotja is neither:
- sustainable – future generations will be less able to meet their
needs if the project goes ahead due to direct removal of the greenstone
as a potential resource and reduction of tourism and conservation
benefits for the country and Malolotja (see point 1);
- equitable – most of the tourism, environmental, social and
economic "costs" of the project are born by Malolotja, the
SNTC, and the local people of the area, the benefits of the mine to
these groups are minimal (if any) and amount basically to employment of
100 people (servicing a very small fraction of the unemployed people in
the region). The benefits of the project accrue mostly to Michael Lee
Enterprises Pty Ltd and the East where 80% of the finished product’s
value is added; nor
- efficient – although the project is financially efficient for
Michael Lee Enterprises Pty Ltd from Swaziland’s point of view it
is not. There will be some limited improvements in employment for a
limited period of time, the government will gain some benefits through
royalties and taxes and local suppliers will gain some benefits through
short term contracts, but in reality these are outweighed by the "costs"
(evidence above) and are negligible in relation to the potential
benefits of tourism and conservation (greenstone can contribute 0.7% of
Swaziland’s yearly exports, whereas tourism can contribute
14% of the GDP for South Africa (WTTC, 1998)).
All the above evidence suggests that mining greenstone in Malolotja is
not efficient, sustainable, equitable nor desirable and therefore steps
should be taken to prevent it. A public debate by a well informed public
should be sufficient to come to this conclusion but there is always the
danger that the public majority are not well informed and therefore come
to a regrettable conclusion. I hope these comments are taken into full
consideration.
Mr Kim Roques
Senior Warden,
Mlawula Nature Reserve
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