MARAMPA IRON ORE PROJECT ENVIRONMENTAL AND SOCIAL IMPACT STATEMENT - VOLUME 2 Prepared For MARAMPA IRON ORE (S.L.) LIMITED Report Prepared by SRK Consulting (UK) Limited UK3823 SRK Consulting Marampa Iron Ore Project ESIS COPYRIGHT AND DISCLAIMER Copyright (and any other applicable intellectual property rights) in this document and any accompanying data or models is reserved by SRK Consulting (UK) Limited ("SRK") and is protected by international copyright and other laws. This document may not be utilised or relied upon for any purpose other than that for which it is stated within and SRK shall not be liable for any loss or damage caused by such use or reliance. 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Date: September 2012 Project Number: UK3823 SRK Project Director and Project Manager: Fiona Cessford Corporate Consultant (Environment) Marampa Iron Ore Limited Client Legal Entity: Client Address: Victoria Place 31 Victoria Street Hamilton Bermuda (British Overseas Territory) HM10 U3823_Marampa_ESIS_Final.docx September 2012 Page i of i SRK Consulting Marampa Iron Ore Project ESIS – Table of Contents Volume 1: Executive Summary Volume 2: Main Environmental and Social Impact Statement (this volume) Table of Contents 1 INTRODUCTION ................................................................................................. 1 1.1 Project setting .......................................................................................................................... 1 1.2 Project proponent .................................................................................................................... 4 1.3 ESIA team ................................................................................................................................ 4 1.4 Project background .................................................................................................................. 6 1.5 Project motivation .................................................................................................................... 8 1.6 Structure of the report .............................................................................................................. 8 2 ENVIRONMENTAL AND SOCIAL REGULATORY FRAMEWORK ................. 11 2.1 Sierra Leone requirements .................................................................................................... 11 2.1.1 ESIA/ EIA requirements in the EPA Act 2008 ............................................................. 11 2.1.2 ESIA/ EIA requirements in terms of the Mines and Minerals Act 2009 ....................... 12 2.1.3 Other environmental and social permissions .............................................................. 13 2.2 International guidelines and standards considered ............................................................... 14 2.2.1 Equator Principles, IFC requirements and WBG EHS guidelines ............................... 14 2.2.2 Self-regulation in the mining sector ............................................................................. 14 3 ESIA OBJECTIVES AND PROCESS ................................................................ 16 3.1 Objectives .............................................................................................................................. 16 3.2 Study area.............................................................................................................................. 17 3.3 ESIA Process ......................................................................................................................... 17 3.3.1 Phase 1: Scoping activities ......................................................................................... 20 3.3.2 Phase 2: Baseline investigations ................................................................................. 21 3.3.3 Phase 3: Impact identification and definition ............................................................... 27 3.3.4 Phase 4: ESIA report review and decision-making ..................................................... 35 3.3.5 Stakeholder consultation ............................................................................................. 36 3.4 Assumptions and limitations .................................................................................................. 39 4 PROJECT DESCRIPTION ................................................................................ 40 4.1 Construction ........................................................................................................................... 41 4.1.1 Land acquisition and resettlement............................................................................... 41 4.1.2 Construction camp and laydown area ......................................................................... 42 4.1.3 Land clearance and infrastructure development ......................................................... 42 4.1.4 Construction management .......................................................................................... 44 4.2 Mine site operation ................................................................................................................ 44 4.2.1 Preliminary pit design .................................................................................................. 44 U3823_Marampa_ESIS_Final.docx September 2012 Page i of ix SRK Consulting Marampa Iron Ore Project ESIS – Table of Contents 4.2.2 Preliminary production schedule ................................................................................. 45 4.2.3 Mining operations ........................................................................................................ 51 4.2.4 Mining equipment ........................................................................................................ 55 4.2.5 Explosives storage ...................................................................................................... 55 4.2.6 Waste rock dumps ....................................................................................................... 56 4.2.7 Topsoil ......................................................................................................................... 57 4.3 Processing ............................................................................................................................. 57 4.3.1 Stage 1 Beneficiation Plant ......................................................................................... 57 4.3.2 Stage 2 Beneficiation Plant expansion ........................................................................ 58 4.3.3 Reagents ..................................................................................................................... 61 4.4 Tailings storage facility .......................................................................................................... 64 4.4.1 Tailings and TSF decant water pipelines .................................................................... 64 4.4.2 TSF design .................................................................................................................. 64 4.4.3 TSF operation .............................................................................................................. 65 4.5 Power supply ......................................................................................................................... 66 4.6 Water supply .......................................................................................................................... 66 4.7 Concentrate transport ............................................................................................................ 69 4.7.1 Stage 1 development .................................................................................................. 69 4.7.2 Stage 2 development .................................................................................................. 69 4.8 Other site infrastructure and services .................................................................................... 69 4.8.1 Roads and freight ........................................................................................................ 69 4.8.2 Storm water management ........................................................................................... 70 4.8.3 Waste management .................................................................................................... 70 4.8.4 Communications .......................................................................................................... 71 4.8.5 Accommodation ........................................................................................................... 71 4.8.6 Medical services .......................................................................................................... 71 4.8.7 Fire fighting .................................................................................................................. 73 4.8.8 Mobile Equipment ........................................................................................................ 73 4.8.9 Fuel use and storage ................................................................................................... 73 4.8.10 Security ........................................................................................................................ 73 4.8.11 Ancillary buildings ........................................................................................................ 74 4.9 Project implementation .......................................................................................................... 74 4.9.1 Project milestones ....................................................................................................... 74 4.9.2 Operation management ............................................................................................... 74 4.9.3 Human resources management .................................................................................. 75 4.9.4 Procurement ................................................................................................................ 76 4.10 Pollution control ..................................................................................................................... 76 4.11 Project closure ....................................................................................................................... 78 4.12 Project Alternatives ................................................................................................................ 79 4.12.1 Power supply ............................................................................................................... 79 U3823_Marampa_ESIS_Final.docx September 2012 Page ii of ix SRK Consulting Marampa Iron Ore Project ESIS – Table of Contents 4.12.2 Water supply ................................................................................................................ 79 4.12.3 Concentrate transport .................................................................................................. 79 4.13 Future studies ........................................................................................................................ 80 5 BIOPHYSICAL BASELINE DESCRIPTION ...................................................... 81 5.1 Physiography and Landscape ............................................................................................... 81 5.2 Geology and Geochemistry ................................................................................................... 82 5.2.1 Geology ....................................................................................................................... 82 5.2.2 Geochemical characterisation ..................................................................................... 83 5.3 Natural Hazards ..................................................................................................................... 84 5.4 Climate ................................................................................................................................... 85 5.5 Water Resources ................................................................................................................... 86 5.5.1 Hydrology .................................................................................................................... 86 5.5.2 Hydrogeology .............................................................................................................. 89 5.5.3 Water quality ................................................................................................................ 89 5.6 Soils ....................................................................................................................................... 90 5.6.1 Soil quality ................................................................................................................... 93 5.6.2 Sediment quality .......................................................................................................... 94 5.7 Air Quality .............................................................................................................................. 95 5.8 Noise ...................................................................................................................................... 97 5.9 Biodiversity............................................................................................................................. 98 5.9.1 Terrestrial habitats and faunal associations ................................................................ 99 5.9.2 Terrestrial species of conservation significance ........................................................ 102 5.9.3 Aquatic habitats and faunal associations .................................................................. 103 5.9.4 Aquatic species of conservation concern .................................................................. 106 5.9.5 Aquatic ecosystem health ......................................................................................... 106 6 SOCIO-ECONOMIC BASELINE DESCRIPTION ............................................ 108 6.1 Approach and methodology ................................................................................................. 108 6.2 Population ............................................................................................................................ 110 6.2.1 Population in the study area ...................................................................................... 110 6.2.2 Ethnicity ..................................................................................................................... 110 6.3 Economy .............................................................................................................................. 111 6.3.1 Description of livelihoods in the study area ............................................................... 111 6.3.2 Value addition ............................................................................................................ 118 6.4 Land tenure .......................................................................................................................... 119 6.5 Living standards ................................................................................................................... 121 6.5.1 Possessions and expenditure ................................................................................... 122 6.5.2 Food Security ............................................................................................................ 122 6.5.3 Habitation .................................................................................................................. 123 6.5.4 Energy sources .......................................................................................................... 123 U3823_Marampa_ESIS_Final.docx September 2012 Page iii of ix SRK Consulting Marampa Iron Ore Project ESIS – Table of Contents 6.6 Social stratification ............................................................................................................... 123 6.7 Vulnerable groups ................................................................................................................ 123 6.8 Health ................................................................................................................................... 123 6.9 Education ............................................................................................................................. 125 6.10 Infrastructure ........................................................................................................................ 125 6.11 Ongoing governmental and non-governmental programmes .............................................. 126 6.12 Contemporary social system and practices ......................................................................... 126 6.13 Archaeology and cultural heritage ....................................................................................... 126 6.14 Community perceptions: needs and apprehensions ........................................................... 127 7 BIOPHYSICAL IMPACT ASSESSMENT ........................................................ 129 7.1 Land transformation ............................................................................................................. 131 7.1.1 LT1: Change in land use as a result of mine and related infrastructure limiting use by local communities ...................................................................................................... 131 7.1.2 LT2: Disruption of community access routes by mine infrastructure, potentially resulting in social disruption ...................................................................................... 133 7.1.3 LT3: Mine infrastructure and activities potentially resulting in visual impacts for local communities .............................................................................................................. 134 7.1.4 LT4: Loss of topsoil through erosion, decreasing land capability ............................. 136 7.1.5 LT5: Fugitive dust potentially resulting in changes in soil chemistry and agricultural land capability ............................................................................................................ 138 7.2 Water resources .................................................................................................................. 140 7.2.1 WR1: Pit dewatering potentially resulting in reduced groundwater availability to ecological systems and local communities ............................................................... 141 7.2.2 WR2: Surface water abstraction affecting downstream users .................................. 143 7.2.3 WR3: Project infrastructure causing altered surface water flow conditions, affecting downstream users ..................................................................................................... 144 7.2.4 WR4: Surface water diversions potentially causing changes to flood risk to adjacent agricultural areas and communities ........................................................................... 149 7.2.5 WR5: Seepage from mining wastes potentially resulting in deteriorated groundwater quality affecting communities and ecological systems .............................................. 151 7.2.6 WR6: Discharges or runoff to surface water potentially resulting in deteriorated water quality affecting communities and ecological systems .............................................. 153 7.3 Ecology and biodiversity ...................................................................................................... 157 7.3.1 EB1: Site clearance and positioning of Project infrastructure potentially resulting in habitat loss and fragmentation, and direct loss of fauna and flora ............................ 157 7.3.2 EB2: Soil disturbance facilitating the establishment and spread of invasive species, potentially affecting indigenous ecosystems ............................................................. 161 7.3.3 EB3: Project activities resulting in sensory or other disturbance to wildlife .............. 163 7.3.4 EB4: Mine infrastructure and activities attracting nuisance species, potentially resulting in impacts on indigenous ecosystems ........................................................ 165 8 SOCIO-ECONOMIC IMPACT ASSESSMENT ................................................ 167 8.1 Economic development ....................................................................................................... 167 8.1.1 ED1: Employment generation by the Project resulting in increased standard of living for the local community ............................................................................................. 168 U3823_Marampa_ESIS_Final.docx September 2012 Page iv of ix SRK Consulting Marampa Iron Ore Project ESIS – Table of Contents 8.1.2 ED2: Employee training leading to skills development in the local community ........ 170 8.1.3 ED3: Increase in government income (from taxes and royalty on mining) potentially leading to social development in Project area ........................................................... 171 8.1.4 ED4: Opportunities for local suppliers and contractors leading to local economic growth ........................................................................................................................ 172 8.2 Resettlement and loss of land, social and natural resources .............................................. 173 8.2.1 RL1: Impoverishment through loss of shelter, land and communal natural resources174 8.2.2 RL2: Changes to community access as a result of the Project potentially affecting livelihoods, access to communal social services and infrastructure and community cohesion .................................................................................................................... 176 8.2.3 RL3: Added pressure on limited host community resources potentially resulting in food insecurity and malnutrition ................................................................................. 178 8.3 Social order .......................................................................................................................... 179 8.3.1 SO1: Influx of job seekers causing increased pressure on government services and infrastructure, potentially resulting in reduced standard of living .............................. 179 8.3.2 SO2: Increase in social ills/problems ........................................................................ 180 8.3.3 SO3: Real or perceived unequal distribution of Project benefits potentially leading to social tension ............................................................................................................. 182 8.4 Archaeology and cultural heritage ....................................................................................... 183 8.4.1 AC1: Possible disturbance to sacred bushes and cemeteries leading to loss of community’s access to cultural resources ................................................................. 183 8.5 Decommissioning and closure ............................................................................................. 184 8.5.1 DC1: Closure of the mine leading to economic decline ............................................ 185 9 COMMUNITY HEALTH, SAFETY AND SECURITY IMPACT ASSESSMENT 187 9.1 Air quality ............................................................................................................................. 188 9.1.1 AQ1: Dust emissions causing nuisance and health impacts on local communities .. 189 9.2 Noise and vibrations ............................................................................................................ 196 9.2.1 NV1: Blasting causing air overpressure and vibrations, potentially resulting in disturbance of local communities .............................................................................. 197 9.2.2 NV2: Operation of mining equipment and vehicles potentially resulting in increase in background noise levels for local communities ......................................................... 200 9.3 Traffic safety ........................................................................................................................ 204 9.3.1 TS1: Increase in Project-related traffic on local and national roads causing increased wear and tear and risk of road accidents .................................................................. 204 9.3.2 TS2: Use of mine site roads by local communities and their livestock causing increased safety risks due to road accidents ............................................................ 207 9.4 Security and Social risks ...................................................................................................... 208 9.4.1 SR1: Risk of human rights abuses due to conflict with the communities .................. 208 9.4.2 SR2: Increased exposure to communicable diseases due to an influx of workers, potentially resulting in a deterioration in public health............................................... 210 9.5 Other hazards potentially resulting in injury ......................................................................... 211 9.5.1 OH1: Blasting resulting in fly rock potentially harming people or their possessions . 211 9.5.2 OH2: Community exposure to toxic or hazardous substances ................................. 212 U3823_Marampa_ESIS_Final.docx September 2012 Page v of ix SRK Consulting Marampa Iron Ore Project ESIS – Table of Contents 9.5.3 OH3: Fire or explosions due to storage of explosives and use of combustible materials .................................................................................................................... 213 9.5.4 OH4: Failure of the TSF resulting in pollution or harm to individuals ........................ 213 10 CUMULATIVE IMPACTS ................................................................................ 214 10.1 Water resources .................................................................................................................. 216 10.2 Economic growth ................................................................................................................. 217 10.3 Social change associated with population increase due to in-migration ............................. 217 11 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM ........................ 219 11.1 Planning elements ............................................................................................................... 221 11.1.1 Leadership and accountability ................................................................................... 221 11.1.2 Legal requirements and other obligations ................................................................. 221 11.1.3 Aspect identification and impact assessment throughout the Project life ................. 222 11.1.4 Objectives, targets and plans for management throughout the life of the Project .... 222 11.2 Implementation (Do) elements............................................................................................. 224 11.2.1 Roles and responsibility ............................................................................................ 224 11.2.2 Contractors, suppliers and vendors ........................................................................... 224 11.2.3 Training ...................................................................................................................... 226 11.2.4 Communication .......................................................................................................... 227 11.2.5 Operational controls .................................................................................................. 227 11.2.6 Documentation and record keeping .......................................................................... 228 11.3 Monitoring and reporting (Check) elements ........................................................................ 228 11.3.1 Assessing, correcting and improving performance ................................................... 228 11.3.2 Non-conformances and incident reporting ................................................................ 230 11.3.3 EMP and ESMS Reporting ........................................................................................ 231 11.4 Act elements ........................................................................................................................ 231 11.4.1 Governance/ Management review ............................................................................ 231 11.4.2 Management of change ............................................................................................. 231 11.5 Stakeholder engagement ..................................................................................................... 232 11.6 Emergency preparedness and response ............................................................................. 233 12 CONCLUSIONS AND OVERALL ASSESSMENT .......................................... 237 13 REFERENCES ................................................................................................ 243 List of Tables Table 1-1: Project Proponent Details ...................................................................................................... 4 Table 1-2: ESIA Team Members ............................................................................................................ 5 Table 1-3: Structure of the ESIS ............................................................................................................. 8 Table 2-1: Sierra Leone environmental and sustainable development legislation ............................... 11 Table 2-2: Environmental and social permissions needed for the Project ............................................ 15 Table 3-1: MIOP ESIA process ............................................................................................................. 19 Table 3-2: Preliminary impacts identified for the Marampa Project ...................................................... 22 Table 3-3: Specialist Studies undertaken during the ESIA ................................................................... 26 Table 3-4: Characteristics used to describe an impact ........................................................................ 31 U3823_Marampa_ESIS_Final.docx September 2012 Page vi of ix SRK Consulting Marampa Iron Ore Project ESIS – Table of Contents Table 3-5: Method for rating the significance of impacts ...................................................................... 33 Table 3-6: Example of impact significance rating summary table......................................................... 35 Table 3-7: High-level summary of stakeholder issues raised and where addressed in the ESIS ........ 38 Table 4-1: Preliminary Ore/Waste Volumes per Pit .............................................................................. 44 Table 4-2: Indicative production schedule ............................................................................................ 49 Table 4-3: Mining equipment ................................................................................................................ 55 Table 4-4: Reagents and other materials likely to be used in the beneficiation plant ......................... 64 Table 4-5: TSF design criteria .............................................................................................................. 65 Table 4-6: Power station capacity and requirements ............................................................................ 66 Table 4-7: Water storage facilities ........................................................................................................ 67 Table 4-8: Management of non-mining wastes ..................................................................................... 72 Table 4-9: Mobile equipment list for site operation ............................................................................... 73 Table 4-10: Estimate of operational personnel requirements ............................................................... 76 Table 4-11: Expected emissions and effluents from mining operations ............................................... 77 Table 5-1: Climate data from MIOL meteorological station .................................................................. 85 Table 5-2: Calculated surface water flows ............................................................................................ 87 Table 5-3: Air quality baseline monitoring programme at mine site ...................................................... 95 Table 5-4: Baseline noise level measurements March 2011 (dBA) ...................................................... 98 Table 6-1: Population in the study area villages ................................................................................. 110 Table 6-2: Distribution of livelihood strategies (aggregated for all study villages) .............................. 111 Table 6-3: Livestock husbandry in the Project area ............................................................................ 114 Table 6-4: Traded wild products ......................................................................................................... 118 Table 6-5: Artisans and specialist skills in the study villages .............................................................. 120 Table 6-6: Income sources in the study area ...................................................................................... 122 Table 6-7: Annual household expenditure in the study area .............................................................. 122 Table 6-8: Most prevalent health problems in the Project area .......................................................... 124 Table 6-9: Consultation of medical services in the study area ........................................................... 124 Table 6-10: Educational levels in the study area ................................................................................ 125 Table 7-1: Summary of evaluated biophysical impacts ...................................................................... 129 Table 7-2: Current use of land directly disturbed by mine infrastructure ............................................ 132 Table 7-3: Predicted changes to 1 in 100 year peak flows and catchment areas for sub-catchments in the Project area ......................................................................................................... 146 Table 7-4: Area of each habitat type directly impacted by the Project ............................................... 158 Table 8-1: Summary of evaluated social impacts ............................................................................... 167 Table 9-1: Summary of evaluated community health and safety impacts or risks .............................. 188 Table 9-2: Predicted 24-hour dust concentrations at local villages .................................................... 194 Table 10-1: Past, present and reasonably foreseeable activities in Project affected area potentially resulting in cumulative impacts ................................................................................. 215 Table 11-1: Elements of the ESMS ..................................................................................................... 220 Table 11-2: Key Roles for Environmental and Social Management ................................................... 225 Table 11-3: Relationship between stakeholder engagement and the ESMS elements ..................... 233 Table 12-1: Preliminary summary of environmental, socio-economic and health and safety impact ratings ........................................................................................................................ 240 List of Figures Figure 1.1: Location of the Project site within Sierra Leone ................................................................... 2 Figure 1.2: Regional setting for the Project site, showing exploration license numbers ........................ 3 Figure 1.3: Interpretive geology of EL46/2011, relative to initial Project layout ..................................... 7 Figure 3.1: Study areas for MIOP ESIA ................................................................................................ 18 Figure 3.2: Overview of the stakeholder engagement process undertaken ......................................... 37 Figure 4.1: Overall site layout plan for the Project, with additional detail on the beneficiation plant and road crossing ............................................................................................................... 43 Figure 4.2: Mafuri prospect interpretive geology................................................................................... 45 Figure 4.3: Rotret prospect interpretive geology ................................................................................... 46 Figure 4.4: Gafal prospect interpretive geology .................................................................................... 47 Figure 4.5: Matukia Prospect Interpretive Geology .............................................................................. 48 Figure 4.6: Layout for Stage 1 mining, showing preliminary surface water management design ........ 52 Figure 4.7: Layout for Stage 2 mining, showing preliminary surface water management design ........ 53 U3823_Marampa_ESIS_Final.docx September 2012 Page vii of ix SRK Consulting Marampa Iron Ore Project ESIS – Table of Contents Figure 4.8: Layout at end of mine, showing backfilled pits and preliminary surface water management design .......................................................................................................................... 54 Figure 4.9: Schematic process flow diagram for Stage 1 .................................................................... 59 Figure 4.10: Schematic process flow diagram for Stage 2 (full development) ..................................... 60 Figure 4.11: Beneficiation plant layout for Stage 1 ............................................................................... 62 Figure 4.12: Beneficiation plant layout, showing Stage 2 expansion ................................................... 63 Figure 4.13: Site layout for end of mine showing locations of settlement ponds and water storage reservoir ....................................................................................................................... 68 Figure 4.14: Proposed organisation chart for operations ...................................................................... 75 Figure 5.1: Low lying swamp area previously used as rice paddy field ................................................ 81 Figure 5.2: River basin to the north west of the Project area ................................................................ 82 Figure 5.3: Topography of Sierra Leone (red symbol indicates Project location) ................................. 82 Figure 5.4: Automatic meteorological station at the MIOL site office ................................................... 86 Figure 5.5: Catchments in the Project area .......................................................................................... 88 Figure 5.6: Measurement of depth to water table using a dip meter .................................................... 89 Figure 5.7: Locations of groundwater and surface water monitoring points ......................................... 91 Figure 5.8: Soil sampling using hand auger.......................................................................................... 92 Figure 5.9: Soil and sediment sampling locations ................................................................................ 93 Figure 5.10: Air quality and noise monitoring locations ........................................................................ 96 Figure 5.11: Photographs of terrestrial habitats within the study area ............................................... 100 Figure 5.12: Distribution of terrestrial habitats across the study area ................................................ 101 Figure 5.13: Photographs of aquatic habitats within the study area ................................................... 104 Figure 5.14: Distribution of aquatic habitats across the study area and locations of baseline and biomonitoring sampling sites ..................................................................................... 105 Figure 5.15: Impacts on streams due to road construction on neighbouring concession area .......... 107 Figure 6.1: Location of villages covered under household survey and rural livelihoods study ........... 109 Figure 6.2: Photographs of different agricultural methods .................................................................. 112 Figure 6.3: Photographs of different crops .......................................................................................... 113 Figure 6.4: Photograph of crops fenced against livestock .................................................................. 114 Figure 6.5: Photographs of different fishing related activities ............................................................. 115 Figure 6.6: Photograph of medicinal plants and plants used for construction .................................... 116 Figure 6.7: Photographs of different types of traps ............................................................................. 117 Figure 6.8: Photographs of sand mining ............................................................................................. 118 Figure 6.9: Photographs of value addition to crops ............................................................................ 119 Figure 6.10: Photographs of artisanal work ........................................................................................ 121 Figure 6.11: Traditional houses .......................................................................................................... 123 Figure 6.12: Examples of educational facilities ................................................................................... 125 Figure 6.13: Location of archaeological and cultural heritage sites in the study area ........................ 128 Figure 7.1: Catchment areas affected by surface water diversion and storage infrastructure, indicating flow directions ............................................................................................................ 148 Figure 7.2: The invasive alien plant Chromlaena odorata (Triffid Weed) ........................................... 162 th Figure 9.1: Maximum predicted 98 percentile PM10 concentrations over the Project area, without management .............................................................................................................. 192 th Figure 9.2: Maximum predicted 98 percentile PM10 concentrations over the Project area, with management .............................................................................................................. 193 Figure 9.3: Noise contour map at day time for 100 Mtpa mining rate, relative to local villages ......... 201 Figure 9.4: Noise contour map at night time for 100 Mtpa mining rate, relative to local villages ....... 202 Figure 11.1: Types of obligations relevant to the ESMS ..................................................................... 221 List of Technical Appendices A SUMMARY OF APPLICABLE LEGISLATION AND INTERNATIONAL GUIDELINES ....................................................................................................A-1 B SLEPA APPLICATION FORM AND SUPPORTING CORRESPONDENCE ...B-1 C STAKEHOLDER ENGAGEMENT PLAN .........................................................C-1 D RESETTLEMENT FRAMEWORK ....................................................................D-1 U3823_Marampa_ESIS_Final.docx September 2012 Page viii of ix SRK Consulting Marampa Iron Ore Project ESIS – Table of Contents E PRELIMINARY PROJECT DESIGN DRAWINGS ............................................ E-1 F ENVIRONMENTAL MANAGEMENT PROGRAMME ....................................... F-1 G PRELIMINARY ENVIRONMENTAL AND SOCIAL MONITORING PROGRAMMES .............................................................................................. G-1 H MIOL POLICIES ...............................................................................................H-1 VOLUME 3: SUPPORTING DOCUMENTATION 1 SD 1: Terms of Reference for Specialist Studies 2 SD 2 A: Climate and Air Quality Baseline 3 SD 2 B: Impact Modelling Reports 4 SD 3 A: Noise Baseline 5 SD 3 B: Impact Modelling Reports 6 SD 4 A: Biodiversity Baseline 7 SD 4 B: Aquatic Bio-Monitoring Report 8 SD 5: Soils and Geomorphology Baseline Report 9 SD 6: Geochemistry ARDML Baseline Report 10 SD 7: Water Reasources Baseline and Impact Assessment Report 11 SD 8: Archaeology and Cultral Heritage Baseline Report 12 SD 9: Socio-Economic Baseline Report 13 SD 10: Natural Resource Use/Rural Livelihoods Baseline Report U3823_Marampa_ESIS_Final.docx September 2012 Page ix of ix SRK Consulting (UK) Limited 5th Floor Churchill House 17 Churchill Way City and County of Cardiff CF10 2HH, Wales United Kingdom E-mail: enquiries@srk.co.uk URL: www.srk.co.uk Tel: + 44 (0) 2920 348 150 Fax: + 44 (0) 2920 348 199 MARAMPA IRON ORE PROJECT ENVIRONMENTAL AND SOCIAL IMPACT STATEMENT - VOLUME 2 1 INTRODUCTION SRK Consulting (UK) Ltd (“SRK”) has been commissioned by Marampa Iron Ore (S.L.) 1 Limited (“MIOL”) to undertake an Environmental and Social Impact Assessment (“ESIA” ) for the Marampa Iron Ore Project (the “Project” or “MIOP”) that meets the requirements of Environment Protection Agency Act No. 11 of 2008. This environmental and social impact assessment statement (“ESIS”) is the documented findings of the ESIA process. The Project is located near the township of Lunsar, some 90 km northeast of the capital city of Freetown, in the Port Loko district of Sierra Leone, West Africa. The Project comprises 2 Exploration Licences, EL46/2011 A and B, held by MIOL, which cover an area of 305.12 km . 2 EL46/2011 A encloses (but excludes) Mining Lease ML02/09 (13.82 km ) held by London Mining plc, as shown on Figure 1.2. ML02/09 contains the former Sierra Leone Development Company Ltd (“DELCO”) open pit mining operation (see Section 1.4 for background on mining in the area). The Project involves the open pit mining and beneficiation 680 Mt of iron ore from four resource deposits in the MIOL exploration licence area. MIOL are in an early stage of Project planning (engineering scoping) and acknowledge the importance of addressing environmental and social issues early in the planning process. The ESIA process has therefore been initiated at this early stage to maximise the opportunity for interactions between the ESIA and Project design teams, and to provide sufficient time for the collection of suitable environmental and social baseline information as input to the ESIA process and ongoing Project design. 1.1 Project setting The Project is located in Sierra Leone, West Africa (refer to Figure 1.1). The site is approximately 90 km northeast of the capital Freetown near the town of Lunsar in the Port Loko District on the coastal plain of Sierra Leone (see regional setting in Figure 1.2). The region around the Project area is relatively flat and low-lying at a height of approximately 50- 90 m above sea level (“masl”). The exploration area is characterised by two main drainage regimes; the Rokel River in the south flows from east to west and the north is drained to the west by tributaries of the Port Loko Creek. The country has a tropical savannah climate with distinct wet and dry seasons. The dry season lasts from December to mid-February, changing to wetter and warmer conditions in mid-February to April, and the rainy season stretches from May to December. 1 The abbreviation ESIA is one of several commonly used terms for impact assessment. Another frequently used abbreviation, “EIA” (environmental impact assessment), has been adopted by the Sierra Leone legislation. The term ESIA is used herein to emphasize the inclusion of social aspects in the impact assessment (environmental and social impact assessment). The ESIA is equivalent to the EIA referred to in the Sierra Leone requirements summarized below. The definition of the word “environment” given in the EPA Act implies that it includes social aspects. Group Offices: Africa Registered Address: 21 Gold Tops, City and County of Newport, NP20 4PG, Asia Wales, United Kingdom. Australia SRK Consulting (UK) Limited Reg No 01575403 (England and Wales) Europe North America South America SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 1.1: Location of the Project site within Sierra Leone Sierra Leone is part of the westernmost part of the upper Guinean lowland forest, which is rich in terms of biodiversity. The natural habitat type for the coastal plain of Sierra Leone is savannah, however the biological environment around the study area is characterised by a highly disturbed environment with significant anthropogenic influences such as slash and burn and subsistence agriculture. These activities have resulted in a prevalence of secondary vegetation growth and a lack of undisturbed habitats. In the Project area, the traditional economic activities are agriculture (largely subsistence- based), charcoal making, animal husbandry, fishing, and trading. Mining is emerging as an additional employment sector due to presence of MIOL, African Minerals Limited (“AML”) and London Mining plc (“London Mining”), the latter of which recently commenced operations at the end of 2011. The largest town in the Port Loko District is Lunsar, in which MIOL’s local office is located. The population of the town has significantly increased in recent years due to the influx of people from surrounding rural areas, thought to be due to the arrival of mining companies in the area. A number of villages surround Lunsar. The houses in the villages are largely built out of mud with palm leaf or corrugated iron roofs. Most villages have a hand-pump well for water supply, but do not have a formal drainage system. U3823_Marampa_ESIS_Final.docx September 2012 Page 2 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 1.2: Regional setting for the Project site, showing exploration license numbers U3823_Marampa_ESIS_Final.docx September 2012 Page 3 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report A culturally important feature of the local communities is the presence of traditional secret societies. These are ancient cultural institutions in the Upper Guinea Coast of West Africa that remain a key element in political relations in rural Sierra Leone (UNHCR, 2007). Society rituals are often performed in dedicated areas of forest called “society bush” having restricted access for non-society members. The natural environment is also an important livelihood resource in terms of food, construction materials, firewood and medicine. 1.2 Project proponent The Project is owned by MIOL, a wholly owned subsidiary of Marampa Iron Ore Limited (a Bermudan registered private company), which is a wholly owned subsidiary of Cape Lambert Resources Limited (“Cape Lambert”). Cape Lambert is an Australian domiciled public company with interests in a number of resource Projects and companies with mineral assets located in Australia, Africa, Greece and South America. Cape Lambert’s stock is listed on the Australian Stock Exchange with ticker “CFE”. Proponent details are provided in Table 1-1: Table 1-1: Project Proponent Details Responsible person: Jack Rowley Position: Project Director Mobile : +61 422 043 125 Contact numbers: Office : +61 8 9380 9555 Fax : +61 8 9380 9666 Email : JackR@capelam.com.au 32 Harrowgate Street Address: West Leederville WA 6007 PO Box 144 West Perth WA 6872 1.3 ESIA team The Project’s ESIA team is largely made up of staff from a number of SRK’s global offices (UK, South Africa and Turkey practices), as well as specialists from various other consultancies. The key team members and their roles are outlined in Table 1-2. SRK is the overall Project manager for the ESIA process and has: provided reporting expertise; given insight on interpretation of the relevant guidelines and standards; and co-ordinated liaison with the Project’s client and engineering teams. Where possible, in-country expertise has been used for logistical support, ongoing water, climatic and air quality monitoring, identification of vegetation and interviewing communities during the natural resource use survey, and assistance with stakeholder consultations (in particular with regulatory authorities and local communities). U3823_Marampa_ESIS_Final.docx September 2012 Page 4 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 1-2: ESIA Team Members Company Name Role in ESIA Process Qualifications/Experience Fiona Cessford Project manager MSc, Pr.Sci.Nat., Corporate Consultant (Environment) Nicola Rump and Project co-ordinators MSc , Consultant (Environmental) Steve King MSc, Senior Consultant (Environmental) Lalit Kumar Socio-economic study and BA (Sociology), MA (Development stakeholder consultation. Planning and Administration) Hilde van Socio-economic study PhD (social psychology), Principal Vlaederen reviewer Consultant (Social) Bora Arpacioglu Noise baseline MSc, ME, Principal Environmental SRK characterisation Engineer Matt Dey Geochemistry (ARDML) Principal Consultant (Geochemical characterisation Engineering) Air quality baseline MSc (Environmental Geochemistry), Vis Reddy characterisation and Pr.Sci.Nat., Principle Consultant predictive modelling Ruth Warrender Soils and geomorphology PhD; Consultant (Geochemistry) characterisation Water resources study PhD, C.Geol FGS, Corporate Consultant Tony Rex and predictive modelling (Hydrogeology) team leader Jeff Hamilton Engineering liaison and General Manager reviewer Steve Kesler Reviewer CEO Jack Rowley ESIA client manager and Project Director MIOL reviewer Local MIOL staff Support water resources members study team through Trained and supervised by T. Rex of SRK ongoing water monitoring Local MIOL staff Management of on-site Trained and supervised by T. Rex of SRK members weather station Support social team with stakeholder engagement Bachelor of Social sciences degree and Aminata Kamara and social survey data over 10 years’ experience in mining and collection; infrastructure Projects in Sierra Leone Sierra Leone Manage field survey consultants teams Identification of vegetation Chief Technician - Department of Biological Mr A.M.B. Feika and assistance with Sciences, Njala University; Sierra Leone surveys for Natural national museum curator. Resource Use study. Nexus Heritage Gerry Wait Archaeology and cultural FSA, DPhil, MIfA heritage baseline study Ecorex Warren Terrestrial ecologist with 14 years’ Consulting McCleland Ecological baseline study experience. Ecologists Tepid Robert Palmer Ecological baseline study PhD (aquatic ecology) and 20 years’ Consultants (Aquatic components) experience. Wild Resources Jenny Wong; Natural Resource Use PhD, study team leader; BSc, MPhil; Limited Bryan Dickinson study team U3823_Marampa_ESIS_Final.docx September 2012 Page 5 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 1.4 Project background The area around Lunsar was the focus of significant mining operations run by DELCO between 1933 and 1975. This mining operation, which is located within ML02/09, mined both the lateritic cap from Masaboin and Gafal Hills, and the underlying specular hematite schists. The specular hematite was concentrated by crushing, coarse grinding and gravity separation, with production reaching approximately 2.5 million tonnes per annum (“Mtpa”) of concentrate in the late 1960s (Cape Lambert, 2009). DELCO constructed a railway and port loading facility at Pepel Port for transport of the product to worldwide markets. During the DELCO period of operation, a large community was established in connection with the mine, which included hospitals, schools, community hall and sports facilities for employees and the local community. The health centre was a recognised training centre for student nurses and an apprentice scheme for boys was also established. The Delco mining operation closed in 1975, following a drop in iron ore prices, resulting in significant job losses. Smaller-scale operations began again in 1981, which involved dredging of the tailings by Austrian company, Austromineral GMBH. This operation was abandoned in 1985 due to increasing production costs. Recent exploration by MIOL identified six priority areas prospective for specular hematite schist mineralisation (Figure 1.3): • Gafal Prospect (including Gafal South and West) - an area comprising gravity high and scattered magnetic high anomalies located immediately to the west of the old Gafal Hill mining area and abutting ML02/09; • Matukia Prospect - an area 1.5 km long covering a gravity high located immediately along strike to the north of the old Masaboin Hill mining area abutting ML02/09; • Makambo Prospect - located approximately 8km north of the town of Lunsar; • Mafuri Prospect - a gravity high located approximately 3 km west of Gafal; • Rotret Prospect - a gravity high located approximately 1.5 km south of Gafal; • Toma Prospect - approximately 7 km south of Lunsar and south of the Rokel River. The presence of hematite schist was confirmed in old prospecting pits during initial field reconnaissance in early 2009. Of the six priority areas, MIOL is currently focussing on the development of the Gafal, Rotret, Mafuri and Matukia Prospects for the current ESIA and mining licence application. An environmental and social reconnaissance survey was carried out by SRK in June 2009. The objectives of the survey were to assess the current environmental and social conditions of the Project area and to identify specific aspects that may require particular consideration during the development of the Project. This survey was considered to be a pre-ESIA activity, but it collected useful information for the scoping process (the first stage of the ESIA process). The survey concluded there was little existing environmental and social data available for the area likely to be affected by the Project and site-specific information would be required as the Project progresses for both engineering and environmental purposes. U3823_Marampa_ESIS_Final.docx September 2012 Page 6 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 2 Figure 1.3: Interpretive geology of EL46/2011, relative to initial Project layout 2 Source: Cape Lambert, 2011 U3823_Marampa_ESIS_Final.docx September 2012 Page 7 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Due to the presence of historic mining activities close to the geological target areas, a long- term baseline monitoring programme commenced so that the pre-disturbance water, sediment and soil quality status in the area potentially affected by the Project could be fully characterised, as these may have been negatively affected by the previous mining activities. Social issues such as land ownership, compensation and in-migration were also highlighted as issues requiring particular consideration as the Project progressed. Following the outcome of the survey, SRK commenced the Environmental Scoping Study (“ESS”) in June 2010, which progressed to a full ESIA process in January 2011. 1.5 Project motivation A preliminary mining scoping study conducted by Bateman Engineering Pty Ltd (“Bateman”) concluded that mining at a capacity of up to 15Mtpa is technically feasible, and financial estimates to date are positive. The Project Mineral Resource is estimated at 680 million tonnes with an in-situ grade of 28.2% Fe (15% Fe cut-off grade) and, with processing, could generate a high quality saleable iron concentrate (~65% Fe), with low levels of deleterious elements. Access to existing rail and port infrastructure, which was recently upgraded and returned to operation by AML, has the advantage of lower capital investment start-up costs and Project lead time, as well as significant environmental advantages, as opposed to construction of a new port and rail. Open pit mining is the preferred mineral extraction method, further reducing capital development costs. As the area currently experiences high unemployment rates and has little or no infrastructural development, through appropriate management, there is potential for local communities to benefit from the Project through direct and indirect employment and development opportunities. Much of the Project footprint area has been disturbed through both previous mining and subsistence agriculture, and therefore is not ecologically pristine, reducing its conservation value and the likely environmental impact. 1.6 Structure of the report The ESIS is presented in three volumes; the structure and content of the three volumes is described in Table 1-3. Information contained within this main report (Volume 2) aims to be concise with supporting technical information presented as Supporting Documents (“SD”) in Volume 3. A glossary of terms is presented at the end of the report and gives an explanation of the main terms used throughout the report. Table 1-3: Structure of the ESIS Volume Short Description Volume 1 Non-Technical Summary A non-technical summary of the ESIA process and main conclusions Non-Technical Summary Information aims to be concise and easily understood by all interested parties. Volume 2 Environmental and Social Impact Statement Chapter 1: Introduction Gives general information about the Project and its proponent. Chapter 2: Environmental Outlines the legislative and regulatory requirements of Sierra Leone, as and Social Regulatory relevant to the Project, along with reference to international standards Framework also considered during the study. U3823_Marampa_ESIS_Final.docx September 2012 Page 8 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Volume Short Description Provides an overview of the objectives of the ESIA and the process Chapter 3: ESIA Objectives undertaken including the scope of work, baseline studies, impact and Process assessment process, and public consultation and disclosure requirements. It includes the assumptions and limitations that have been recognised in the preparation of this ESIA. Chapter 4: Project Describes the proposed Project, including the mine development, Description processing, tailings management, power generation, water supply, transport, waste management and other associated infrastructure. Chapter 5: Bio-physical Describes the existing condition of the physical and biological Baseline Description components of the environment in relation to international and Sierra Leone environmental standards. Chapter 6: Socio-economic Describes the current social and economic conditions in the regional and Baseline Description local area, with reference to conditions in Sierra Leone as a whole. Identifies and evaluates bio-physical impacts likely to arise as a result of Chapter 7: Bio-physical the Project in relation to sensitive natural and human receptors, and Impact Assessment determines the overall significance of each impact. It includes identification of appropriate management measures. Chapter 8: Socio-economic Identifies and evaluates the socio-economic impacts including Impact Assessment identification of appropriate management measures. Chapter 9: Community Summarises the potential health and safety risks to local communities as Health and Safety Risks a result of the Project, and identifies appropriate management measures. Chapter 10: Cumulative Discusses potential cumulative impacts resulting from other Impacts developments in the area as well as future phases of the Project. Provides a framework for the environmental and social management Chapter 11: Environmental system that will need to be implemented in response to the impacts and Social Management identified in Sections 7 and 8. It provides an environmental and social System management plan, and includes a monitoring programme and the Stakeholder Engagement Plan (SEP) for the Project. Chapter 12: Conclusions Summarises the key findings and outcomes of the ESIA process. Chapter 13: References Contains references to documentation and other sources of information that were used in this ESIS. Appendices Includes appendices for the main body of the report Appendix A Summary of applicable legislation and international guidelines Appendix B SLEPA application form and supporting correspondence Appendix C Stakeholder Engagement Plan and supporting information Appendix D Resettlement Framework Appendix E Preliminary Project design drawings Appendix F Environmental Management Plan Appendix G Preliminary Monitoring Programmes Appendix H MIOL policies Volume 3 Supporting Documents SD 1: Terms of Reference Defines both general and study-specific Terms of Reference (ToR) for Specialist Studies provided to the specialists and on which their respective studies were based. SD 2: a) Climate and Air Characterises the current air quality on site (baseline) and predicts (via Quality Baseline and b) modelling) potential impacts on air quality resulting from the Project. Impact modelling reports SD 3: a) Noise Baseline Characterises the current noise levels on site (baseline) and predicts (via and b) Impact modelling modelling) potential noise impacts on surrounding communities resulting reports from the Project. SD 4: a) Biodiversity Characterises the present ecological state (baseline) of the Project area Baseline and b) Aquatic and indicates existing impacts, sensitive habitats and species of special Bio-monitoring Report concern. SD 5: Soils and Characterises and comments on the soil quality for the study area Geomorphology Baseline relative to relevant quality guidelines and average crustal abundance. report U3823_Marampa_ESIS_Final.docx September 2012 Page 9 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Volume Short Description SD 6: Geochemistry Characterises the expected tailings, waste rock and ore product with ARDML Baseline report regard to predicted acid generation and mineral leaching properties SD 7: a) Water Resources Characterises the current water quality and flow dynamics (both surface Baseline and b) Impact and ground water), and makes predictions (via modelling) regarding Assessment report potential impacts on water resources SD 8: Archaeology and Identifies and maps sites of cultural heritage importance within the study Cultural Heritage Baseline area and makes recommendations for further work required (Phase 2 report assessment) should the Project be authorised. SD 9: Socio-economic Summarises the current social and economic status of the area in the baseline report. local and regional context, and provides background on Sierra Leone as a country. SD 10: Natural Resource Identifies, characterises and (where possible) maps the plant and animal Use / Rural Livelihoods species used by local communities and describes agricultural and baseline report. harvesting practices, including information on seasonality. U3823_Marampa_ESIS_Final.docx September 2012 Page 10 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 2 ENVIRONMENTAL AND SOCIAL REGULATORY FRAMEWORK This chapter summarises the environmental and social regulatory framework for the Project, with an emphasis on requirements relating to the impact assessment process. Section 2.1 presents a brief summary of the legal/regulatory requirements of Sierra Leone and Section 2.2 describes international guidelines and standards that were referred to in the preparation of this report. Further detail on the applicable legislation and international guidelines summarised below and considered when preparing this ESIS is provided in Appendix A. 2.1 Sierra Leone requirements Key Sierra Leone legislation pertinent to the environment and to sustainable development considered in the planning of the Project is listed in Table 2-1. The legislation most relevant to the ESIA process is: • the Environment Protection Agency Act No. 11 of 2008 (EPA Act 2008); and • the Mines and Minerals Act 2009. A brief outline of the relevant requirements of these two Acts is presented in Sections 2.1.1 and Section 2.1.2, respectively, with more detail given in Appendix A. Environmental and social permissions needed by the Project are identified in Section 2.1.3. Table 2-1: Sierra Leone environmental and sustainable development legislation Primary subject Policy Legislation Environment and National Environmental • The Environment Protection Agency Act, 2008 sustainable Policy (1994) (No. 11 of 2008) development Mineral resources Core Mineral Policy of the • National Reconstruction and Development Act, and mining Government of Sierra 1999 (No. 5 of 1999) Leone (2008) • Mines and Minerals Act, 2009 Water National Water and • The Water (Control and Supply) Act, 1963 Sanitation Policy (August • Sierra Leone Water Company Act, 2001 (No. 6 2008) of 2001) Biodiversity and National Biodiversity • Wildlife Conservation Act, 1972 (No. 27 of 1972) biological Strategy and Action Plan resources (developed in accordance Forestry with the requirements of • Forestry Regulations, 1989 (P.N. No. 17 of the 1992 Convention on 1990) Biodiversity) • Forestry Act, 1988 Land National Lands Policy • Devolution of Estates Act, 2007 (No. 21 of (2005) 2007) • Land Commission Act (not promulgated yet) • Commercial Lands Act (not promulgated yet) Radiation • Protection from Radiation Act, 2001 (No. 14 of 2001) Occupational • The Factories Act, 1974 (1974) environment Local government • Local Government Act, 2004 (2004): An Act which provides for decentralisation and devolution of functions, powers and services to local councils. 2.1.1 ESIA/ EIA requirements in the EPA Act 2008 The EPA Act 2008 forms the legal basis for environmental management and protection in Sierra Leone. It provides for the establishment of an Environment Protection Agency (“EPA” U3823_Marampa_ESIS_Final.docx September 2012 Page 11 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report or “SLEPA”), which has a wide range of environmental management functions including coordination of the activities of government agencies and other agencies on matters relating to environmental protection and management. The governing body of the EPA is a Board of Directors, which comprises a chairman and senior representatives of several ministries with an interest in environmental matters and people knowledgeable in commence, finance and law. The EPA Act requires EIA licences to be obtained for Projects with the potential to have significant impacts. The Act charts the procedure to obtain an EIA licence, with emphasis on the responsibilities of the EPA and the EPA Board, as outlined below. • An application must be made to the EPA for a licence, accompanied by a description of the proposed Project (refer to Appendix B for Application and Screening Forms th submitted to SLEPA, dated 17 August 2010) . • The EPA will decide (within 14 days) whether an EIA is required. • If required, the applicant should then prepare an EIA (refer to Appendix B for th correspondence from SLEPA dated 20 August 2010, in which it is confirmed that an EIA is required). • On receipt of the EIA, the EPA will circulate it to professional bodies or associations, Government Ministries and non-governmental organisations (“NGOs”) for review. • The EPA will also open the EIA for public inspection and comment. It will notify the public of this in two issues of the Gazette (consecutive issues) and two issues of a newspaper (with an interval of at least seven days between the first and second publications). • The EPA will submit the comments on the EIA, together with the EIA, to the Board for consideration. • If the Board approves the EIA, it will instruct the Executive Director of the EPA to issue an EIA licence. • The EPA will issue a licence to undertake the activity/ Project. An EIA licence will have a period of validity and contain conditions for the protection of the environment. The EIA licence procedure presented in the EPA Act 2008 appears to be the same as that presented in the repealed Environment Protection Act 2000, except that the agencies responsible for implementation of the EIA provisions have changed. Guidelines on EIA procedures were published by the MLCPE in July 1999. The same guidelines were re-issued by the MLCPE in July 2002. The guidelines were originally intended to facilitate implementation of the EIA provisions in the old Environment Protection Act 2000 and are currently considered by the MLCPE to be valid for the EIA provisions in the new EPA Act, 2008. A summary of the EIA procedure to be followed in terms of the MLCPE guidelines is presented in Appendix A. 2.1.2 ESIA/ EIA requirements in terms of the Mines and Minerals Act 2009 The Ministry of Mineral Resources (“MMR”) controls mining and mining-related matters by means of the Mines and Minerals Act 2009. This Act replaces the Mines and Minerals Act 1994 and puts more emphasis on protection of the environment, community development and health and safety. The Act requires an application for a large-scale mining licence be accompanied by: • an EIA licence issued by the EPA and the corresponding EIA and environmental management programme (“EMP”); U3823_Marampa_ESIS_Final.docx September 2012 Page 12 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report • a list of interested and affected parties, including land owners and occupiers of the area, and details of public consultation; and • proposals for the progressive reclamation and rehabilitation of land disturbed by mining (Article 106). The EMP will become legally binding and will be attached to the mining licence. Compliance with the EMP will be included in the terms and conditions of the licence (Article 110). Additional conditions relating to rehabilitation could also be included in the conditions of the licence (Article 136). Specifications for the EIA, EMP and public consultation are given in a part of the Act dedicated to Environmental Protection (Part XV, Sections 131 and 137). Reports on progress in the implementation of the EMP must be submitted to the MMR annually (Article 134). Financial assurance is required to provide for obligations originating from the EIA and EMP (Article 136). There are several other provisions in the Act that were considered during the ESIA process. These are summarised below. • The Act creates an obligation on large-scale mining licence holders to promote community development and it establishes the framework through which companies and communities enter into formal agreements (Part XVI, Articles 138 to 141). Licence holders are obliged to comply with community development agreements (Article 115). • The Act promotes preferential employment of citizens of Sierra Leone, as well as preferential procurement of goods and services from Sierra Leone. Relevant sections of the Act include Articles 106, 163 and 164. An application for a mining lease must be accompanied by proposals to achieve this. Commitments made in these proposals will become legally binding by means the terms and conditions of the mining licence (Article 110). 3 • Land tenure and compensation for disturbance of surface rights are dealt with in Articles 32 to 38 of the Act. Rural land in Sierra Leone is held by landowning families (extended families or lineages) with a chieftaincy structure playing a significant administrative and custodian role. At present, the sale of land is virtually impossible and leasing of land is challenging because property boundaries have not been surveyed, written deeds do not exist and both chiefs and recognised representatives of land owning families have to be involved in decisions on leasing of land (Appendix A). The Act states a holder of a mineral right must obtain written consents from landowners/ occupiers and/or regulatory authorities to use land currently used for other purposes. Compensation must be paid in the event of damage to property and cultivated land. 2.1.3 Other environmental and social permissions A preliminary identification of the environmental and social permissions needed for the Project was undertaken and these are listed in Table 2-2. Additional permissions may be identified during the ongoing Project development process as a result of ongoing consultation with regulatory authorities and as a result of any legal reviews undertaken by MIOL. 3 The term “land tenure” is used here to refer to rights to occupancy and use of a specified area of land. U3823_Marampa_ESIS_Final.docx September 2012 Page 13 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 2.2 International guidelines and standards considered Although not legally binding on the Project, the ESIA team took consideration of a number of international guidelines and standards whilst undertaking the ESIA. These are described below, and further detail is provided in Appendix A. 2.2.1 Equator Principles, IFC requirements and WBG EHS guidelines Development financiers can play a major role in the development and enforcement of sustainable development standards through the conditioning of their loans. A significant number of these institutions have now signed up to the Equator Principles, which provide a framework for the assessment and management of environmental and social risks in a Project by those seeking Project finance. The Principles require observance of the International Finance Corporation Performance Standards on Social and Environmental Sustainability (“IFC PS”) and the Environmental, Health and Safety (“EHS”) Guidelines when developing 4 Projects in non-high income OECD countries. 5 The individual IFC PS 2007 are titled: 1: Social and Environmental Assessment and Management System; 2: Labour and Working Conditions; 3: Pollution Prevention and Abatement; 4: Community Health, Safety and Security; 5: Land Acquisition and Involuntary Resettlement; 6: Biodiversity Conservation and Sustainable Natural Resource Management; 7: Indigenous Peoples; and 8: Cultural Heritage. The EHS Guidelines are technical reference documents with general and industry-specific examples of Good International Industry Practice (“GIIP”), as defined in IFC's Performance Standard 3 on Pollution Prevention and Abatement. 2.2.2 Self-regulation in the mining sector A number of voluntary business charters, codes of conduct/ethics/toolkits and good-practice guidelines have been generated specifically for the mining industry. Those of particular relevance to environmental management and sustainable development are: • International Council on Mining and Metals Sustainable Development Framework - which comprises a set of ten principles, public reporting; and independent assurance; • E3 Plus - a Framework for Responsible Exploration; • the Voluntary Principles on Security and Human Rights; • the Extractive Industry Transparency Initiative; and • the Mining and Metals Sector Sustainable Development Good Practice website. 4 Organization for Economic Cooperation and Development 5 The IFC PS have recently been reviewed and new standards took effect as of 1 January 2012, however as these were not in force at the time most of the ESIA work was undertaken, the old PS were the main reference document for the ESIA process. U3823_Marampa_ESIS_Final.docx September 2012 Page 14 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 2-2: Environmental and social permissions needed for the Project Relevant legislation (and Responsible regulatory Permission corresponding guidelines) authority/ parties to the Main submissions to be made agreement EIA licence • Environment Protection Agency EPA • Screening form - submitted at the screening stage (refer Act, 2008 to Appendix B). • Guidelines on EIA procedures • An ESIS (this document) to obtain an EIA licence. published by MLCPE in July 1999 Mineral right: Large-scale mining licence Mines and Minerals Act 2009 MMR Mining lease application accompanied by: • an EIA licence and corresponding EIA and EMP; • a list of interested and affected parties, including land owners and occupiers of the area, and details of public consultation; and • proposals for rehabilitation of land disturbed by mining; • proposals and a programme for preferential employment and training of citizens of Siena Leone; • proposals with respect to the procurement of goods and services obtainable within Sierra Leone. Written consent to use land Mines and Minerals Act 2009 Consent from the owners Not specified. or occupants of the land. Lease agreements where the holder of a Mines and Minerals Act 2009 Lease agreement Not specified. mineral right requires exclusive use of land. between the holder of the mineral right and the owners or occupiers of the land Written permission to disturb classified/ Forestry Act 1988 The Chief Conservator Not specified. protected forest (Licence for national forest, Forestry Regulations 1989 permission for community forest) Licence for clearing of vegetation to develop Forestry Regulations 1989 An inspector of the Not specified. mine infrastructure Forestry Division Licence for clearing vegetation on the banks Forestry Regulations1989 Division inspector Not specified. of a watercourse (within 1 in 100 year flood line/ about 30 m of a watercourse) Clearance authority for clearing vegetation Forestry Regulations, 1989 The Chief Conservator Not specified. from land designated as sacred bush. Water use licences None (see water legislation in Discharge permits Appendix A) U3823_Marampa_ESIS_Final.docx September 2012 Page 15 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 3 ESIA OBJECTIVES AND PROCESS This chapter describes the objectives of the ESIA (Section 3.1), the study area considered during the ESIA process (Section 3.2), the activities carried out (Section 3.3) and the assumptions and limitations of the study (Section 3.4). 3.1 Objectives The overall objectives of the ESIA process are to: • identify issues and concerns regarding the proposed Project that need to be addressed; • identify national, international and corporate management requirements which the Project must satisfy; • gather and evaluate baseline information to characterise the affected environment and communities; • undertake consultation with stakeholders and promote full disclosure of information and transparency in regard to the Project; • identify, define and evaluate environmental and social impacts so that the potentially significant impacts can be adequately addressed during Project design; • develop a framework management system that sets out key management and monitoring objectives for the life of the mine that can be further developed and implemented by MIOL and any contractors involved; • assess and provide feedback on selected Project alternatives as part of the pre-feasibility and feasibility phases; and • promote environmentally and socially sustainable development. This ESIA has been planned and undertaken with due consideration of the legal, regulatory and policy requirements outlined in Chapter 2. The Third Schedule (Section 26) of the Sierra Leone EPA Act (2008) provides the specification that an EIA should include a description of the following aspects. References to the sections in this report where these requirements are met include: a) the location of the Project and its surroundings (Section 1.1); b) the principle, concept and purpose of the Project (Section 1); c) the direct or indirect effects that the Project is likely to have on the environment (Chapter 7); d) the social, economic and cultural effect that the Project is likely to have on people and society (Chapter 8); e) the communities, interested parties and Government ministries consulted (Section 3.3.5); f) any actions or measures which may avoid, prevent, change, mitigate or remedy the likely effect on people and society (Chapter 11); g) any alternatives to the proposed Project (Section 4.11); h) natural resources in the locality to be used in the Project (Sections 4.6 and 7.2); i) the plans for decommissioning of the Project (Section 4.11); j) such other information as may be necessary for a proper review of the potential environmental impact of the Project (Chapter 3 (description of methodology); report Appendices and Volume 3 Support Documents). U3823_Marampa_ESIS_Final.docx September 2012 Page 16 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report In line with these objectives, the ESIA process supports the priorities of: • the Project proponent – including the Project design team, the future operations management team and shareholders, who wish to develop and operate the Project in accordance with Sierra Leone law and (where possible) international standards; • the responsible government authorities who will decide whether the Project can be approved and what conditions of approval should be applied; and • other stakeholders, particularly local communities, who wish to understand the development proposal and the impacts on their communities and environment. 3.2 Study area The initial ESIA study area consisted of three independent zones representing possible areas of disturbance, and two corridors linking these areas, as outlined below. 2 • Area 1 (29.3 km ) covers the proposed locations of the processing plant, power generators and auxiliary infrastructure, staff village, and tailings storage facility, with the AML rail corridor crossing through the area. 2 2 • Areas 2 (18.8 km ) and 3 (29.6 km ) cover the geological target zones of Matukia and Gafal (and the nearby Rotret and Mafuri resource areas), respectively. The waste rock dumps will be located close to the mining areas within Areas 2 and 3. 2 • Two corridors of 100 m width (approximately 4.6 km ) have been identified for transportation of the ore (via haul roads) from the mining areas in Areas 2 and 3 to the processing infrastructure in Area 1. The study areas used for the purposes of the ESIA are shown on Figure 3.1. The figure indicates that the initial study area was expanded towards the end of the study to incorporate changes in the Project design. The scope of the ESIA is restricted to the mining and processing operations, and specifically excludes third party infrastructure for transportation of the concentrate from the site via rail to the port, and facilities at the port. The upgrade and operation of these rail and port facilities has been undertaken by a third party and are not reliant on the feasibility of this Project, and therefore are not considered to be within the Project’s area of influence. 3.3 ESIA Process The ESIA comprises the integrated assessment of physical, biological and social environments potentially affected by the Project. The ESIA process undertaken for the Project consists of the following four phases: scoping; baseline characterization; impact assessment and reporting; and review and decision-making. The specific objectives and activities of these phases are outlined in Table 3-1 and described in the following sections. Stakeholder consultation is a critical component of the ESIA process and is highlighted in the table, with further information provided in Section 3.3.5. U3823_Marampa_ESIS_Final.docx September 2012 Page 17 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 3.1: Study areas for MIOP ESIA U3823_Marampa_ESIS_Final.docx September 2012 Page 18 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Table 3-1: MIOP ESIA process Phases Main purpose Main activities Documents produced Phase 1: Scoping • Preliminary planning of the ESIA approach and • The ESIA team used a preliminary Project • A stakeholder engagement plan incorporation of the ESIA plans into the overall description from the Project planning team to and stakeholder database programme. determine what specialist studies were likely to • An ESIA scoping report (including • Initial round of issue identification to define be required. the terms of reference for the baseline and specialist investigations required • Scoping-level stakeholder consultation indicated ESIA) to support the ESIA process. what issues were of concern. This was used to • A background information • Desktop social scan to enable the engagement refine the terms of reference for specialist document for stakeholders process to be planned, followed by the first studies. • Records of engagement of round of consultation to share information and stakeholders gather issues of concern that might influence the terms of reference for the ESIA (discussed further in Section 3.3.5). Phase 2: Baseline • Collect background information on the • Baseline specialist investigations • Reports by the specialists investigations environmental and social setting of the Project Phase 3: • Investigate specific issues raised (by • Review of available Project information and • Reports by specialists Impact assessment stakeholders, specialists and the ESIA team). information from the scoping exercise and the • ESIS and report compilation • Define the potential impacts of the Project and baseline investigations. identify measures for the management of the • Discussions with Project engineers to identify impacts. opportunities to eliminate or mitigate impacts • Determine the significance of the potential through modification of the Project. impacts with and without management. • Further specialist investigations of specific • Evaluate the overall acceptability of the Project issues. (from environmental and social perspectives). • Impact assessment exercise. • Report compilation. Phase 4: Development • Develop an environmental and social • Consultation with the Project team to develop a • Framework implementation and of a detailed management system framework for the Project plan that covers: management plan. implementation and to ensure that: • policies, procedures, practices and action plans management plan • the management commitments in the ESIA where necessary; report and the conditions of approval are fully • monitoring and evaluation procedures; implemented; • resource needs (human and financial); • there is ongoing improvement in social and • a management system framework for environment performance throughout the life of implementation of the programme. the Project. U3823_Marampa_ESIS_Final.docx September 2012 Page 19 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 3.3.1 Phase 1: Scoping activities “Scoping” is a term conventionally applied by ESIA practitioners to indicate the beginning or inception phase of an ESIA process. The United Nations Environment Programme (“UNEP”) environmental assessment training programme (June 2002 and April 2007) explains that the main purpose of scoping is to identify: • the important issues to be considered in the ESIA; • the appropriate time and space boundaries of the assessment; • the information necessary for decision-making; and • the potential impacts (significant effects) to be studied in detail. Desktop review and environmental and social scan An environmental and social scan of the study area was carried out in June 2010. The aim of the scan was to update the information collected during the reconnaissance survey (Section 1.4.1) and visit the new geological target areas. The scan involved the following activities: • a review of any new information (prepared since June 2009) and maps of the study area; • discussions with staff at the site relating to exploration activities, status of Project development and community relations; and • general observations of the surrounding biophysical and social environment. Stakeholder engagement Following a period of stakeholder identification and analysis, a stakeholder engagement plan (“SEP”) was developed to guide the stakeholder consultation process. As part of the scoping consultations, a background information document (“BID”) was prepared and distributed among stakeholders to help explain the Project and the ESIA process. Preliminary consultation meetings were held with key Government ministries during July 2010. Scoping consultations with local communities and other key Project stakeholders were undertaken in March 2011. Following these meetings, the Terms of Reference (“ToR”) for the ESIA and specialist studies were reviewed to incorporate stakeholder issues where required. Preliminary hydrological assessment A hydrologist visited the site during June 2010 to undertake a preliminary hydrological and hydrogeological assessment of the study area and to install an on-site meteorological station (for collection of on-site meteorological data for use during the ESIA). The activities carried out during this site visit were: • collection and summary of background data and maps from previous studies; • site walk-over with GPS and compilation of surface and groundwater feature inventory; • identification of surface water monitoring sites and measurement of river flow and basic water chemistry on the Baki, Batabana and Kagbu Rivers at the time of the visit; and • inventory and water-table monitoring of existing boreholes where possible. Issue identification During scoping and continuing through the ESIA process, issues on which attention needed to be focused were identified from the following: • iterative and systematic review of the Project description as it was developed by the Project team to identify Project aspects that could be possible sources of impacts U3823_Marampa_ESIS_Final.docx September 2012 Page 20 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report (“aspects” is a term for the “mechanisms” by which Project activities cause environmental and social impacts); • consideration of the areas of influence; • careful consideration of comments made and concerns raised by stakeholders; and • review of the findings of baseline investigations and specialist investigations. The main aspects that have been identified are listed in Table 3-2. Identified impacts associated with these aspects were grouped under issue headings to keep the analysis of impacts as simple, streamlined and coherent as possible. The issue headings were chosen considering similarities and links between impacts and management measures required to address the impacts. The chosen issue headings are given in Table 3-2. The identified impacts and issues influenced the approach to presentation of information in this ESIS. The information on the Project description (Chapter 4) and environmental and social baseline description (Chapters 5 and 6) has been presented in a manner providing a foundation for the detailed discussion of impacts (Chapters 7, 8 and 9). Identification and analysis of Infrastructure site alternatives As part of the ESIA process the ESIA team undertook an analysis of the proposed Project alternatives for major infrastructure such as the tailings facility and waste rock dump locations. Project infrastructure site alternatives that are of importance from environmental and/or social perspectives are discussed in Section 4.11. Decisions taken on site alternatives, and the factors influencing these decisions, are outlined in the analysis. 3.3.2 Phase 2: Baseline investigations Baseline studies were performed to provide information on the environmental and social setting of the Project, characterize the pre-disturbance environment and provide a baseline against which impacts can be assessed and monitored. A description of the baseline, including the results of these studies, is provided in Chapters 5 and 6. Baseline study scopes of work and more detailed information on the baseline studies is contained in Volume 3 (Support Documents). A list of the specialist studies undertaken for the ESIA is presented in Table 3-3. The baseline studies were managed by SRK (UK) and undertaken by groups of local and international specialists in each respective field. The studies were undertaken in accordance with ToR, a copy of which is included as Support Document 1 of Volume 3, and was provided to SLEPA prior to commencement. Detailed ToR for each specialist study is provided in the baseline study reports, which are provided in Volume 3 (Support Documents 2 to 10) of the ESIS. U3823_Marampa_ESIS_Final.docx September 2012 Page 21 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Table 3-2: Preliminary impacts identified for the Marampa Project Aspect group Aspect Mechanism Potential impacts Land trans- Surface Site clearance within footprint of mine and • Disturbance of sites of archaeological, historic or cultural importance formation disturbance at associated infrastructure • Loss of land available to local communities the mine site; Construction of open pits, waste rock • Disruption of tracks and roads by infrastructure (such as fences, water supply pipeline, Topographic dumps and TSF. haul roads etc.) change at the • Mine infrastructure and activities resulting in visual intrusion and loss of ‘sense of place’ mine site on local communities (open pit • Changes to land capability workings, • Habitat loss or fragmentation and direct loss of plants and animals leading to alteration of waste rock ecosystem services dumps, and • Indirect habitat alteration through colonisation by invasive species tailings storage facilities) Alteration of surface water drainage at the • Changes in availability of water to downstream water users and ecosystems sites of infrastructure • Changes in spatial and temporal patterns of flow, influencing erosion, sedimentation, and flooding, affecting downstream water users and ecosystems Water Water take Abstraction for mine supply • Interference or reduced availability of water to other users and ecological receptors resources Dewatering of workings • Alteration of watercourse flow regimes, resulting in changes to flood patterns, fluvial Water Interruption of or changes to surface water processes, erosion, aquatic habitat, ecosystems and ecosystem services diversion channels to accommodate construction of • Increase in stream turbidity and siltation, affecting aquatic fauna and flora mine infrastructure Discharges Seepage from mine and mineral-processing • Deterioration of groundwater and surface water quality potentially impacting on from point and waste disposal / dirty water holding communities and ecological systems, for example from increased turbidity from sediment diffuse sources facilities; laden runoff, heavy metal leachate from mine facilities and nutrients from blasting or Uncontrolled discharges (such as during sewage treatment etc. storm events, spills, leaks etc.); • Adverse health effects on the health of humans or animals drinking the water Wastewater discharges; Runoff from exposed surfaces (sediment mobilisation, nitrates from blasting); Seepage from potential pit lakes formed at closure Biodiversity Alterations to Contamination of water resources; • Loss of natural habitat for aquatic / wetland species and ecology natural water Abstraction from and changes to flow of • Threat to species of special concern due to loss of habitat courses streams • Effects on community usage of rivers (for harvesting of natural resources) Loss of Clearing for mine infrastructure • Increase in spread of alien invasive species indigenous • Loss of habitat and food sources for indigenous species vegetation • Loss of important resource for local communities U3823_Marampa_ESIS_Final.docx September 2012 Page 22 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Aspect group Aspect Mechanism Potential impacts Soil quality Land • Erosion of topsoil by wind or surface • Reduction in protective vegetation cover Clearance water runoff • Increased potential for soil erosion and sediment mobilisation • Sediment deposition on down-gradient land and in downstream water courses • Increased potential for leaching of soils, increasing iron or zinc concentrations in surface water runoff Construction of • Loss of agricultural land • Loss of currently productive and potentially viable land mine buildings • Soil compaction • Decline in crop production, with subsequent pressure on food supplies to local and related communities facilities • Reduced soil productivity potential Run-off from • Contaminated stormwater runoff from • Degradation of soils within exposed areas and in vicinity of roads and other developed mine facilities exposed surfaces areas • Potential decline in soil chemical quality and productivity potential Air quality Point • Vehicle emissions; • Increase in background concentrations of fine particulate matter (dust) leading to emissions • Stack emissions; nuisance and health effects for nearby communities • Stationary sources (such as • Increase in background concentrations of gaseous pollutants (such as sulfur dioxide, generators, crusher); nitrogen dioxide and carbon dioxide etc.) potentially causing health risks to nearby • Incinerators communities • Increase in national (Sierra Leone) contribution of greenhouse gases to global greenhouse gas concentrations. Diffuse • Fugitive dust emissions from dry • Increase in concentrations of course particulate matter leading to nuisance and health emissions surfaces (such as TSF, waste rock effects for nearby communities dumps, stockpiles and other exposed areas) Noise and Equipment/ • Noise emissions; • Increased disturbance to nearby sensitive receptors (such as local communities, schools vibration vehicle • Vibrations from blasting and equipment etc.) operation /vehicles • Sensory disturbance resulting in animal displacement Blasting Waste Domestic, • Litter; • Waste disposal sites resulting in creation of an attractive nuisance to scavenger animals production construction • Sewage; • Contamination of soil and/or water (wastes other and • Non-process related industrial wastes; • Degradation of land and health risks associated with the above impacts than mine operational • Hazardous wastes (such as waste oils, • Visual and ecological impacts due to uncontrolled dumping of waste waste) wastes chemicals, spent packaging) U3823_Marampa_ESIS_Final.docx September 2012 Page 23 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Aspect group Aspect Mechanism Potential impacts Economic Job creation • Direct employment during construction • Direct or indirect employment of locals contributing to alleviation of widespread development Procurement and operation; unemployment and poverty of services and • Indirect employment by service • Skills acquisition through job training supplies providers and suppliers • Improved infrastructure and services Payment of tax • Tax on profits; • Potential for sustainable economic developments and levies • Duties on imports; • Improved standard of living for local communities through social development initiatives • Payroll tax; • Value added tax Community • Investment in social development investment initiatives Resettlement Land • Physical displacement (relocation of • Involuntary impoverishment – loss of assets, income and livelihood and land acquisition dwellings / villages) • Loss of access to common property resources (such as wells, boreholes, schools, health acquisition within the • Economic displacement (loss of access clinics etc. Project site to land used for agriculture, artisanal • Loss of access to cultural resources such as sacred bush mining, natural resources etc.) • Human rights abuses (related to resistance of displacement) • Psychological impacts on individuals manifesting as apathy, helplessness and a sense of inadequacy • Breakdown of social networks and community cohesion (community disarticulation) • Reduced food security leading to malnutrition and poor health • Civil unrest and instability, particularly between host communities and resettled population • Exacerbation of inequality Social In-migration of • Influx of job seekers to local villages • Increased pressure on government services organisation job-seekers to placing additional pressure on already • Development of informal settlements local villagers limited resources and resulting in social • Increases in social ills (petty crime, alcohol abuse, prostitution, vandalism) ills • Health deterioration resulting from an increased risk of exposure to disease • Increased pressure on natural resources (such as clearance of land for subsistence agriculture) • Increased pressure on natural resources such as wood (for fuel) and fauna (increased bush meat consumption) • Increased cost of living for those not benefiting from the Project Archaeology Loss of cultural • Clearing of land for mine infrastructure, • Lack of understanding or appropriate mitigatory / compensatory action by developers, and cultural heritage items causing loss or disturbance of items / causing dissatisfaction amongst local communities heritage / areas areas of cultural / heritage importance. • Loss of items / areas of heritage importance from communities and society as a whole • Social impacts relating to loss of cultural identity U3823_Marampa_ESIS_Final.docx September 2012 Page 24 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Aspect group Aspect Mechanism Potential impacts Closure Retrenchment • Loss of employment/business; • Unemployment and loss of income / • Outward migration; • Closure of support and service businesses Cease of • Cessation of taxes, fees and royalties • Outward migration of skilled workers, leaving the elderly and the unskilled behind leading operations to government to the eradication of the consumer base • Psychological impacts on individuals manifesting as apathy, helplessness and a sense of inadequacy • Erosion of Governments’ revenue base leading to a reduction in the allocation of funds to the area and subsequently deterioration in quality of life ARDML / • Consumption of contaminated fish, • Health impacts on humans and animals relating to bioaccumulation of heavy metals etc. contamination fauna or forest products in soil and water resources near the mine of water or soil • Consumption or use of water from pits for irrigation or livestock watering U3823_Marampa_ESIS_Final.docx September 2012 Page 25 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Table 3-3: Specialist Studies undertaken during the ESIA Name of study Source Supporting documentation reference Climate and Air quality SRK (South Africa) ESIA Volume 3, SD 2 Noise SRK (Turkey) and Eddie Jewel ESIA Volume 3, SD 3 Acoustics (impact modelling) Ecology and Biodiversity Ecorex Consulting Ecologists ESIA Volume 3, SD 4 and Nepid Consulting Soils and Geomorphology SRK (UK) ESIA Volume 3, SD 5 Geochemistry - Acid Rock Drainage SRK (UK) ESIA Volume 3, SD 6 and Metal Leaching Water Resources SRK (UK), with in-country ESIA Volume 3, SD 7 assistance Archaeology and Cultural Heritage Nexus Heritage ESIA Volume 3, SD 8 Socio-economic SRK (UK), with in-country ESIA Volume 3, SD 9 assistance Natural Resource Use Wild Resources Limited , with ESIA Volume 3, SD 10 in-country assistance The general objectives of these bio-physical and social baseline reports are to: • provide an overview of existing available literature relevant to the biophysical and social characteristics of the area (international, national, regional and local context); • justify the methodology used to undertake the study (sampling, analysis and assessment tools), highlighting any limitations or assumptions; • provide a description of the existing bio-physical and/or social setting (baseline conditions); • provide a statement on the conservation importance of each component of the environment; • identify sensitive natural and human receptors susceptible to impacts arising from possible Project activities; • bench mark the baseline conditions of the Project-affected area against recognised in- country and international guidelines and standards; and • provide recommendations on further studies that may be required and recommendations for management and monitoring of the potentially affected environment should impacts occur. The scope of baseline study requirements were finalised following consultation with SLEPA, and have taken into account the issues or concerns raised by stakeholders and the public during scoping consultations (Section 3.3.5). The baseline study reports will be submitted to SLEPA as part of the ESIS and can be made available by MIOL to other stakeholders upon written request. Where available, Sierra Leone standards and guidelines have been used, supplemented with the most appropriate international guidelines. However, in most cases appropriate local guidelines were not available and the specialists used their professional judgement in selecting the most appropriate international guidelines for their respective studies. In doing so, consideration was given to similarities in environmental conditions between Sierra Leone and the country-specific standard to be adopted (unless the standard is not country-specific, such as standards developed by the World Health Organisation or IFC). U3823_Marampa_ESIS_Final.docx September 2012 Page 26 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Each of the baseline study reports (included in Volume 3 and summarised in Chapters 5 and 6) specified which standards or guidelines were used for that particular study. It is noted that these guidelines are not legally binding but merely intended for reference purposes. Using the baseline conditions measured on site, site-specific criteria for acceptable limits may be devised for the Project if required at a later stage. 3.3.3 Phase 3: Impact identification and definition Starting in the scoping phase and refined throughout the ESIA process, specific aspects of the Project are identified that may give rise to impacts, positive or negative. Impact definition is iterative throughout the ESIA process and generally entails developing a description of the aspect, pathway and receptor that comprise the impact, as outlined below (social impact may require a different approach – discussed further below): • aspect is the mechanism by which Project activities may cause impacts (for example, gaseous emissions to the atmosphere or effluent discharges to a water body); • receptor is a person, natural ecosystem, structure or infrastructure system that experiences the impact; and • pathway is the mechanism by which the aspect affects the receptor (such as inhalation of air or drinking of water). Impacts are defined where there is a plausible pathway between the Project aspects and receptors. The aspects, pathways and receptors are identified based on: • previous environmental or social studies; • review of the evolving Project description to identify aspects; • consideration of the area of influence to determine pathways and receptors; • experience of the ESIA and Project specialists; • consideration of issues raised by stakeholders; and • findings of baseline investigations as they become available. Impact assessment Impact assessment is an iterative process starting with issue identification and impact definition during the scoping phase, as outlined in Section 1.1.1. As the ESIA progresses, the emphasis shifts to impact evaluation, which consists of the systematic evaluation of each of the identified impacts using criteria enabling the significance of the impacts to be determined and the impacts to be ranked accordingly. As part of this process, management measures are defined to reduce the significance of negative impacts or enhance positive ones. After consideration of the management measures, the significance of the resulting (residual) impacts is re-evaluated using the same criteria. The identified management measures form the basis for subsequent development of the Project’s environmental and social management programme. In some cases impact evaluation involves the use of predictive modelling to determine impact significance. The results of these studies are presented in the impact assessment chapters, and more detailed information is contained in the support documents as outlined in Table 3-3. The predictive modelling exercises undertaken include: • air quality; • water resources (both chemical and physical changes); and • noise. U3823_Marampa_ESIS_Final.docx September 2012 Page 27 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Cumulative impacts consider other proposed or anticipated future activities in the vicinity of Lunsar that may have additive or synergistic effects on the impacts of the Project. These include the construction and operation of a mine within ML02/09 (London Mining concession area) and the AML railway line to Pepel Port, which runs through the Project area. Both of these developments began operation in late 2011. Cumulative impacts were considered in the ESIA process and are discussed in Section 10. Impact grouping Different types of impacts are often interrelated and therefore an integrated holistic approach has been taken to impact assessment. For example: different aspects can impact on the same receptor; different impacts can have cumulative impacts on receptors; one impact could result in a sequence of different impacts (a chain of different impact events); and one primary impact could have a diversity of secondary impacts. This interrelationship between impacts can make description and evaluation of impacts complicated and repetitive. For this reason and to facilitate impact evaluation, impacts have been grouped where possible. Generally grouping takes account of similarities in the sources of the impacts, the aspects, the pathways of exposure, the receptors and/or the management measures required to address the impacts. There are no strict rules about how impacts should be grouped and people may group impacts differently. What is important is that grouping facilitates a reader-friendly and structured discussion of impacts. The groupings of impacts are not discrete; there are overlaps between groups of impacts that require cross-referencing. Social impacts may be grouped and evaluated slightly differently, taking cognisance of the points listed below: • social issues are often clustered and interdependent rather than clearly separable; • communities are dynamic and in a continual process of change, with the Project one factor contributing to this change - it is often difficult to identify if an issue is attributable to a Project aspect, to factors beyond the Project’s control or a combination of both; • social issues are not always objectively measurable and often need to be inferred rather than measured - a combination of insight into social processes in general and knowledge of the communities under study are important to draw valid inferences; • social issues are often unavoidable and difficult to manage, and as such management strategies aim to manage change rather than avoid an issue; and • successful management of a potentially negative issue may result in a positive outcome. A section on Community Health and Safety Impacts has been included (Chapter 9) to discuss specific health and safety issues associated with the Project on surrounding communities. These issues include noise, air quality, and the various safety risks (including traffic); specific management measures are provided. Impact description There is a trend away from highly prescriptive approaches to impact evaluation. Most ESIA practitioners recognise that impact evaluation is not a purely objective and quantitative exercise. It has a subjective element; often based on qualitative judgement and values as well as scientific criteria. Consequently, in the impact assessment chapter’s emphasis is placed on describing how impacts have been interpreted so others can understand the rationale of the assessment. U3823_Marampa_ESIS_Final.docx September 2012 Page 28 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Each impact description: • starts with a definition of the impact using an impact statement outlining the aspect- pathway-receptor; • describes the sensitivity, importance or value of the receiving environment or receptors; • explains the extent of change associated with the impact; • rates the significance of the impact; • explains the effectiveness of proposed management measures; and • characterises the level of uncertainty in the impact assessment. The significance of an impact is determined based on the product of the consequence of the impact and the probability of its occurrence. The consequence of an impact, in turn, is a function primarily of three impact characteristics: • magnitude; • spatial scale; and • timeframe. Magnitude is determined from quantitative or qualitative evaluation of a number of criteria discussed further below. Where relevant, this includes consideration of the sensitivity of the receptor, the importance or value of the receptor and the extent of change experienced by the receptor. The sensitivity of existing or reasonably foreseeable future receptors reflects their ability to tolerate disturbance or change. More vulnerable receptors may be less adaptable than the majority of receptors. For example, if a minor disturbance has the potential to result in the permanent loss of the biodiversity of a habitat, the affected environment would be categorised as having a low tolerance to disturbance and is consequently a highly sensitive habitat. In another example, a population with high levels of unemployment is likely to be more sensitive to job creation than an area with low unemployment, meaning that new jobs will have a greater positive magnitude in an area where people need jobs. The importance or value of the receptor can be described using the following indicators: • status of legal protection; • inclusion in local government policy; • level of public concern; • number of receptors affected; • intrinsic or perceived value placed on the receiving environment by stakeholders; and • economic value to stakeholders. Where legally designated protection is not specified, importance or value is likely to be a subjective evaluation based on available information, the opinion of the experts on the ESIA team and consideration of the views of affected stakeholders. The extent of change may be measured qualitatively or quantitatively. One way of measuring change is by comparing to relevant thresholds. Examples of possible thresholds are listed below with the main sources of legal and functional thresholds applied in the ESIA being the host country standards and the World Bank Group EHS Guidelines: • legal thresholds - established by law or regulation and often numeric in nature; • functional thresholds – where if exceeded, the impacts will disrupt the functioning of an ecosystem sufficiently to destroy resources important to the nation or biosphere U3823_Marampa_ESIS_Final.docx September 2012 Page 29 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report irreversibly and/or irretrievably; • normative thresholds - established by social norms, usually at the local or regional level and often tied to social or economic concerns; • preference thresholds - preferences for individuals, groups or organizations only, as distinct from society at large; and • reputational thresholds – the level of risk a company is willing to take when approaching or exceeding the above thresholds. Spatial scale is another impact characteristic affecting impact consequence. The spatial scale of impacts can range from localized (confined to the proposed Project site) to extensive (national or international extent). They also may vary depending on the component being considered. Different scales have been used for the bio-physical impacts and the socio- economic impacts. The impact timeframe is the third principal impact characteristic defining impact consequence and relates to either its duration or its frequency (when the impact is intermittent). Impact duration can range from relatively short (less than four years) to long (beyond the life of the Project). Frequency ranges from high (more than 10 times a year) to low (less than once a year). These timeframes will need to be established for each Project based on its specific characteristics and those of the surrounding environment. Additional characteristics, including reversibility, sustainability and timing (onset) of the impact, can also play a role in consequence determination of some types of impact. As appropriate, these additional characteristics are considered and described alongside the three primary characteristics of magnitude, spatial scale and duration. Once the impact consequence is described on the basis of the above impact characteristics, the probability of impact occurrence is factored in to derive the overall impact significance. The probability relates to the likelihood of the impact occurring, not the probability that the source of the impact occurs. For example, a continuous Project aspect (such as generation of dust) may result in an unlikely probability of impact if there are no receptors within the area influenced by that activity. The resulting significance rating may be further qualified by explaining the effectiveness of proposed management measures designed to mitigate or enhance the impact, and by characterizing the level of confidence or uncertainty in the assessment. The characteristics used for the written impact descriptions are outlined in Table 3-4. The next section outlines the specific process used in this ESIA for impact significance rating. U3823_Marampa_ESIS_Final.docx September 2012 Page 30 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Table 3-4: Characteristics used to describe an impact Characteristics Sub-components Terms used to describe the impact Type • Positive (a benefit), negative (a cost) or neutral Nature • Biophysical, social, cultural, health or economic • Direct, indirect or cumulative Phase of Project • Construction, operation, decommissioning or post closure • High, medium or low capacity to accommodate change Sensitivity of receptor • High, medium or low conservation importance • Vulnerable or threatened • Rare, common, unique, endemic • High, medium or low concern to some or all stakeholders • High, medium or low value to some or all stakeholders Magnitude Importance or value of receptor (for example, for cultural beliefs) • Locally, nationally or internationally important • Protected by legislation or policy • Gravity or seriousness of the change to the environment Severity or degree of change to the • Intensity, influence, power or strength of the change receptor • Never, occasionally or always exceeds relevant thresholds Area affected by impact - • Area or volume covered Spatial scale boundaries at local and regional • Distribution extents will be different for • Local, regional, transboundary or global biophysical and social impacts. • Short term or long term Length of time over which an • Intermittent (what frequency) or continuous environmental impact occurs or • Temporary or permanent Timeframe frequency of impact when • Immediate effect (impact experienced immediately after intermittent causative Project aspect) or delayed effect (effect of the impact is delayed for a period following the causative Project aspect) • Definite (impact will occur with high likelihood of probability) Probability - likelihood or chance an impact will occur • Possible (impact may occur but could be influenced by either natural or Project related factors) • Unlikely (impact unlikely unless specific natural or Project related circumstances occur) • Potential for recovery of the endpoint from the impact Reversibility / sustainability • Reversible or irreversible • Sustainable beyond the Project’s life Effectiveness of management measures (will • Indication of what could occur in the absence of management measures reduce impact to an management measures acceptable level) • Effectiveness of proposed measures • Scientific uncertainty – limited understanding of ecosystem (or community) and processes governing change • Data uncertainty – restrictions introduced by incomplete Confidence in impact evaluation (degree of or incomparable information, or by insufficient certainty in the significance ascribed to the impact) measurement techniques • Policy uncertainty – unclear or disputed objectives, standards or guidelines • Personal opinion – some impact may be perceived different by different people Impact significance rating The impact significance rating process serves two purposes: firstly, it helps to highlight the critical impacts requiring consideration in decision making processes (such as engineering planning decisions, government approval of the Project, the feasibility decision and Project finance approvals); secondly, it serves to show the primary impact characteristics, as defined above, used to evaluate impact significance. The impact rating system used in the ESIA was selected because it: U3823_Marampa_ESIS_Final.docx September 2012 Page 31 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report • is simple and does not detract from the written description of potential impacts; • is easy for stakeholders to understand; and • is useful in helping to distinguish impacts needing to be brought to the attention of decision makers. Impact assessment matrices can become complex if too many categories are used or if specific criteria are developed for each environmental component or Project activity. The rating system used here is a simple 3x3 matrix and is standardised across all environmental components and activities. It relies on the clear description of the impact given in the text to show the reader how the final significance rating has been arrived at. It is recognised that this simple approach may limit the evaluation of some impacts associated with a specific environmental component or activity. Therefore under certain circumstances the ESIA practitioner may choose to modify the criteria used in the matrix table for that specific evaluation; any such modifications are clearly explained in the text. The impact significance rating system is presented in Table 3-5 and involves three parts as outlined below. • Part A: Define impact consequence using the three primary impact characteristics of magnitude, spatial scale and duration. When assessing the magnitude, it is not necessary that all definitions given by the table agree with the assessment chosen. The justification for the assessment should be clearly explained in the impact discussion. In the case of negative impacts, the most conservative definition should generally be used – in other words, if any of the definitions fall under the major category then the overall magnitude is major. For positive impacts, a balance should be sought with the rating reflecting the most likely definition that applies. • Part B: Use the matrix to determine a rating for impact consequence based on the definitions identified in Part A; and • Part C: Use the matrix to determine the impact significance rating, which is a function of the impact consequence rating (from Part B) and the probability of occurrence. U3823_Marampa_ESIS_Final.docx September 2012 Page 32 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Table 3-5: Method for rating the significance of impacts PART A: DEFINING CONSEQUENCE IN TERMS OF MAGNITUDE, DURATION AND SPATIAL SCALE Use these definitions to define the consequence in Part B Definition Criteria Negative Positive • Large number of receptors affected • Large number of receptors • Receptors highly sensitive and/or are affected of conservation importance • Receptors highly amenable to • Substantial deterioration, nuisance or positive change Major harm to receptors expected • Receptors likely to experience a • Relevant thresholds often exceeded big improvement in their • Significant public concern expressed situation during stakeholder consultation • Relevant positive thresholds • Receiving environment has an often exceeded inherent value to stakeholders • Some receptors affected • Receptors slightly sensitive and/or of moderate conservation importance • Some receptors affected • Measurable deterioration, nuisance • Receptors likely to experience MAGNITUDE or harm to receptors some improvement in their Moderate • Relevant thresholds occasionally situation exceeded • Relevant positive thresholds • Limited public concern expressed occasionally exceeded during stakeholder consultation • Limited value attached to the environment • No or limited receptors within the • No or limited receptors affected zone of impact • Receptors not sensitive to • Receptors not sensitive to change change • Minor deterioration, nuisance or harm • Minor or no improvement in Minor to receptors current situation • Change not measurable or relevant • Change not measurable thresholds never exceeded • Relevant positive thresholds • Stakeholders have not expressed never exceeded concerns regarding the receiving • No stakeholder comment environment expected Duration of continuous aspects Frequency of intermittent aspects TIMEFRAME Short term/ Less than 4 years from onset of impact Occurs less than once a year (determine low frequency specific to Medium term/ More than 4 years from onset of impact up to Occurs less than 10 times a year but each Project) frequency end of life of Project (approximately 15 years) more than once a year Long term/ Impact is experienced during and beyond the Occurs more than 10 times a year high frequency life of the Project (greater than 15 years) Biophysical Socio-economic SPATIAL Small Within 200 m of the Project footprint area Within the chiefdom in which the activity SCALE occurs (determine Intermediate Within the district in which the facilities are Within the province in which the activity specific to located occurs each Project) Beyond the district in which the facilities are Beyond the province in which the activity Extensive located occurs (national / international) U3823_Marampa_ESIS_Final.docx September 2012 Page 33 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report PART B: DETERMINING CONSEQUENCE RATING Rate consequence based on definition of magnitude, spatial extent and duration SPATIAL SCALE MAGNITUDE TIMEFRAME Small Inter- Extensive mediate Short term / low frequency Low Low Medium Minor Medium term / frequency Low Low Medium Long term / high frequency Medium Medium Medium Short term / low frequency Low Medium Medium Moderate Medium term / frequency Medium Medium High Long term / high frequency Medium High High Short term / low frequency Medium Medium High Major Medium term / frequency Medium Medium High Long term / high frequency High High High PART C: DETERMINING SIGNIFICANCE RATING Rate significance based on consequence and probability CONSEQUENCE Low Medium High PROBABILITY Definite Low Medium High (of exposure to Possible Low Medium High impacts) Unlikely Low Low Medium + denotes a positive impact. Using the matrix, the significance of each described impact is initially rated. This initial rating assumes the management measures inherent in the Project design and described in the Project description (Chapter 4) are in place. For example, if a fuel store has been designed with secondary containment, the initial impact rating takes this into account. For most impacts an impact summary table is given to present the rating results, as shown in the example below. The heading row of the table gives the impact definition (see above). The following rows present the impact characteristics and significance ratings. The final row presents any additional management measures identified by the impact assessor as required to appropriately control/enhance the impacts. These would be over and above the inherent management measures incorporated into the Project design. Included in the summary table is a confidence assessment, which provides the reader with an indication of the assurance level placed on the rating process and addresses the concept of uncertainty. A statement is also given on whether the impact is reversible or sustainable. The management measures given in the table will take the form of either: mitigation measures (those measures needed to reduce the significance of negative impacts to an acceptable level); or enhancement measures (those measures needed to optimise the effects of positive impacts). Where such measures are stipulated, the final table row provides the rating for the ‘residual impact’ (negative impacts) or ‘enhanced impact’ (positive impacts), which assumes these measures are successfully implemented and reflects the actual impact expected from the Project. Where no residual impact is given the actual impact of the Project is the initial impact. U3823_Marampa_ESIS_Final.docx September 2012 Page 34 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Table 3-6: Example of impact significance rating summary table Impact X: Example impact statement (aspect, pathway and receptor) Impact characteristics Initial impact Residual or optimised impact (taking cognisance of management measures) Type (+ / - /neutral) Sensitivity Receptor importance Magnitude or value description Extent of change / threshold compliance Magnitude rating Duration Timeframe Frequency description Timeframe rating Scale CONSEQUENCE RATING PROBABILITY RATING SIGNIFICANCE RATING Reversibility/sustainablity Confidence Management measures • Measure 1 • Measure 2 etc. The strategy for selecting practical mitigation measures is as follows: • avoid the impact wherever possible by removing the cause(s) – always preferred; • reduce the impact as far as possible by limiting the cause(s) – preferred where impacts cannot be avoided; • ameliorate the impact by protecting the receptor from the cause(s) of the impact – only where the causes of the impact cannot be reduced; and • providing compensatory measures to offset the impact – this is used only when none of the above are appropriate and is often used when impacts to biodiversity resources cannot be mitigated. All relevant management measures (inherent design measures, mitigation measures, enhancement measures and good practice measures) are eventually consolidated into the environmental and social management programme, which forms a fundamental part of the environmental and social management system described in Chapter 11 and which may become legally binding. 3.3.4 Phase 4: ESIA report review and decision-making The purpose of this ESIA report is to present the information from the ESIA process that is available and relevant in an integrated and holistic manner. It aims to provide the big picture in as non-technical a manner as far as possible. Technical detail is provided in the various supporting documentation such as the specialists baseline and impact assessment studies, which are provided as the supporting documentation in Volume 3 of the ESIA report. The ESIA will be submitted to the relevant regulatory authorities for review and consideration. The review will inform the government’s decision and enable it to set the conditions of U3823_Marampa_ESIS_Final.docx September 2012 Page 35 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report approval. The ESIA report will also be made available for public review and there will be feedback consultations with stakeholders. The feedback consultations will inform stakeholders about progress with Project planning, expected impacts and proposed mitigation measures. The consultations will acknowledge issues raised by stakeholders and tell them how these are to be addressed, and they will provide stakeholders with an opportunity to comment on the Project and proposed mitigation measures. Stakeholders that have shown an interest in the ESIA will be involved in the feedback consultations. Records of the feedback consultations will be provided to regulatory authorities for consideration in the Project approval decision. The feedback consultations will not be replaced by any government public hearing that are prescribed because they are important to the long-term constructive relationship between the Project and stakeholders, but it is possible that the government may be amenable to replacing/ integrating public hearings with the feedback consultations. 3.3.5 Stakeholder consultation The purpose of stakeholder consultation during the ESIA process is to enable the views, interests and concerns of Project stakeholders, including vulnerable or disadvantaged groups, to be taken into account. The objectives and activities of the stakeholder consultation, and how these link to the ESIA process, are shown schematically in Figure 3.2. Approach During the Scoping phase, and following a process of stakeholder identification and analysis, an initial SEP was developed to guide the initial and ongoing stakeholder consultation process. As part of the scoping consultations, a BID was prepared and distributed among stakeholders to help explain the proposed Project and the ESIA process. Details on the ESIA stakeholder consultation are presented in the SEP. The SEP is a live document, which has been updated throughout the ESIA process and will continue to evolve as the Project proceeds through the construction, operation and decommissioning phases. The purpose of the SEP to date was to guide and record public consultation and disclosure activities during the ESIA process. The SEP to guide the stakeholder engagement process through the construction phase and the rest of the life of the Project has been presented as part of the ESMS. Summary of ESIA stakeholder consultation Initial stakeholder consultations focused on formally initiating the ESIA process with SLEPA and identifying specific regulatory requirements of relevant Government ministries. The meetings were held on a one to one basis in the relevant Government ministry office. A BID outlining the status of the Project was provided to ministry representatives, who were given the opportunity to raise issues associated with the Project and were encouraged to contact MIOL if queries arose. Minutes of these meetings are included as Appendix 2 to the SEP (Appendix C). Following these meetings, a screening form was completed and submitted to SLEPA in line with the national Environmental Impact Assessment (EIA) process (Section 2.1). SLEPA categorised the Project as Category A, thus requiring an Environmental and Social Impact Assessment (ESIA) for the Project (refer to Appendix B for correspondence from SLEPA dated 20th August 2010). U3823_Marampa_ESIS_Final.docx September 2012 Page 36 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Figure 3.2: Overview of the stakeholder engagement process undertaken U3823_Marampa_ESIS_Final.docx September 2012 Page 37 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report An interim consultation meeting to discuss the ToR for the baseline studies and other issues was held SLEPA in February 2011. Stakeholder consultation meetings for the scoping phase of the ESIA were held with local communities, NGO’s and authorities in March 2011, and any additional issues raised that had not already been included in the ToR for the baseline studies were included at that stage. A list of the stakeholders who were engaged during the ESIA process is appended to the SEP. The stakeholders include: • local communities; • national, provincial and local government and authorities; • community based organisations (“CBOs”) and NGOs; and • others, such as private sector, academia and the media. Issues raised by stakeholders during the ESIA process have been recorded in a database, along with a response indicating how these issues have been addressed through the ESIA process, and are summarised in Table 3-7. A summary of the issues and responses to each issue is included as an Issues Report in Appendix C. The Issues Report details the issues raised; identifies people who raised them and their affiliations; and shows how the issues have been addressed in the ESIA by means of comments and/or cross referencing to relevant sections of the ESIA report. A final round of stakeholder consultations for the ESIA process will be held on submission of the draft ESIA report to SLEPA, following which any additional issues raised will be addressed in the final ESIA report submitted to SLEPA for approval. A full record of the stakeholder consultation process to date is presented in the SEP. The current version of the SEP is presented in Appendix C and this will be updated following feedback consultation with stakeholders. Table 3-7: High-level summary of stakeholder issues raised and where addressed in the ESIS Subcategory Issue raised Addressed in ESIA report Community health and Dust and noise impacts on local communities Section 9.1 and 9.2 safety Safe use of explosives Section 9.5.1 Traffic safety Section 9.3 Land transformation Loss of agricultural land and insufficient Section 7.1 rehabilitation Visual impacts Section 7.1 Ecological Use of appropriate vegetation for Section 7.3 rehabilitation Water resources Added pressure on limited water resources Section 7.2 Economic Requirement for tangible community Section 8.1 development development Employment for local communities (and Section 8.1 attracting workers from farms and schools) Social organisation Conflict within and between communities Section 8.3 Resettlement and land Compensation for land Section 8.2 acquisition Correct implementation of resettlement Section 8.2 Management Implementation and monitoring of Chapter 11 measures management measures U3823_Marampa_ESIS_Final.docx September 2012 Page 38 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report 3.4 Assumptions and limitations The ESS was initiated early in the Project planning process and as such limited Project information was available at that stage. In the absence of a provisional Project layout, a general study area was defined indicating zones within which disturbance was considered likely. By the time most of the baseline studies were complete, the Project description had been refined and new study areas were delineated (Figure 3.1), which were slightly larger than the original study areas. As additional Project information became available, the focus areas for subsequent field trips supporting the ESIA process were amended accordingly and in consultation with the Project team. The initial baseline field work areas were however defined based on the original (slightly reduced) study area compared to the revised Project study areas, which show expansion mainly in Areas 1 and 2. This does not represent a fatal flaw for the baseline as the areas involved are similar. However this has meant that baseline information used in the impact assessment has been extrapolated over a wider and marginally different area. Stakeholder consultations with local communities and the general public were delayed until March 2011, which represented a limitation for the scoping process, as not all stakeholder issues were available prior to initiating the baseline studies. However, this did not preclude stakeholder issues from being considered in these studies as soon as they were available. SRK can confirm no critical new issues were identified and the minor issues were appropriately addressed by the ongoing baseline studies before completion. Therefore the delay in consultations is not considered to be critical to the ESIA nor the stakeholder engagement process as a whole, nor to have resulted in issues not being suitably addressed. The scope of the ESIA is restricted to the potential mining and processing operations around Lunsar and specifically excludes construction of the rail transportation of the concentrate from the site to the port, and facilities at the port. As a third party is responsible for these facilities, the rail line and ports are not considered to be within the Project’s area of influence. It does however include product transport pipelines, running from the ore processing area on site to Tagrin Port, along an existing rail corridor that is also operated by a third party. The Project is currently at a pre-feasibility study and thus some details of the design may change as the Project moves into the feasibility and detailed design phase. At this stage no significant changes are expected, however should changes to the Project description occur that materially affect the outcome of this impact assessment report, an addendum would be prepared. U3823_Marampa_ESIS_Final.docx September 2012 Page 39 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report 4 PROJECT DESCRIPTION This Chapter provides a preliminary description of the major Project components based on 2 the Project design. The exploration licence area (EL46/2011) covers 305.12 km in total. The development area of the Project’s footprint (and hence the study area for this ESIA) is 52.3 2 km . Further detail of the preliminary design is provided in Appendix E. The ultimate Project involves the construction of facilities and infrastructure to produce up to 6 15 Mtpa of iron concentrate. This will be done in two stages. Stage 1 will involve the construction of facilities to produce 2.5 Mtpa of iron concentrate through the mining of oxide ore only. Stage 2 (an extension to Stage 1) involves expanding these facilities, and the construction of additional facilities, to enable the production of a total of up to 15 Mtpa of iron concentrate through the mining of oxide and/or fresh ore. While the development plan of Stage 2 of the Project is reasonably known at this time, it will be the subject of a detailed feasibility study moving forward. Where possible this ESIA will describe (and assess impacts relating to) the full proposed development, i.e. production of up to 15 Mtpa of concentrate (Stage 2), clearly stating where detail relates specifically to Stage 1. Changes and additional components (such as for product export) to the Stage 2 development proposal resulting from the outcomes of the detailed feasibility study (and therefore not described or assessed in this ESIA) will however be covered by a future amendment to the ESIA. Potential future expansion plans are discussed further in Section 4.13. The existing railway between Marampa and the Pepel Port facilities has been refurbished and placed back in to operation by AML to service their Tonkolili Mine. An access agreement is in place with AML, allowing MIOL to export 1.8 Mtpa (potentially increasing to 3.4 Mtpa) of concentrate through the rail and Pepel port facilities for its Stage 1 development. An environmental authorisation has been obtained for these as part of AML’s Project, and they are therefore not included in this ESIA. Product export will involve pumping concentrate via pipelines to the port of Tagrin and will be covered in the amendment to this ESIA. The main Project components included in this ESIA are listed below: • Four open pits (Matukia, Gafal, Rotret and Mafuri) and four associated waste rock dumps (“WRD”) • Run of mine (“ROM”) and low grade stockpiles • Beneficiation plant, comprising: - crushing; - stockpiling; - ore reclamation; - scrubbing / grinding; - rougher / scavenger magnetic separation; - rougher / scavenger concentrate regrind; - cleaner and recleaner magnetic separation; - concentrate thickening and filtration; - tailings thickening; - reagent storage and use; and 6 It should be noted that references to concentrate production rates refer to dry metric tonnes. The moisture content of the product may range between 8-10%, which will increase the actual tonnage of concentrate produced, transported and exported accordingly (wet metric tonnes). U3823_Marampa_ESIS_Final.docx September 2012 Page 40 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report - supporting utilities. • Tailings storage facility (“TSF”) • Power generation and distribution facilities • Water supply facilities • Stormwater management facilities • Waste water management systems • Communications systems • Accommodation • Medical and emergency services • Utilities (potable water supply, fire water system, air compressor systems) • Mobile equipment (vehicles etc.) • Buildings for storage, offices, workshop, laboratory, etc. • A rail spur and head, connecting to the existing Pepel railway line • Use of existing road routes for transport of supplies to the mine (including the existing Makeni Highway, connecting Freetown to Lunsar) and some new on-site roads to connect Project infrastructure The design, construction, operation and closure of the Project components are described in the following sub-sections. For some components, such as power and water supply, alternative options and their social or environmental implications were evaluated. These are described together with the decision-making rationale. Where relevant, inherent design measures to protect the bio-physical or social environmental have been highlighted; these measures are assumed to be in place when evaluating the initial Project impacts in Chapters 7, 8 and 9. 4.1 Construction The facilities at the mine site for Stage 1 will be constructed over an 18 month period. Once Stage 1 is in operation construction of Stage 2 will commence, and will continue for a further 18 to 24 months. The total construction period for the Project will therefore be approximately 3 to 3½ years. This section outlines the activities occurring during or just prior to construction, which may impact upon the bio-physical or social environment. 4.1.1 Land acquisition and resettlement The resettlement and compensation process will be undertaken in adherence with the legislative requirements in Sierra Leone and the international guidelines. The objective will be to ensure that the standard of living and livelihoods of Project affected people (“PAPs”) are either improved, or at least restored to pre-resettlement levels. The approach to the resettlement process will involve establishment of a Resettlement Working Group (“RWG”) to facilitate the consultation process and negotiations and establishment of a Grievance Committee. The planning phase of the resettlement process will include a census and assets survey to provide the baseline profile of each affected household, and a valuation survey to establish the market value and cost of production for the main local crops and buildings. Following this, an entitlement framework for the PAPs will be prepared and signed off by the RWG and relevant government agencies. Once agreed with the PAPs, a moratorium will be declared that restricts the construction of new buildings/structures in the Project displacement areas. The implementation phase of U3823_Marampa_ESIS_Final.docx September 2012 Page 41 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report resettlement will include the following activities: • Construction of resettlement sites in preparation for physical relocation of PAPs; • Initiation of income restoration and sustainable development initiatives to restore or improve the standard of living of PAPs; and • Concurrent monitoring and evaluation to determine the standard of living of PAPs relative to pre-resettlement levels. 4.1.2 Construction camp and laydown area During the construction phase, contractors will provide temporary facilities to house construction personnel. It is expected that this will be separate from MIOL’s accommodation camp. The location of this camp has not yet been determined. The decision regarding a location will be driven by Project requirements (proximity to construction sites) but will take cognisance of the local communities in the area. The camp will be powered from diesel generators, water will come from the mine site’s potable water system (though a temporary treatment system may be required until such time as the full system is in place) and waste disposal will be via suitable package sewage treatment works with a discharge of treated effluent to a soakaway or evaporation basin. A fenced and secured construction laydown area will be built in proximity to the camp or construction site to store construction materials. This will mainly comprise a compacted earth base, however if hazardous material (for example fuels, oils, lubricants, paints etc.) storage is required this will be within suitable constructed containment facilities (with impermeable bases and roofs as required). 4.1.3 Land clearance and infrastructure development Initial construction activities include land clearance, site grading for temporary material laydown areas, permanent structure foundations, roadway development and storm water management ponds. This will be followed by construction of the infrastructure. In addition to infrastructure footprint areas and mine pre-stripping, land will be cleared to provide access to borrow pits. At this stage the location of the borrow pits is not known but wherever possible these will be located within the footprints of areas to be disturbed. Construction equipment will include rock crushers, concrete mixer trucks, concrete pumper trucks, mobile cranes, container handler, forklifts, excavators, loaders, dozers, graders, water trucks, and pick-up trucks. Most construction activities take place within the Project component footprints but some existing (non-Project) linear infrastructure will be affected during construction as listed below. In these cases, MIOL will interact with the operator of the relevant infrastructure to minimise disturbance during the construction period. • The haul roads between the pits and the beneficiation plant cross the national road to Freetown. At these locations the haul road will be constructed in a culvert under the national road. • The pipeline from the beneficiation plant to the TSF crosses the existing rail way line. This will also be constructed in a culvert under the railway line. • The new MIOL rail spur will need to link into the existing rail line to Pepel port. U3823_Marampa_ESIS_Final.docx September 2012 Page 42 of 244 SRK Consulting (UK) Ltd Figure 4.1: Overall site layout plan for the Project, with additional detail on the beneficiation plant and road crossing U3823_Marampa_ESIS_Final.docx Page 43 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report 4.1.4 Construction management The construction activities will be managed by an Engineering, Procurement and Construction Management (“EPCM”) contractor. The EPCM contractor will be managed by a small team of owner’s construction personnel. The EPCM contractor will select and recommend main contracting companies for the various stages of the work including earthworks, concrete works, structural works, mechanical and piping works, electrical works and building works. Due to the specialised nature and extent of the construction works, it is expected that the main contracting companies will be sourced from outside of Sierra Leone. It will be a requirement of the contracts, however, that the main contractors employ, or sub-contract to, Sierra Leoneans where possible. It is expected that the construction labour force will peak at around 600 – 700 personnel, of which 30 – 70% could be locally sourced unskilled labour, depending on the type of construction work being conducted at the time (e.g. concrete works, earthworks, mechanical and electrical installations). Due to the specialist nature of the construction works, it is expected that the majority of the skilled workforce will come from outside of Sierra Leone. The Company will implement a policy, however, where-in the use of Sierra Leonean labour is maximised where-ever possible, with training provided to maximise opportunities for such staff to transfer to operational roles. 4.2 Mine site operation 4.2.1 Preliminary pit design Four open pits have been designed to access ore bodies; Rotret Pit, Matukia Pit, Mafuri Pit and Gafal Pit. The main ore type at each location is a specular hematite schist, with minor amounts of magnetite and goethite. The Stage 1 development is based on the mining of shallow oxide ore, to produce nominally 2.5 Mtpa of concentrate. The Stage 2 development will continue with mining of any remaining oxide ore and mine fresh ore to produce up to 15 Mtpa of concentrate. Provisional pit dimensions and ore and waste recovery volumes are presented in Table 4-1. The total mine life is approximately fourteen years. Table 4-1: Preliminary Ore/Waste Volumes per Pit Deposit Ultimate Pit Ultimate Pit Pit Area Ore (kt) Waste (kt) Total (kt) Length (m) Width (m) (ha)** Gafal 2,200 800 150 151,541 181,721 333,263 Mafuri 2,700 800 200 177,933 199,904 377,838 Matukia 1,600 800 125 128,392 185,201 313,592 Rotret 1,500 500 75 55,246 45,366 100,612 Total 550 513,112 612,192 1,125,305 ** Approximate area of disturbance in hectares Average pit slopes will be 30 degrees, and slope heights vary between 20 and 55 m. The oxide ore will be mined from within 40-50m of the natural ground level with the ultimate pit shells expected to extend to depths varying from 150- 280 metres below ground level (“mbgl”), and crest elevations of 70 to 90 mRL (reduced level in meters with respect to mean sea level).. The average mine life for each pit is approximately ten to thirteen years, with the exception of Rotret, which has an expected mine life of six to seven years. U3823_Marampa_ESIS_Final.docx September 2012 Page 44 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report The pits will be bunded to prevent surface water inflow. Runoff from the area surrounding the pits will be diverted to stormwater settlement ponds (located close to each pit). 4.2.2 Preliminary production schedule The provisional mining schedule is presented in Table 4-2. Mineral extraction is due to commence within 18 months with mining rates varying from 8-12 Mtpa. Total movements will increase from 12 to 66 Mtpa during Stage 1 and up to 110 Mtpa during Stage 2 (due to commence 18 months after the start of Stage 1), as production increases and deeper pit stages are developed. The four pits will be mined in sequence to prioritise recovery of oxide ore for staged processing and open up areas of ore for the expanded Stage 2 circuit. Cross sections showing the interpretive geology for each pit (showing the oxide and fresh ore proportions) are provided in Figure 4.2 to Figure 4.5. Figure 4.2: Mafuri prospect interpretive geology U3823_Marampa_ESIS_Final.docx September 2012 Page 45 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Figure 4.3: Rotret prospect interpretive geology U3823_Marampa_ESIS_Final.docx September 2012 Page 46 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Figure 4.4: Gafal prospect interpretive geology U3823_Marampa_ESIS_Final.docx September 2012 Page 47 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Figure 4.5: Matukia Prospect Interpretive Geology U3823_Marampa_ESIS_Final.docx September 2012 Page 48 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Table 4-2: Indicative production schedule U3823_Marampa_ESIS_Final.docx September 2012 Page 49 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report The development sequences for the deposits, over the full Project development, can be summarised as follows: • Rotret pit development in four pit phases: o Oxide pit development in two phases, southern part first; o Deeper pit development in two pit phases, southern part first. • Mafuri pit development in six pit phases: o Oxide pit development in two pit phases, first the wider area at west and then along strike to east; o Deeper pit development in four pit phases, first the wider area at the west, then the two pit phases along strike to east and final southern wall cutback along strike. • Gafal pit development in six pit phases: o Oxide pit development in three pit phases from west to east (Gafal South last); o Deeper pit development in three pit phases from west to east (Gafal South last). • Matukia pit development in three pit phases: o Oxide pit development as a single phase; o Deeper pit development in two pit phases along strike, first stage located centrally and second phase cutting final walls along strike. Once the Rotret Pit and the third phase of the Mafuri Pit are complete, they will be backfilled with waste rock from further expansion of the Gafal Pit and an extension of the Mafuri Pit to 3 the south-east. The Matukia Pit will be used to store 120 Mm of tailings towards the end of the mine life. Surface water management Major drainage diversion works are required prior to and during the development of the Mafuri oxide pit and Mafuri expansion towards Gafal open pit, as the eventual pit is likely to totally cut across the Gafal stream. The proposed sequence of mining and backfilling of pits (filling approximately 50% of the pit areas with waste and tailings material, reducing the area required for the WRD) listed below will determine the timing for the various components of the drainage diversion works required. • Development of the western part of the Mafuri pit first, making it available for waste backfilling (from the development of eastern pit areas) after year 5; • Completion of Matukia pit by year 9, making it available for tailings storage for the rest of mine life; • Completion of Rotret pit by year 10, making it available for waste backfilling from the later pit phases in the Gafal West and Mafuri East areas; and • Completion of the Mafuri eastern and Gafal western pit boundaries (adjoining) last to delay the Mafuri East stream diversion towards the end of mine life. There are no major drainage routes crossing through the Gafal and Rotret open pits as they are located mostly at higher ground. Significant flows are not expected through the two streams crossing the Matukia pit as the catchment areas feeding these streams are small. Major drainage works are however required for the development of Mafuri pit in phases, preliminary plans for which are summarised below and depicted in Figure 4.6 to Figure 4.8. U3823_Marampa_ESIS_Final.docx September 2012 Page 50 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Further detail on the water management plan for the mine will be developed during feasibility studies. • A drainage channel (5 m width) will be required to divert the Mafuri West stream before the start of mining Mafuri oxide pits (year 2). With the exception of a 200 m section cutting through a hill, the drainage channel to the west of the pit boundary will be generally shallow. Some sections of the channel will require bunding to divert the water from the pit. The material excavated for construction of the channel (50 000 bcm) will be used to construct this bund. • Excavation of a major drainage channel (maximum depth 10-12 m and length 600 m) at the north of the Mafuri pit to divert the water from the Mafuri East stream before the development of last phases of Mafuri and Gafal pits (~ year 8). • As the channel excavation at the north of Mafuri is completed, mining and waste backfilling of the Mafuri pit in the central area will be finalised to allow diverted water to cross the Mafuri pit. Suitable materials and construction methods will be used to seal the channel over the waste backfill. • After the construction of the channels listed above (~year 8), the water flow in the main Mafuri West stream will be diverted by means of a bund. This will cause damming to approximately 3-4m depth in the lower catchment as the water level rises and flows through the newly excavated channel further north. The expected layout at the end of Stage 2 mining is shown in Figure 4.8. 4.2.3 Mining operations Conventional open pit mining methods including drilling, blasting, loading and hauling will be used. Ore will be transported from the pits via haul truck and taken directly to the beneficiation plant area, located approximately 6 km from the pits. Mining will be conducted on a 24 hour basis, with three crews working two 12 hour shifts. The waste to ore strip ratio is expected to be 1.2 over the life of mine and approximately 0.4 when mining the oxide material (Stage 1). Where possible, waste material mined will be used for the construction of access and haul roads, as well as for construction of the embankment for the tailings storage facility. Haul roads will generally be constructed to a width of 18 m. Underpasses will be required at the Makeni Highway in two locations, one to the west of Lunsar and the other to the east of Lunsar (see locations on Figure 4.1). The haul roads will be designed to achieve a haulage level a few meters above the maximum standing water level. Blasting activity during the mining of oxide material will be minimal, with the rate of activity increasing as the mining of fresh ore (Stage 2) commences and would generally occur during the day time only. Blasting is likely to utilise ammonium nitrate-fuel oil (ANFO) as a bulk explosive and non-electric surface and down hole delays. Each hole will be stemmed prior to blasting. U3823_Marampa_ESIS_Final.docx September 2012 Page 51 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Figure 4.6: Layout for Stage 1 mining, showing preliminary surface water management design U3823_Marampa_ESIS_Final.docx September 2012 Page 52 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Figure 4.7: Layout for Stage 2 mining, showing preliminary surface water management design U3823_Marampa_ESIS_Final.docx September 2012 Page 53 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Figure 4.8: Layout at end of mine, showing backfilled pits and preliminary surface water management design U3823_Marampa_ESIS_Final.docx September 2012 Page 54 of 244 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Preliminary hydrological and hydrogeological studies indicate major dewatering operations will be necessary to manage the combination of rainfall runoff and groundwater inflow. Dewatering requirements, based on seasonal conditions, will range from less than 3 3 10,000m /d to greater than 40,000m /d at maximum pit development. Dewatering is likely to be achieved through a combination of groundwater abstraction ahead of mining, and in-pit sump dewatering. The excess water will pumped to settlement ponds before release to the natural water courses that drain to the Rokel River with a proportion directed to the TSF during the dry season. 4.2.4 Mining equipment The preliminary estimates of the mining equipment required for the production schedule is provided in Table 4-3. The numbers may vary slightly over the mine life depending on the ore and waste haul distances. The truck requirements per excavator are relatively high due to the 6 km ore haulage to the plant site and generally low waste to ore ratios. Based on 300 mining days per year (assuming about 60 days lost due to high rainfall), it is estimated that up to about 85 kt ore would need to be transported per day from the pit to the beneficiation plant (requiring approximately 350 movements in a 240 tonne truck), and 120 kt rock waste per day (requiring approximately 500 truck movements between the pits and the waste rock dumps). Table 4-3: Mining equipment Mine development Stage Stage 1 Stage 2 Liebherr R984C Excavator 2 2 Caterpillar 777D/F D/Truck 12 16 Liebherr R995 Excavator 6 Caterpillar 793 D D/Truck 48 Cat D10T Dozer 2 8 Cat 16M Grader 1 6 Cat 773D WT Water truck 2 6 Caterpillar 992 FEL 1 2 Tamrock Drill 1 2 Reedrill SKSS Drill 2 8 The workshop for servicing the mining equipment will be located to the north of Mafuri Pit (location shown on Figure 4.1) and include 5 maintenance bays and a washdown bay. If the wash down only involves the removal of external dirt and dust, a sedimentation process will be used to reduce the total suspended solids content before discharging the waste water. If machinery, engines, engine parts and other equipment are being cleaned, then the washdown bay will drain through an appropriate filtration system consisting of a holding tank and oil/water separator. Hazardous materials (reactive, flammable, corrosive and toxic) will be stored in clearly labelled containers (in a designated storage area) and vehicles. Storage and handling of hazardous materials will be in accordance with local regulations, and appropriate to their hazard characteristics. Fire prevention and secondary containment will be provided for the workshop and storage facilities. 4.2.5 Explosives storage The daily bulk explosive requirement for the mining operations will be minimal during the U3823_Marampa_ESIS_Final.docx Page 55 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Stage 1 mining operation. For Stage 2 it will vary between 25-40 tonnes per day, depending on the depth of the pits and strength of the rocks mined. Approximately two weeks supply of bulk explosives will be stockpiled at the site in a purpose built shed, the location of which is indicated close to the Gafal waste dump on Figure 4.1. The shed will be designed, structured, ventilated and secured based on Australian standards (AS 2187) or other acceptable international standards. It is expected that approximately 1-2 bulk explosives trucks will arrive to site daily for 4-5 days of the week, with detonating explosives and other accessories transported every 1-2 weeks, A steel container transportable explosives magazine, built to industry standards, will be located away from other installations and critical infrastructure. The magazine will be secured for access to authorised personnel only, ventilated sufficiently, provided with adequate lighting and electrical wiring in compliance with regulations. The detonators and explosives for the site will be transported separately in containers and vehicles built to appropriate standards. Licensed professionals and equipment and a sufficient level of security personnel and equipment will be employed during the transport of the explosives. The explosives at the site will be handled by the licensed shot firers and appropriate equipment will be used in transportation and installation before the blasts. The explosive storage areas will be located and drained adequately to prevent any flooding. The explosives magazine will be effectively earthed against lightning. The explosive structures will be marked clearly in the site plans, and the facilities and equipment will be clearly signed for identification. 4.2.6 Waste rock dumps Excavated waste rock over the life of the mine is estimated to total approximately 612 Mt (Table 4-1), and will initially be transported via haul trucks to four WRDs, one adjacent to each pit. The exact configuration of the WRDs will depend on the final pit outlines, though the dumps are currently anticipated to have an average height of between 15 and 20 m above natural topography during Stage 1, increasing to 50 m in height by the end of mine life. In addition to the external waste dumps, a total of approximately 200 ha of earlier mined out pits will be backfilled progressively with the waste mined from later pit stages. The approximate areas of disturbance for each of the final waste dumps are as follows: • 100 ha Gafal waste dump • 100 ha Mafuri waste dump • 350 ha Matukia waste dump • 250 ha Rotret and Gafal waste dump • 800 ha Total area required for external waste dumps During Stage 1, a relatively large amount of laterite low grade ore will need to be stockpiled. This stockpiled laterite material will be reclaimed during the Stage 2 operation and blended to make up 10% of the process plant feed. It is proposed that the ROM and long-term stockpile area will be used for this purpose. The preliminary estimate of area requirement for the ROM pad and long term ore stockpiles is approximately 100 ha. The waste dumps will be constructed in 20 m lifts as the final face slopes are formed progressively as each lift reach the area limits. The waste dump face slopes will be less than 20 degrees with 10 m wide berms located between 10-20 m vertical intervals to prevent erosion from high rainfalls. The overall slope of the waste dumps will be 16-18 degrees. U3823_Marampa_ESIS_Final.docx Page 56 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Any waste that might be an environmental concern and any oxide waste that might be a stability concern will be dumped internally within the dumps and covered with neutral waste to protect against weathering. Geochemical investigations have been completed on expected waste rock samples from the four pits, as well as the expected ore, concentrate and tailings materials and reveal low potential for acid generation. Leaching of metals from the waste rock is also unlikely (although further geochemical assessment will be conducted to confirm this). Drainage channels will be constructed around the waste dump areas and through the waste dump slopes, as necessary, to direct the surface water flow to the settlement ponds. The settled water in the ponds will be released to environment with regular water quality tests performed to monitor the quality of the discharge. If the water in the pond exceeds the agreed water quality standards, it will be contained until it complies or redirected to the TSF. 4.2.7 Topsoil Topsoil recovered from the pit and waste dump areas will be stored separately and used for the rehabilitation of the waste dump surfaces and other structures. 4.3 Processing The beneficiation plant will consist of facilities and areas for crushing, stockpiling, ore reclamation, grinding, wet high intensity magnetic separation (including roughing and scavenging, regrinding, cleaning and recleaning), concentrate thickening and filtration, tailings thickening and utilities, and reagent storage. The general arrangement of the beneficiation plant (showing the components for Stage 1 and the additional components for the Stage 2 7 expansion) is shown on Figure 4.10 . The TSF and rail loading spur will be located close to the beneficiation plant (Figure 4.1). 4.3.1 Stage 1 Beneficiation Plant During Stage 1, processing will treat oxide ore only to nominally produce 2.5 Mtpa of iron ore concentrate, although the actual production output will be matched to the tonnage of sales in place at the time. The process flowsheet for Stage 1 is shown schematically in Figure 4.9. Parts of the Stage 1 process plant will be constructed at a larger capacity, to facilitate the Stage 2 expansion. The Stage 1 process plant will include the following key components, shown on Figure 4.10: • 5 Mtpa primary crushing module; • 2.5 Mtpa wet scrubbing module; • 2.5 Mtpa Wet High-Intensity Magnetic Separation (WHIMS) plant; • 5 Mtpa concentrate thickener; • 5 Mtpa tailings thickener; • 2.5 Mtpa concentrate pressure filtration facility; • 1,000,000 tonne linear product stockpile including stacking equipment; and • A rail spur to connect to the Project to the existing Tonkolili to Pepel railway line. Oxide ore will be hauled from the pits to the beneficiation plant and deposited by haul truck either directly into the primary crusher, or stockpiled on the ROM ore pad before being loaded by front end loader into the primary crusher. The primary crushing plant will consist of sizers 7 Note the pipeline to Tagrin port shown on this layout plan is not included in the scope of this ESIA U3823_Marampa_ESIS_Final.docx Page 57 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report (toothed rolls crushers) to reduce the ore to rocks of less than 250 mm. The ore will then be fed by conveyor to a rotary wet scrubber where it is further reduced in size to 850 µm. Scrubbed material will be pumped directly to the rougher magnets within the WHIMS circuit. Scrubber oversize material will be directed to a temporary stockpile and will be processed through the comminution circuit for the fresh ore, when it is installed in the Stage 2 beneficiation plant. The scrubbed ore will be processed initially via three sequential stages of WHIMS including initially, two stages of roughers and a scavenger stage. The scavenger WHIMS units will be operated at higher field strength to maximize overall iron recovery. The non-magnetic fraction from the scavenger stage will be the final beneficiation plant tailings stream, which will be thickened prior to disposal to the TSF. The scavenger concentrate will be reground to a top size of 180 µm before recycling to the first stage rougher WHIMS unit to optimize iron recovery from the beneficiation plant. The concentrates from both the rougher stages will be screened at 250µm, with the -250µm fraction reporting directly to the cleaner WHIMS units. The +250µm fraction will undergo regrinding in closed circuit with a 250µm screen before proceeding to the cleaner WHIMS magnets. The cleaner tails will be directed back to the rougher WHIMS, whilst the cleaner concentrate passes to the recleaner stage. The final concentrate product from the recleaner stage will have an iron grade of approximately 65% iron with low levels of deleterious elements. The recleaner tailings are returned to the cleaner magnetic separators. All of the WHIMS magnetic separators require significant amounts of wash water to remove the magnetic fraction from the WHIMS magnet matrix. The concentrate fractions will be dewatered using hydrocyclones, and the cyclone overflow streams will be recycled within the plant as wash water. The final concentrate is flocculated and thickened to approximately 65% solids via a conventional thickener and then pumped to three agitated slurry holding tanks of 3 approximately 4,580m each with surge capacity to store concentrate for approximately 20 hours of plant operation. The clear thickener overflow will be returned as wash water for the cleaner and recleaner magnetic stages. From the holding tanks, thickened product will feed a pressure filtration plant for dewatering. The filter cake (with a moisture content of approximately 8%) will be stacked onto 1,000,000 tonne linear stockpiles adjacent to the rail siding. Front end loaders will recover the product from these stockpiles for loading into the rail cars, for transport to Pepel port. Supernatant water from the TSF will be recovered and recycled within the beneficiation plant. 4.3.2 Stage 2 Beneficiation Plant expansion During Stage 2, processing will continue to treat oxide and/or fresh ore to nominally produce up to 15 Mtpa of concentrate. The process flowsheet for the full Project (Stage 2) is shown schematically in Figure 4.9. The Stage 2 expansion will generally replicate the Stage 1 process plant modules, but will also add a secondary and tertiary crushing and screening plant to process the harder fresh ore material (Figure 4.10). U3823_Marampa_ESIS_Final.docx Page 58 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Figure 4.9: Schematic process flow diagram for Stage 1 U3823_Marampa_ESIS_Final.docx September 2012 Page 59 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Figure 4.10: Schematic process flow diagram for Stage 2 (full development) U3823_Marampa_ESIS_Final.docx September 2012 Page 60 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report The expansion will add the following key components at the beneficiation plant: • 2 x 5 Mtpa primary crushing modules; • 1 x 2.5 Mtpa wet scrubbing module; • 3 x 5Mtpa secondary / tertiary crushing and screening modules; • 3 x fine ore stockpile stacking equipment and six fine ore stockpiles, including 6 x 2.5 Mtpa tunnel reclaim systems; • 6 x 2.5Mtpa primary ball milling modules; • 5 x 2.5 Mtpa WHIMS plant; • 2 x 5 Mtpa concentrate thickener; • 2 x 5 Mtpa tailings thickener; • 2.5 Mtpa concentrate pressure filtration facility; and • 4 x concentrate slurry storage tanks. Oxide ore will continue to be processed as described in Section 4.3.1, but at an increased capacity of concentrate production. Fresh ore will be blended with a minor component of laterite ore and fed from the primary crusher directly to the secondary / tertiary crushing and screening plant. The crushed -10mm product from this plant will then be discharged to fine ore stockpiles for temporary storage. Tunnel reclaimers will recover the fine ore from the stockpiles and convey it to the primary ball milling circuits. The primary ball mills will operate in closed circuit with vibrating screens, creating a milled product finer than 850µm. This will then proceed to the rougher magnets in the WHIMS circuit. From here the two ore types are processed in the same way, following the description in the section above. During Stage 2, 1.8 Mtpa (or up to 3.4 Mtpa) of concentrate will continue to be railed to and stored at Pepel, for subsequent export, while the remaining concentrate will be exported via the port of Tagrin. The entire plant will be controlled using modern instrumentation including magnetic flowmeters, level sensors, density control systems (non-radio-active), automated valves, variable speed motors, etc. These units will be integral components to a computer operated, intelligent process logic control system, which will be managed by trained beneficiation plant operators from central Control Rooms situated within the plant. 4.3.3 Reagents As the processing circuit is largely based on physical separation techniques, few chemical reagents are required. The only reagent required is flocculant, which is used to thicken the concentrate and the tailings to accelerate the settling of fine solids out of the slurry. Other materials used in the process are described in Table 4-4. The reagents storage area at the beneficiation plant is shown on Figure 4.11 as item 13 and on Figure 4.12 as item 20. U3823_Marampa_ESIS_Final.docx September 2012 Page 61 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Figure 4.11: Beneficiation plant layout for Stage 1 U3823_Marampa_ESIS_Final.docx September 2012 Page 62 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Figure 4.12: Beneficiation plant layout, showing Stage 2 expansion U3823_Marampa_ESIS_Final.docx September 2012 Page 63 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS –– Main Report Table 4-4: Reagents and other materials likely to be used in the beneficiation plant Name Use Hazard Quantity Containers * rating used (t/a) Concentrate thickener– to Non 20 grams 1 Tonne Bulk Flocculant Anionic type accelerate solids settling hazardous per tonne Bags of solids Tailings thickener – to Non 20 grams 1 Tonne Bulk Flocculant Anionic type accelerate solids settling hazardous per tonne Bags process of solids Equipment oil, coolants Mobile equipment and Hazardous TBD 200 L drums and hydraulic fluids vehicles * Classification is based on the United Nations (UN) Recommendations on the Transport of Dangerous Goods - Model Regulations (UN, 2009) 4.4 Tailings storage facility A TSF will be constructed in two phases, as shown in Figure 4.1, and will store tailings for the first 12 years of the operation. Following this period, tailings will be stored within the mined out Matukia Pit. 4.4.1 Tailings and TSF decant water pipelines Tailings material and TSF decant water will be transported to and from the TSF respectively via HDPE pipelines (1 km pipeline in each direction). The pipelines will be above ground, but buried under a protective soil mound, and if stream crossings are required these will be handled via bridges. No pump stations will be required along the pipelines 4.4.2 TSF design A conventional multiple cell valley-type TSF will be constructed across three adjacent valleys north of the processing facilities (figures showing the proposed layout of the TSF and embankment wall construction can be found in Appendix E. The final configuration of the facility will cover 750 ha and will have the capacity to store approximately 200 Mt of tailings. The facility will be constructed in stages, using perimeter embankments around the four sides of the facility along ridgelines. The starter embankments of the TSF will be constructed to a maximum height of 23 m, and will be raised by upstream construction techniques in stages (3 x 5m lifts) to a maximum embankment height of 38 m, with a nominal freeboard of 5 m. The facility will be unlined due to low permeability of in-situ bedrock. Construction materials for the starter embankment will include clayey gravel sourced from borrow areas within the final TSF footprint. Borrow material from within and outside the footprint will also be used for upstream construction and mine waste may also be used during the later years of the facility life. A decant system and under drainage will be constructed to recover supernatant water from consolidation of the tailings material. At start-up, the decant system will consist of temporary pumps (land based or floating pontoon mounted). After Year 3 a fixed pump decant within each TSF cell will be utilised for supernatant water recovery. The decant towers will comprise slotted pipes stacked vertically and surrounded by clean filter rock. The decant towers will be raised along with the perimeter embankments. Access to the decant facilities for light vehicles and maintenance equipment will be via a decant access way constructed from gravelly borrow materials or mine waste. Return water will be pumped back to the plant for re-use in the process. U3823_Marampa_ESIS_Final.docx September 2012 Page 64 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS –– Main Report An under drainage system will also be constructed to assist in the recovery of water, reduce the potential for seepage losses and to prevent embankment failure. The under drainage system will comprise a collection trench positioned upstream of the main embankments that will drain to pump sumps. Pumps deployed down an inclined borehole will allow recovery of water. The under drainage lines will typically comprise a shallow geotextile lined trench backfilled with coarse aggregate. At the top of the trench geotextile will be wrapped and stabilized with select rock. Water collected in the under drainage system will be pumped to the decant area and hence back to the plant for re-use in the process. The TSF will be designed such that upslope catchment areas will be small to limit watershed (clean) run-off into the tailings area. Runoff will be by incident precipitation only. The facility will be designed to contain a 1 in 1000 average recurrence interval three-day precipitation event, whilst maintaining a freeboard of at least 0.3 m. As it is situated on an elevated area relative to its surroundings, stormwater flow will naturally be directed away from the TSF. Management of stormwater on the TSF will therefore not be required. Table 4-5: TSF design criteria Design component Criteria Throughput 22.8 Mtpa (max) Solids content 60% (by weight) Density Dry density 1.5 t/m³ Seismic Operating basis earthquake loading 0.06g (0.6 m/s²) Post-closure maximum credible 0.1g (0.1 m/s²) earthquake loading Hydrology Embankment levels Will contain design storm event while maintaining 0.3 m freeboard Design storm 1 in 1000 year return 3-day precipitation event 4.4.3 TSF operation Tailings will be deposited using sub-aerial deposition techniques from multiple spigot locations located on the main and saddle embankments. At start-up, tailings deposition will be from the main (northern) embankment, which will lead to the formation of a beach up the valleys, moving in a south westerly direction. Temporary pumps for supernatant water recovery will move up the valleys as the tailings and water levels rise. The location of tailings spigots will be changed as required to ensure tailings beaches slope towards the decant area and to direct the supernatant water pond away from the containment embankments and maintain it around the decant facilities. The pond will be minimized as far as practicable (while maintaining enough water to keep the tailings material moist and thereby prevent tailings dust generation) to reduce evaporation and maximise water return. Once the TSF is fully operational, water volumes surplus to plant and site requirements will be removed from the TSF and discharged downstream via silt traps / constructed wetlands. Discharge of water will be required to maintain constructability of the proposed upstream embankment raising construction method and also embankment stability. Embankments, tailings delivery and deposition, and water recovery systems will be inspected frequently by an operator or shift supervisor (at least once per production shift) to limit operational problems. Groundwater quality and quantities will be monitored frequently and the design and operation of the TSF will be inspected by a qualified geotechnical engineer at least once per year. U3823_Marampa_ESIS_Final.docx September 2012 Page 65 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS –– Main Report As the TSF is situated on an elevated area relative to its surroundings, storm water flow will naturally be directed away from the TSF. Management of storm water on the TSF will therefore not be required. An emergency spillway will be installed as part of the TSF design to manage discharge, should this occur. Geochemical characterisation of the tailings material (ARDML potential) has indicated that it is unlikely to generate acidity, but will also have limited buffering capacity. Net Acid Generation (NAG) test leachate analysis of tailings samples also revealed little potential for leaching of iron or trace metals from the metallurgical samples. For further detail refer to Marampa Iron Ore Project ARDML Baseline Assessment Report (SRK Consulting, 2011), included in SD 6 of Volume 3. 4.5 Power supply Power will be supplied to the Project using HFO generators, which will be introduced in stages to match the staged development of the Project. A power station will be constructed close to the beneficiation plant and rail spur line (Figure 4.1) and will be sized in accordance with the details in Table 4-6. Table 4-6: Power station capacity and requirements Stage 1 (MW) Stage 2 (MW) Demand Installed Demand Installed 22 45 115 145 The average HFO consumption would be approximately 4 t/h, based on an average specific fuel consumption of 190 g/kWh. The HFO will be stored in steel tanks contained within a 3 bunded facility. The tanks will be sized to provide 1 month of total storage capacity (3,000 m 3 for Stage 1 and 15,000 m for Stage 2). HFO will be delivered to site by means or road tankers owned and operated by a third party supplier. Power will be generated at a medium voltage of 11 kV and will be distributed to the various load centres at the same voltage. Each load centre will consist of a step down transformer(s) and Motor Control Centres (MCC’s). The Low Voltage power supply will be reticulated at 550 V. As the majority of the power usage will be within the beneficiation plant, the power plant will be located as close as possible to minimise the length of transmission lines, and hence maintenance, energy losses and probability of outages. 4.6 Water supply To reduce the demand on local water sources, the majority of the water used in the process will be sourced from rainfall captured in the TSF. A preliminary water balance established for 3 the Project, indicates that approximately 8,000m of make-up water per day would only be required during the dry season. The maximum demand is estimated at approximately 1250 3 m/hr. During the dry season the plant make-up water will be pumped from a newly constructed pumping station on the Rokel River, positioned to the south of the plant (exact location yet to be identified). Once the Project is operational, containment, controls and mine dewater input U3823_Marampa_ESIS_Final.docx September 2012 Page 66 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS –– Main Report will provide routine closed cycle use, with top-up from the river supply if and when required. The pump station at the Rokel River will contain electric pumps that will pump water via a buried HDPE pipeline to the plant site. The water at the plant site will be stored in 2 steel 3 tanks, each 5,000 m capacity, from where it will be distributed. Raw water will be clarified and filtered for use as potable water. Potable water will be distributed to the plant and to a header tank in the accommodation village. Details of the proposed water storage facilities for the mine site are provided in Table 4-7. As indicated in Figure 4.13, four settlement ponds (one downstream of each open pit and WRD) are included to manage stormwater runoff. Additional ponds may be required at the beneficiation plant, long-term stockpile area and TSF, but the size and location of these ponds is yet to be confirmed. Table 4-7: Water storage facilities Facility Location Storage Structure Water source(s) Destination (and capacity final use of water) 3 • Pumped from • Beneficiation Raw Beneficiation 2 x 20,000m Steel Rokel River plant water tank plant tanks • Potable water treatment system • Fire water system • Mine site fresh water tank 3 • Raw water Tank • Plant (process Process Beneficiation 2 x 20,000m Steel water) water tank plant tanks • Thickener tank overflow • Reclaim water from tailings dewatering plant • Storm run-off from collection pond/s • Effluent from the sewage treatment plant • Reclaim from TSF Storm Mine pits 50m x 200m; Excavated • Storm water • Transferred to water and WRD; Designed to pond runoff (and pit the process settlement Beneficiation store 1:10 - dewatering water water tank ponds plant, year, 24-h in the case of the • Evaporation stockpile storm event pit, if required) • Possible area and during discharge if TSF operation quality suitable Mine Mine camp TBD Steel tank • Potable water • Accommodation camp treatment plant camp potable water tank Mine site Mine area TBD Steel • Raw water tank • Dust raw water tanks suppression tank/s U3823_Marampa_ESIS_Final.docx September 2012 Page 67 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Figure 4.13: Site layout for end of mine showing locations of settlement ponds and water storage reservoir U3823_Marampa_ESIS_Final.docx September 2012 Page 68 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report 4.7 Concentrate transport 4.7.1 Stage 1 development During Stage 1, iron concentrate will be transported from the mine site to the Pepel port by way of an existing railway between Marampa and the port of Pepel. The railway and the port itself have been refurbished and placed back in to operation. Both facilities are owned and operated by African Railways and Port Services Ltd (ARPS), a subsidiary of AML. MIOL has an access agreement with AML for access to the rail and port facilities at Pepel. Spur line A 3.0 km spur line (shown in Figure 4.1 with additional detail in Figure 4.11) will be built to connect the Project with the existing railway at chainage 71 km (from Pepel Port). The line will be a single turnout from the main line. Incoming (empty) trains would pass directly through the junction along the spur line and on into the load out siding. A departure loop parallel to the spur line will be required to hold trains awaiting access to the mainline. A ‘Points man’ station will be required at the north end of the loop to control switching into and out of the main line as well as the switch from the departure loop. Load out area Returning empty trains will enter the load out siding head on. The locomotives will be decoupled from the wagons and will continue on a loop to re-join the wagons on the western end. The newly loaded train will leave the load-out area head on and will run to the departure loop prior to being released onto the main line. Switches in the siding area will be operated by manual levers. The load out area, shown in Figure 4.11, will include an 850 m-long track and a loading apron of 10m width from which front end loaders will load the wagons. The loading apron will be constructed on a suitably compacted sub base. Two 500,000 T linear product stockpiles will located to the rear of the apron parallel to the track. The loaders will take material from the part of the stockpile nearest the wagon being loaded. Rolling stock The rolling stock for ore transport will be supplied by AML, as part of the rail and infrastructure agreement with MIOL. 4.7.2 Stage 2 development During Stage 2, it is anticipated that product export as described for Stage 1 will continue, but that the additional 13.2 Mtpa iron ore concentrate will be pumped to Tagrin Port via pipelines. Details of the pumping system, dewatering and other activities associated with product export will be described in the future amendment of this ESIA document. 4.8 Other site infrastructure and services 4.8.1 Roads and freight Site roads Roads will be constructed to connect the various components of the operation. Two large haul roads will be required to transport ore from the Matukia Pit and the Rotret, Mafuri and U3823_Marampa_ESIS_Final.docx September 2012 Page 69 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report Gafal pits to the processing area. Each one of these haul roads will be approximately 6 km long and the routes are shown on Figure 4.13. Smaller roads will also be required at the beneficiation plant for light vehicles. Two new road crossings will be required where the haul roads from the Gafal Pit and Matukia Pit will cross the Makeni Highway. In these areas the Makeni highway will pass over multi- plate arch culverts, through which the haul trucks will pass (see Figure 4.1 for the locations and design detail of these road crossings). The roads will be constructed from Laterite, which is naturally occurring in the upper soil profile of the site. Preliminary investigations have confirmed the suitability of the in-situ material for road construction. Water trucks will be used to minimise dust on the haul roads during the dry season. Freetown-Lunsar road Inbound freight will travel from Freetown port to Lunsar via an existing sealed road (the Makeni Highway). Specialized equipment will be supplied by the freight forwarder and clearing agent to transport any oversized equipment to the site. 4.8.2 Storm water management The high rainfall during the wet season will require effective drainage networks for process and accommodation facilities. A water management plan will be developed to provide a strategy for segregating two categories of water, defined either as impacted or non-impacted (clean) water. Impacted water refers to run-off that potentially has low pH (acidic) or contains elevated levels of naturally occurring metals or high sediment loads. Storm water settlement ponds will form part of the drainage network to collect this impacted water. They will be sized in accordance with EHS guidelines. During normal operations, the sediment ponds will be cleaned out during the dry season, with the collected sediment placed on the waste dumps for long term storage. 4.8.3 Waste management A waste management plan will be implemented that: • Minimises waste generation by efficient use of resources; • Reduces the volume of unavoidable waste through product selection, re-use and recycling; • Contains and isolates waste from groundwater and surface water, and enables storage, treatment or collection of waste that does not result in long term impacts on the surrounding environment; and • Minimises the environmental impacts of waste hydrocarbons and chemicals through appropriate storage, handling and disposal. The types of wastes generated by the Project will include: • General Waste: - Domestic waste (e.g. plastic, paper, workshop wastes and domestic solid and food wastes); - Construction and industrial waste (wood, scrap metal, tyres, rubber, lights, batteries); - Sewage. • Hazardous Waste: U3823_Marampa_ESIS_Final.docx September 2012 Page 70 of 298 SRK Consulting (UK) Ltd Marampa Iron Ore Project ESIS – Main Report - Hydrocarbons (engine oils, lubricants etc.); - Medical waste; - Plant maintenance related chemicals (although only in small amounts). Domestic and industrial waste will be disposed of in a dedicated landfill site built for the purpose. Containerised sewage treatment plants will be used to handle sanitary waste water, which will be installed at the beneficiation plant/office area, as well as the accommodation camp. During construction, the village plant units will serve the construction camp. The sewage treatment plants will be sized to accommodate the number of people working at the Project. Hazardous materials and waste will be stored in accordance with international standards. Procedures will be prepared for the correct handling and storage of hazardous materials, including the disposal of hazardous waste. Hazardous waste will be removed from site by a licensed contractor for disposal in an approved facility, in accordance with the requirements of controlled waste regulations. 4.8.4 Communications Initial site communications during the early phases of construction will be via satellite. During construction a mobile phone tower will be installed in a suitable position to enable coverage across the operational mining area including the accommodation village, mining area and beneficiation plant. Telephone and data network cables will service the site and accommodation village and will be buried. 4.8.5 Accommodation For Stage 1, a 115-man staff village / accommodation camp will be constructed to accommodate operational expatriate and senior national staff. The camp will be expanded to accommodate a total of approximately 210 personnel for Stage 2 of the development. The staff village is shown on Figure 4.1 and will consist of: • General Manager’s quarters; • Senior Manager quarters; • Manager quarters; • Messing and laundry facilities; and • Recreational facilities. Operator level and junior supervisors will be sourced and/or housed within the existing facilities in Lunsar. Buses will be utilised to transport personnel to the site. During the construction phase, contractors will make provision for temporary facilities to house their personnel. 4.8.6 Medical services A clinic will be constructed near the beneficiation plant, to be manned by an expatriate paramedical team, assisted by local medical professionals. The clinic will be fitted out to provide standard general practice patient care and to provide stabilisation of patients who may be injured in an accident. Injured patients, once stabilised, will be taken by ambulance to either the Lunsar hospital or medivac’ed to Freetown to the better equipped hospitals. U3823_Marampa_ESIS_Final.docx September 2012 Page 71 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 4-8: Management of non-mining wastes Wastes Temporary storage Potential waste recycling Waste treatment Disposal Non-hazardous waste Domestic waste Non-hazardous waste transfer station Paper, wood products, plastics and Landfill metals recycling Organic waste Non-hazardous waste transfer station Composting Landfill Tyres Non-hazardous waste transfer station Recycling Scrap – such as scrap metal, wood Non-hazardous waste transfer station Recycling Landfill waste, worn conveyor belt, used wear (specifically demarcated containers) liners Inert construction material and Non-hazardous waste transfer station Donate to local community Landfill demolition debris (stockpiles) Storage drums Non-hazardous waste transfer station Returned to suppliers or recycling Sewage sludge Wastewater treatment systems None Landfill Flue gas desulfurisation waste; spent HFO plant None filter fabric and associated solids from HFO plant Hazardous waste HFO sludge Hazardous waste storage depot None By approved contractor Spent oil and lubricants Hazardous waste storage depot Recycling Soils contaminated with hydrocarbons Hazardous waste storage depot Use in rehabilitation (once treated) Bioremediation and then use for rehabilitation Clinic waste/ medical waste In clinic in containers None By approved contractor Hazardous waste from the plant area Hazardous waste storage depot None By approved contractor and laboratory (including empty storage containers) U3823_Marampa_ESIS_Final.docx September 2012 Page 72 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 4.8.7 Fire fighting Buildings and locations of flammable materials will be fitted with fire extinguishers. A fire water system will be installed consisting of fire hydrants, hose reels, a sectional pressed steel tank, electric fire pumps (one operating, one on standby), an electric jockey pump and a diesel engine driven emergency pump with auto start and control system. The pumps will start automatically in the event of a pressure drop in the pipeline, indicating a hose reel or hydrant valve has been opened. Fire water will be distributed in a ring main to the plant and to the accommodation village. 4.8.8 Mobile Equipment The following table summarises a preliminary estimate of the number and types of mobile equipment (additional to the mining equipment listed in Table 4-3) allowed for as a permanent fleet: Table 4-9: Mobile equipment list for site operation Number provided Vehicle Stage 1 Stage 2 (additional) LDV/Utility vehicles 38 14 Fire truck 1 Ambulance 1 Mobile crane – 50 t 1 Mobile crane – 20 t 1 1 Skid steel loader 2 2 Front end loader 4 Flat bed truck – 5 t 4 Tractor trailer 2 Forklift – 5 t 3 2 Buses – 54 seater 4 Waste skip trailer 1 Rail load out Front end loaders 3 4.8.9 Fuel use and storage Fuel will be stored on site during the construction and operation of the Project. Fuel will be stored in steel tanks at the beneficiation plant (see location on Figure 4.11 (item 16) and Figure 4.12 (item 23)) and contained in bunded enclosures, designed to international standards, to prevent any contamination of the environment. Two types of fuel will be consumed at the site: • HFO - for the power generating facility (Section 4.5); and • Diesel fuel - for use in the mining fleet (Section 4.2.4) and mobile fleet (Section 4.8.7). The storage facilities for HFO and diesel will be designed to provide a minimum of one month 3 3 operating capacity (3,000 m of each fuel type for Stage 1 and 15,000 m for Stage 2). It is assumed that consumption (and therefore storage capacity) of HFO will approximately equal that of diesel. Fuel will be supplied by road tankers from Freetown using third party suppliers. 4.8.10 Security • MIOL will provide its own security for the site. The accommodation camp, process plant, U3823_Marampa_ESIS_Final.docx September 2012 Page 73 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report office and workshop areas will be fenced (all other areas will be unfenced). 4.8.11 Ancillary buildings The following buildings have been allowed for in the design: • Compressor house; • Offices / administration building; • Laboratory (with the capacity to process 100 samples per day, and including areas for sample preparation, equipment and two offices); • Workshops and maintenance facilities; • Process equipment store; • Reagents / oil stores; • Refreshment and rest room facilities at the plant (for approximately 30 operators, maintenance and warehouse staff); • Dining / recreation area; • Change house and laundry; • Clinic and fire station; • Communications centre / radio or satellite links; and • Security entrances – plant and accommodation camp. 4.9 Project implementation This section outlines how the Project will be successfully implemented if approval to proceed is received from the MIOL board and relevant regulatory authorities. 4.9.1 Project milestones Subject to raising sufficient funds to finance the construction of the Stage 1 development, it is expected that the Stage 1 operations will commence within 2 to 3 years of the Mining Licence being granted. While the Stage 1 development is in progress, the Company will conduct a feasibility study on the Stage 2 expansion, with the target, subject to raising of sufficient funds to finance the Stage 2 expansion, to commence construction of Stage 2 immediately after Stage 1 becomes operational. 4.9.2 Operation management The proposed organisation chart for the Project during operation is given below, though this will be reviewed on an ongoing basis as the Project develops. U3823_Marampa_ESIS_Final.docx September 2012 Page 74 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 4.14: Proposed organisation chart for operations 4.9.3 Human resources management It is likely key management positions will be sourced from Australia, with the remainder of the expatriate personnel sourced from Europe and South Africa. As there is a well-developed mining industry in several other African countries, a selection of personnel could be sourced from these countries as well. Although there is a skilled labour force in Sierra Leone, it is likely that competition between mining operators for this labour will be tight, and that considerable training will be required for local nationals. For the purposes of design, it has been assumed that expatriates will work a 6 weeks on/ 3 weeks off cycle, and that most national personnel will relocate to Lunsar. It is likely, however, that some senior national staff will be housed in the accommodation village and commute to work. The estimated numbers and categories of personnel required for the permanent workforce during Stage 1 and Stage 2 operations are shown in Table 4-10 below. Mining at the Project will be undertaken by an experienced mining contractor. A contractor will also be used at the accommodation camp (to provide messing and cleaning services) and for the power station operation. All other personnel will be employed directly by MIOL. U3823_Marampa_ESIS_Final.docx September 2012 Page 75 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 4-10: Estimate of operational personnel requirements Area Position Stage 1 Stage 2 Manager Operations Manager and Secretarial Support 3 3 Mine Mine Manager and Staff 3 3 Mine Technical Services 30 44 Mine Operations 7 10 Mining and Blast Contractors 175 500 Process Operations Process Manager and Staff 3 3 Metallurgy and Laboratory 21 52 Concentrator 52 189 Pipeline 0 43 Concentrate Storage & Load out 21 51 Power Station 8 18 Maintenance Maintenance Manager and Staff 3 3 Mechanical 26 72 Electrical 19 51 Commercial Commercial Manager & Staff 3 3 Administration, Accounting & Marketing 24 33 Supply / Warehouse 14 20 Accommodation Village Contractor 20 45 OHS&E OHS&E Manager and Staff 3 3 Health and Safety 10 14 Environment 4 4 Security Security Manager & Staff 2 2 Security 91 91 Community Community Manager 1 1 Community Liaison 3 3 Total 546 1261 4.9.4 Procurement It is unlikely to be possible to source the necessary goods for construction and operation of the mine from within Sierra Leone, with the exception of minor consumables such as fuel, food, stationary etc. Where possible however, additional goods will be sourced locally. 4.10 Pollution control The expected emissions and effluents from the main operations are described in Table 4-11 along with the planned pollution control measures included in the Project design. U3823_Marampa_ESIS_Final.docx September 2012 Page 76 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 4-11: Expected emissions and effluents from mining operations Activity Sources Outputs Planned control Mining Pit Drilling and Noise, blasting • Standard blasting controls excavation blasting fumes and vibrations Shovels and Dust • Use of water sprays or other suitable binding front end loader agents Groundwater • Pump to tailings storage facility or sediment traps inflow and rainfall prior to release to water courses into pit Haulage vehicle • Vehicle exhausts emissions • Regular maintenance Waste rock Dumping of Noise • Hearing protection for operators dumps waste rock Dust • Use of water trucks Storm water runoff • Sedimentation ponds Seepage • Ground preparation to minimise seepage Ore Haul trucks Dust • Water sprays or suitable binding agents transport • Control vehicle speeds Oil and waste • Oil-water separators at vehicle maintenance area / water from truck workshop shop • Settlement ponds for sediment Haulage vehicle • Vehicle exhausts emissions • Regular maintenance Processing Crushing, ROM Ore Dust from mobile • Water trucks screening Stockpile equipment • Slope and contour the ROM pad such that run-off and movements water contained on the pad or drained to suitable stockpiling settlement pond Crushing and Dust • Dust generation at all transfer points and on all Screening conveyors within these circuits managed using Modules vacuum dust collection systems • Covered conveyors Noise • Hearing protection for operators Fine Ore Dust • Telescopic chutes to minimise ore drop heights Stockpiles • Fine misting sprays to minimise dust generation Primary Primary Grinding Slurry spillage • Build on an impermeable concrete pad with Grinding Circuit adequate bunding around the perimeter to contain spillage • Hose slurry spillage into concrete sumps built into the concrete pad • Fit sumps with sump pumps to transfer the material back into the grinding circuit Noise • Hearing protection for operators • Consideration of noise bunding, if required WHIMS Rougher, Slurry spillage and • As for Primary Grinding Circuit. Scavenger, Noise Cleaner and Recleaner Circuits Regrind Milling Slurry spillages • As for Primary Grinding Circuit. Circuits and Noise Reagent Reagent Storage Dry Flocculant • Concrete floor Storage Warehouse Spillage • Regular sweeping of any dry flocculant spillage U3823_Marampa_ESIS_Final.docx September 2012 Page 77 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Activity Sources Outputs Planned control Reagent Flocculant Spills of flocculant • Impermeable concrete pad with adequate bunding Mixing and Mixing and around the perimeter to contain spillage Dosing Storage • Hose any spillage into concrete sumps built into the concrete pad • Fit sumps with sump pumps which transfer the material back into the mixing or holding tank Tailings Tailings Tailings Slurry Spill • As for reagent mixing and dosing Dewatering Thickener Power supply Power HFO Haulage vehicle • Require third party suppliers to use regularly generation transportation emissions maintained vehicles with suitably trained drivers Noise • Exhaust stacks Spills of HFO • Require third party suppliers to provide emergency training to drivers and to have spill kits with each truck HFO plant Emissions • Standard exhaust systems Noise • Enclosed in a building • Hearing protection for operators TSF Tailing Overflow from Discharge of • None, as supernatant expected to be of suitable disposal TSF pond tailings quality to meet discharge standards supernatant TSF dry beach Dust • Revegetate side slopes as soon as practicable and side walls after construction • Water sprays if necessary for slopes and dry beach Tailings and Tailings and Spillage of tailings • Regular inspections of pipelines decant water decant water or decant return • Leak detection system transport pipelines water Concentrate transport Concentrate Concentrate Concentrate Spill • As for reagent mixing and dosing Dewatering Thickener Concentrate Filtration Building Concentrate Spill • As for reagent mixing and dosing Filtration 4.11 Project closure The objective once mining operations are completed will be to ensure, as far as practicable, rehabilitation achieves a stable and functioning landform, which is consistent with the surrounding landscape and other environmental values. The general strategy for the completion of mine development, assuming expansion is possible, is that once mining of fresh ore is completed, the pits may be partially backfilled, allowing for up to 50% of the pit areas to be backfilled with waste and tailings. Once the Rotret Pit and Mafuri Pit are complete, they would be backfilled with waste rock from further expansion of the Gafal Pit and an extension of the Mafuri Pit to the south-east. This will minimise the need for waste rock disposal on surface, reduce the area of land to be disturbed and assist with closure at the end of life of mine. The Matukia Pit may be used to store about 3 120 Mm of tailings towards the end of the mine life, also reducing surface disturbance and facilitating closure implementation. The final site configuration at the end of mining is shown on Figure 4.8. Remnants of the mining activities post closure will include: • Open pit voids and pit lakes - as the Project involves bulk scale iron ore open pit mining U3823_Marampa_ESIS_Final.docx September 2012 Page 78 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report to below the natural water table, the open pits that remain post closure will fill with water and form a lake. • Waste rock dumps - the WRD constructed during the mining operation will remain post closure. Upon rehabilitation, the waste dumps will not be visually dissimilar to the surrounding environment. Progressive rehabilitation as proposed above may reduce the overall height of the dumps. • Tailings storage facility - the TSF will remain a permanent feature of the landscape and the contained tailings will drain to an increasingly stable mass. A preliminary water balance analysis of the facility indicates the facility could contain a large water pond area, which would vary between the wet and dry seasons. As part of water management at closure a lined spillway will be constructed to remove excess water from the TSF. Only the top surface that will be permanently above the maximum water level will require rehabilitation. • Removal of infrastructure - the main infrastructure built for the Project (such as the beneficiation plant, workshops, pipelines, power station etc.) will be removed post closure, with the infrastructure re-used, recycled or disposed of as appropriate. For general infrastructure, such as general buildings, roads etc., MIOL will first consult with the local authorities to determine what may be left intact for the benefit of the community. 4.12 Project Alternatives Alternatives considered for the various Project components are discussed in the relevant subsections above, as follows: 4.12.1 Power supply The power alternatives considered for the Project include: • the Bumbuna Hydroelectricity generation plant; and • heavy fuel oil (HFO) power plant. The Bumbuna hydroelectricity plant has an installed capacity of 50 MW but a stable capacity of only 18 MW during the dry season, which is insufficient for MIOL’s requirements. There is also currently no transmission link between the Bumbuna plant and the Project site, and for these reasons this source was eliminated as a possibility and HFO was chosen as the preferred option, as outlined in Section 4.5. 4.12.2 Water supply Alternatives considered for water supply include the small lake within the London Mining lease area. However, this supply would be inadequate for the purpose and possibly disrupt other water users including villages in the area. 4.12.3 Concentrate transport Road, rail and pipeline options were considered for the transport of the concentrate to the port. Road transport is expensive, high risk from a community health and safety perspective and challenging due to constraints with the existing national road network. It was therefore determined that rail would be used to transport the concentrate to Pepel port as outlined in Section 4.7. U3823_Marampa_ESIS_Final.docx September 2012 Page 79 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 4.13 Future studies The current Project description is based on the processing of ore in the Gafal, Rotret, Mafuri and Matukia resource areas to a produce up to 15 Mtpa of iron concentrate. This will be done in two stages. Where Stage 2 (or other additional development of the mine) requires the construction of new facilities not included in the description above and therefore not covered by this ESIA, additional studies and an amendment to this ESIA will be required. Subject to adequate financing being arranged, Stage 2 construction would commence immediately after Stage 1 became operational. Product transportation and export for Stage 2 is not included in this ESIA. However, it is envisaged that concentrate will be pumped to the Tagrin port, which is planned for development by AML. At Tagrin port, the concentrate will be dewatered and stockpiled, before being recovered and loaded on to Cape Size vessels. Additional infrastructure requirements to accommodate this will be confirmed during detailed feasibility studies, and assessed during the above-mentioned amendment to this ESIA. Other prospects have also been identified within EL46/2011 during the course of exploration activities, which could (subject to feasibility studies and environmental approval) potentially be exploited in the future. Infrastructure for the Project has therefore been sited to avoid sterilisation of these resources and facilitate additional mine development if this proves feasible. U3823_Marampa_ESIS_Final.docx September 2012 Page 80 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 5 BIOPHYSICAL BASELINE DESCRIPTION Baseline studies were undertaken for environmental aspects that may be affected by Project activities. The environmental baseline studies provide a database of physical, chemical and biological parameters which are used to predict and monitor the effects of the Project on the environment. The sections below provide a brief summary of the areas studied and methods used to characterize the environmental aspects of the areas potentially affected by Project infrastructure and activities. Detailed methods and findings are included in the full reports, which are presented as supporting documents to the ESIA, in Volume 3. It is recognised that the site has experienced disturbance due to mining and agricultural practices in the past and therefore cannot be considered to be in a ‘natural state’. It should also be noted that due to changes in the Project layout during the course of the ESIA, much of the baseline studies were completed based on the study areas defined under a previous layout, resulting in slight inconsistencies in this regard. This is however considered not to be of consequence to the ESIA due to the relatively minor changes involved, and the fact that the impact assessment has been conducted based on the Project description and layout presented in Chapter 4. 5.1 Physiography and Landscape Sierra Leone comprises three physiographic regions: a narrow band of coastal lowlands, the interior wooded plains, and the upland plateau which includes scattered mountains and hills to the north-east (Okoni-Williams et al., 2001). The Project is situated in the interior plains, as marked by a red symbol in Figure 5.3. The region around the Project area is relatively flat and low-lying at a height of approximately 40 to 90 masl and is characterised by gently undulating topography. The topographical variation creates two main drainage regimes within the Area; the majority of the concession area drains southwards into the Rokel River and the north of the Project Area drains westward into the Port Loko Creek. The lowland river valleys are characterised by relatively flat profiles with broad floodplains, which are generally waterlogged during the wet season and often used for rice cultivation, as shown in Figure 5.1 and Figure 5.2 . Villages are generally located on higher ground. Figure 5.1: Low lying swamp area previously used as rice paddy field U3823_Marampa_ESIS_Final.docx September 2012 Page 81 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 5.2: River basin to the north west of the Project area Figure 5.3: Topography of Sierra Leone (red symbol indicates Project location) 5.2 Geology and Geochemistry 5.2.1 Geology The Project Area covers an area of Archean basement gneiss and granite structurally overlain by rocks of the Marampa Group. The Marampa Group consists of an upper Rokotolon Formation and a lower Matoto Formation. Iron ore mineralization at the Project is hosted in specular hematite quartz mica schists (hematite schist) of the Rokotolon Formation, which is interlayered with quartz-mica-albite schists. The Marampa Group has been subject to multiple folding events which have imparted a strong foliation in the rock units and resulted in a basin and dome pattern of synforms and U3823_Marampa_ESIS_Final.docx September 2012 Page 82 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report antiforms with iron mineralisation preserved in the synformal areas. Later uplift of the basement has resulted in the current distribution of the hematite schists, with a concentration in the south eastern area and along the eastern margin of the large basement dome. Intense tropical weathering has produced a laterite cover over much of the Project area, ranging from 2 – 6m in thickness. The laterite consists of a hard massive pisolitic cap preserved on the many low elongate hills of the region. Laterite colluvium is common on the flanks of the hills. Beneath the laterite an oxidised, saprolite zone extends to depths of 10 – 30m below surface. The iron ore mineralisation occurs as units of hematite schist located within the metapelitic schists of the Rokotolon Formation. Due to the complex folding and lack of outcrop it is uncertain how many individual units of hematite schist occur and how they are related stratigraphically. To date, seven major hematite schist prospects (excluding Gafal Hill and Masaboin Hill) have been identified on the Marampa licence, with individual bodies of mineralisation up to 100m thick and extending over strike lengths of several kilometres. The locations of the seven hematite prospects are shown in Figure 1.3. 5.2.2 Geochemical characterisation Mining activities result in disturbance and exposure of rock. This increases the surface area and the likelihood of exposure of unoxidised surfaces to air and water, potentially generating acidic conditions and mobilising metals. Although these weathering processes would occur naturally over extensive geological timeframes, the disturbance by mining accelerates this process. A geochemical characterisation study was undertaken by SRK (ARDML Baseline Assessment for MIOL Project, SRK, 2012) to classify and quantify the potential acid rock drainage and metal leaching potential (ARDML) contribution to the environment from the deposit rocks. The geochemical characterisation study involved a review of previously collected information, field investigations and an assessment of the ARDML potential of the ore, waste rock, tailings and concentrate material using the following tests: • mineralogical characterisation using optical microscopy, Scanning Electron Microscopy (SEM) and X-Ray diffraction; • whole rock assay using Multi-Acid digest and elemental analysis; • carbon and sulfur analysis, and neutralizing potential analysis for Acid Base Accounting (ABA); • Neutralisation Potential (NP) to determine the sample’s ability to neutralise acidity; • Net Acid Generation (NAG) testing and NAG test leachate analysis; and • short-term leach tests. Sampling was carried out to provide lithological and spatial representation of geological units across the four pits proposed for this ESIA (Rotret, Matukia, Mafuri and Gafal). A total of 64 waste rock samples were selected from diamond drill cores from the four proposed pits, and were prepared on site in the MIOL laboratory. Four of these samples were duplicates for QA/QC analysis. QA/QC results were within reasonable limits expected for the test procedures used and no further analytical reruns were recommended. The IFC Mining Effluent Guidelines (IFC, 2007) and preliminary Sierra Leone Water Supply Guidelines (domestic water quality standards) were used to evaluate the leachates produced. In addition to the waste rock characterisation, a total of six samples of ore, tailings and concentrate were selected for metallurgical testing. U3823_Marampa_ESIS_Final.docx September 2012 Page 83 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Acid Rock Drainage Potential Results from the static acid generation prediction testwork show that the samples tested are predominantly classified as Non Acid Forming (NAF) with a low average sulfur content (compared to average crustal abundance) below 0.1% sulfide sulfur. Only a small portion of the dataset indicated uncertain characteristics with only one extreme sample showing Potentially Acid Forming (PAF) characteristics. The Quartz Mica Schist (QMS) material was found to generally have the highest sulfide content, up to 0.11%. However, in NAG tests, QMS samples were found to produce a NAG pH greater than 7 and as such are still classified as NAF. Only two samples were found to generate acidity in the NAG tests, both of which were taken from the Rotret area and produced low NAG values of approximately 5 kg CaCO /tonne. Across the Project area, net acid generation from oxidation of waste rock is 3 considered to be unlikely. Metals Leaching Potential In the short-term leach tests, metal leaching from the waste rock samples was generally low. Leachates showed a net alkalinity and relatively high pH levels comparable to Project area groundwater. Release of zinc and manganese was observed for highly weathered clay and saprolite samples, and iron and aluminium concentrations were elevated in higher pH samples of unweathered material. Boron release was found to be spread across lithological units and appeared to be solubility controlled. Results from the NAG leachate analysis, which indicate long-term conditions, indicated elevated chromium, manganese and boron release. Manganese release was associated with the lower NAG pH samples suggesting pH controlled solubility. Boron release was found to be slightly sporadic but correlated with higher concentrations from samples with a higher whole rock boron concentration. Overall, the potential exists for flushing and release of iron, aluminium, zinc, manganese and boron from the waste rock dumps at concentrations which may require further management if shown to be the case. Metallurgical samples Analysis of the ore, concentrate and tailings samples showed that all samples contained negligible levels of sulfides and low levels of carbonate. The ore, concentrate and tailings are therefore unlikely to generate acidity but will also have limited buffering capacity. ABA predictions class all the metallurgical samples as NAF. With respect to metal leaching, there is little potential for leaching of iron, manganese or trace metals from the metallurgical samples although zinc and arsenic release was detected from the tailings material and iron release was observed from the ore concentrate. 5.3 Natural Hazards Sierra Leone is located on the African tectonic plate in one of the least seismically active zones in Africa. Only five seismic events were reported in the region between 1947 and 1978, and none of these were recorded by the nearest seismological station in Senegal (Nippon Koei, 2005). The most common natural disasters occurring in Sierra Leone are flooding and disease epidemics (mainly bacterial infectious diseases). From 1996 to 2009 flooding affected 221,000 people in Sierra Leone and 103 people were killed (EM-DAT, 2012). It is estimated U3823_Marampa_ESIS_Final.docx September 2012 Page 84 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report that a disease epidemic occurs every two years in Sierra Leone (Preventionweb, 2012). Between 1985 and 2008, approximately 11,500 people were affected by disease epidemics and approximately 1,000 people died as a result (EM-DAT, 2012). 5.4 Climate Sierra Leone has a tropical savannah climate with distinct wet and dry seasons controlled by the migration of the Inter-tropical Convergence Zone (“ITCZ”) between the northern and southern hemispheres. The movement of this climatic feature creates a wet season from May to October and a dry season from November to April. The dry Harmattan winds usually blow from late November to mid-March transporting dust from the Sahara Desert. These winds bring no precipitation apart from the occasional very light rain. Average wind speeds in Sierra Leone are generally low. There is little seasonal variation in mean air temperatures, with slightly hotter conditions in around midyear. Historical climate data was available from the Freetown meteorological station; located 90 km west of the Project site, and was used to evaluate long-term climate trends in the area. 0 Historical temperatures average 27 C and historic annual rainfall averages 1580.5 mm. The nearest regional meteorological station to the Project area is located at Makeni; however this station has only been recording data since 1990. Annual average temperature between 2002 and 2005 ranges from 25.0°C and 25.5°C and total annual rainfall ranges from 2524.3 mm in 2003 and 3370.8 mm in 2004 (Statistics Sierra Leone, 2008). As part of the assessment of baseline environmental conditions at the site, an assessment of ambient climatic conditions in the area was undertaken to enable evaluation of any potential Project impacts influenced by to climate. The data was analysed by the air quality specialists as a component of their study (included as SD 2 in Volume 3). Due to the lack of site-specific data for the Project, a weather station was installed at the MIOL Office in Lunsar at a base elevation of 64 m (see Figure 5.4). The parameters listed below were monitored continuously and recorded every 10 minutes with data downloaded every month. • Wind speed and direction at 10 m above ground. • Temperature at 1.75 m above ground. • Solar radiation measurement at 2.5 m. • Relative humidity at 1.75 m. • Rainfall at 2.5 m. Climate data collected from the on-site meteorological station is displayed in Table 5-1. The station has been collecting data since June 2010, however due to malfunctioning of the device between May and December 2011, only data for the 12 month period until May 2011 is presented. Table 5-1: Climate data from MIOL meteorological station Month Daily Temperature Average (°C) Rainfall (mm) Number of rainy days June 2010 27.5 8.8 3 July 2010 25.7 399 23 August 2010 25.4 376.6 29 September 2010 26.0 283.4 25 October 2010 26.3 384.2 27 November 2010 27.2 78.2 12 U3823_Marampa_ESIS_Final.docx September 2012 Page 85 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Month Daily Temperature Average (°C) Rainfall (mm) Number of rainy days December 2010 27.5 32.4 4 January 2011 26.6 0 0 February 2011 28.7 0 0 March 2011 29.3 24 3 April 2011 29.3 17.4 8 May 2011 28.6 0.1 3 Total - 1604.1 137 The average temperature recorded at the on-site weather station is 27.34°C, which remains relatively constant year round due to the equatorial location. Rainfall data shows the distinct contrast between the wet season and dry season with rainfall ranging from a minimum of 0 mm in January 2011 and February 2011 to 399 mm in July 2010 (when the highest daily rainfall of 68 mm was also recorded). The prevailing wind direction is consistent throughout the year, predominantly from the southwest and west-southwest direction. Annual average wind speeds at the 10 m level in Lunsar were 2.63 m/s; however the wind speeds and direction may be affected by tall trees surrounding the weather station. Comparatively the Lunsar meteorological station is representative of the historic temperature and rainfall data obtained from the Freetown weather station. Figure 5.4: Automatic meteorological station at the MIOL site office 5.5 Water Resources 5.5.1 Hydrology Surface drainage within the Project area falls within two river catchments; the Rokel and Port Loko Creek (also called Bankasoka River). The Bankasoka is to the North of the Project area U3823_Marampa_ESIS_Final.docx September 2012 Page 86 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report and drains predominantly east to west, before turning south west where it drains into the Freetown Harbour (also known as the Sierra Leone River) at Tumbu Island. The Rokel is Sierra Leone’s largest river originating in the Guinea Highlands, from where it flows south west, passing in close proximity to the south of the site. The flow of the Rokel is regulated by a hydroelectric dam (Bumbuna Dam) which is located approximately 100 km upstream of the concession area. The Bumbuna Dam environmental impact assessment indicates flow releases from the dam will be increased compared with the natural flows during the dry season and below natural flow during the wet season, but the overall difference between regulated and natural flows under normal dam operation will not be significant. However, there are no flow-gauging stations on the Rokel downstream of Bumbuna with which to accurately estimate regional flows. Local drainage in the Project area is dendritic in form with shallow catchments and poorly defined stream channels within flat-lying wide, marshy flood plains. The three rivers located within the Project Area which all drain to the Rokel are the Kagbu, Baki and Batabana. The catchments of these three drainages are shown on Figure 5.5. Hydrological monitoring commenced at the mine site in June 2010. Surface water flow was measured monthly using a Valeport electromagnetic flow meter at four locations. River level stage gauging was also measured. Calculated flows from these sampling locations are shown in Table 5-2. The surface water flow monitoring sites MSW028 and MSW029 are located on the Kagbu River with MSW030 located approximately 3.3 km further downstream from MSW028. MSW031 and MSW034 are located on tributaries of the Kagbu River, both of which in a south easterly direction before joining the Kagbu River River depths were recorded approximately daily and the flow gauging monthly. Table 5-2: Calculated surface water flows Sample ID River Name Flow (m3/s) MSW028 Kagbu 0.686 MSW029 Kagbu 0.708 MSW030 Small Tributary 0.573 MSW031 Kagbu 0.175 U3823_Marampa_ESIS_Final.docx September 2012 Page 87 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 5.5: Catchments in the Project area U3823_Marampa_ESIS_Final.docx September 2012 Page 88 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 5.5.2 Hydrogeology An assessment of the hydrogeological conditions at the Gafal and Matukia pits has been undertaken by Coffey Geotechnics Limited. The hydrogeological setting of the Project area is characterised by a shallow, weathered zone overlying fresh rock which supports an unconfined aquifer. Groundwater is likely to be present in three distinct aquifer settings: perched aquifers within the surface laterites, the base of the saprolite zone and the major fracture systems within the fresh rock. The dominant aquifer is likely to be the base of the saprolite to the top of fresh rock zone, supplemented by deeper fracture systems, many of which may prove high yielding. Groundwater conditions at Marampa are considered to be non-homogeneous and anisotropic, with groundwater levels in individual bores (as well as groundwater yields) possibly controlled by the hydraulic properties and recharge conditions of individual fracture systems with little interconnection between such fractures in some areas. SRK manually dipped 21 boreholes at Gafal, 6 at Matukia and two village wells to establish the depth of the water table (see groundwater monitoring locations in Figure 5.7). In dry season conditions (March, 2011), the water table was measured at a maximum depth of 16 m below ground level and 7 to 8 m below ground level in the Matukia area (Figure 5.6). Maximum depth in the water table occurs in areas of highest topography and the depth to the water table decreases towards valley locations where it is likely to be coincident with surface water (streams or swampy areas). Shallow groundwater in the Project area therefore provides baseflow to the surface water network, probably on a perennial basis. Village water supply wells and boreholes will most likely extract water from this resource. Figure 5.6: Measurement of depth to water table using a dip meter 5.5.3 Water quality One round of water quality sampling was undertaken by SRK during February 2011. Seven U3823_Marampa_ESIS_Final.docx September 2012 Page 89 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report surface water quality samples were collected from the villages of Marunku, Mabungu, Maso, Matukia and Makump, and five groundwater samples were collected from village wells (locations shown on Figure 5.7). As the groundwater samples were collected from actively used community wells the wells were not purged prior to sampling. The samples were sent to Severn Trent Services (STS) in the United Kingdom for analysis of basic parameters, total and dissolved metals and petroleum hydrocarbons. The surface water sample results were compared to the Australian and New Zealand Environmental Conservation Council (“ANZECC”) Fresh and Marine Water Quality Guidelines (ANZECC, 2000) to indicate ecosystem disturbance and the groundwater samples were compared to World Health Organization (“WHO”) Guidelines for Drinking Water Quality (WHO, 2008) for public health limits. The surface water sample results showed moderate acidic to near-neutral pH ranging from 4.7 to 6.5 and generally low metal concentrations. Elevated levels of aluminium were recorded, however, exceeding ANZECC guidelines (0.05 mg/l) in 5 out of 7 samples. The average aluminium concentration across the sites was 0.29 mg/l and the maximum reached 0.79 mg/L. Nitrate concentrations were above the ANZECC guideline of 0.7 mg/l at one sampling point (3.9 mg/l) and minor exceedances of ANZECC guidelines were recorded for copper and zinc at three points. Total petroleum hydrocarbons were analysed in four of the surface water samples. Two points were characterised by elevated TPH concentrations. This was mainly found to be the C6-C40 fraction, which is associated with petrol and diesel compounds and the C24-C40 fraction, which is associated with residual fuels (for example fuel oil, lubricating oil, mineral oil and asphalt). In addition, elevated concentrations of the C16-C24 (354 µg/l) and C10-C16 fractions (85 µg/l), associated with diesel range organics, were found at one point. Groundwater samples showed a moderately acidic to near-neutral pH ranging from 4.7 to 6.7. The electric conductivity of 34 µs/cm to185 µs/cm for the samples indicates low salinity. The groundwater samples were generally characterised by low metal concentrations with parameters falling below the WHO drinking water quality guideline limits. Total petroleum hydrocarbons were below the limit of detection in the samples. 5.6 Soils The soils of Sierra Leone are recognised as being generally ferrallitic in nature. The soils of the lowland regions in the coastal plains are characterised by seasonal water logging, inadequate drainage and elevated iron and aluminium contents (NSADP, 2009). Soils are generally red to yellow-brown in colour and acidic (pH 4-5) in nature due to frequent water logging. Stobbs et al. (1963) recognise the soils in the lowland regions of Sierra Leone can be classified into one of four groups: • Oxisols (also referred to as ferrallitic soils) – these highly weathered soils consist primarily of hydrated oxides of iron and aluminium and are characterised by low organic matter content. Their low residual primary mineral content results in a low cation exchange capacity (CEC). The soils are typically red-brown in colour. • Groundwater laterites – characterised by poor drainage, high acidity and horizons with elevated sesquioxide (iron and aluminium) concentrations. Generally characterised by low organic matter content. • Acid gleysols (also referred to as hydromorphic soils) - these acidic soils (typically grey in colour) are annually flooded and are characterised by seasonal anoxic conditions. U3823_Marampa_ESIS_Final.docx September 2012 Page 90 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Hydormorphic processes are dominant and the leaching of soluble ferrous iron from the soil profile results in its distinct grey coloration. • Alluviosols – these are generally young soils confined to levees and are characterised by a good fertility as a result of the high nutrient content. Figure 5.7: Locations of groundwater and surface water monitoring points U3823_Marampa_ESIS_Final.docx September 2012 Page 91 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report The soils in the vicinity of the Marampa region can be broadly classed as ferrallitic soils (oxisols) and have low soil erosion potential, although this may be enhanced by high and intense rainfall, land clearance and removal of vegetation cover. A soil baseline study was undertaken by SRK (see SD 5 of Volume 3 for full study report) to determine the physical and chemical characteristics of the soil and sediments specifically located within the study area and assess the potential productivity of the soils based on soil structure and nutrient status. A total of 21 soil samples and 11 sediment samples (including duplicates for QA/QC) were collected for chemical and physical characterisation in March 2011 (Figure 5.8 shows sampling technique and Figure 5.9 the sampling locations). Soil samples were collected from areas likely to be disturbed by the placement of Project-related infrastructure, around the boundary of the London Mining concession, and agricultural areas. Sediment samples were collected from locations downstream of potential operations or proposed waste storage facilities. The soil and sediment samples (in the <0.05 mm fraction) were analysed at Scientifics laboratory (Burton-on-Trent, UK) for chemical and physical characteristics. Analysis of the >0.05 mm fraction was carried out by Soil Mechanics Ltd (Bristol, UK). Figure 5.8: Soil sampling using hand auger U3823_Marampa_ESIS_Final.docx September 2012 Page 92 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 5.9: Soil and sediment sampling locations 5.6.1 Soil quality The soils were classified based on particle size using the United States Department of Agriculture (“USDA”) soil classification system. The chemical results were compared to three times crustal average abundance of elements (Mason, 1966) and the Canadian Council of Ministers of the Environment, 2007 (“CCME”) soil quality guidelines for protection of environmental and human health. The solution chemistry during the leach tests was U3823_Marampa_ESIS_Final.docx September 2012 Page 93 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report compared to IFC EHS guidelines for Mining (2007) to determine whether leaching of the soils is likely to result in release of contaminants at concentrations above international effluent discharge guidelines. The majority of soil samples collected during the survey were classified as sandy loam (USDA soil classification), due to the large proportion of sand (60%), with smaller proportions of silt (33%) and clay (1.5%). There was limited variation in soil texture across the study area. The moderate proportion (average: 46%) of fine particles (particle sizes < 0.1 mm) in the samples indicated a potential for soil erosion however the moderate organic content indicates the potential for erosion is low. The soils were found to be moderately acidic in nature (pH 4.7 to 5.8), with a low cation exchange capacity (10.5 to 19.7 meq/100g) and are dominated by iron and aluminium. These are typical characteristics of soils in humid regions of the tropics, where the high chemical weathering rates and high rainfall result in intense leaching of soil bases. The organic matter content of the soils was found to vary from 1.19% to 5.09%, with cultivated soils generally being characterised by a lower organic matter content (<2%). Levels of the essential plant nutrients nitrogen and phosphorus were found to be generally within typical levels for well drained soils, indicating the soils have good agricultural potential. The majority of soil parameters were below CCME soil quality guidelines apart from boron, selenium and chromium, but the cause of these exceedances is thought to be natural. The moderately acidic pH of the soils is outside the CCME recommended range of 6 to 8 s.u. in all samples collected. Soil leachates were circum-neutral (pH 6.6 to 8.0). Most constituents were leached at very low concentrations, with many parameters being at or near analytical detection limits in the leachates. Iron and zinc were the only parameters to exceed IFC standards in the leachates. For iron, exceedances were noted for 12 samples (from a total of 21) in the first stage of leaching and for two samples in the second leaching stage. Exceedances for zinc were observed for three samples in the first stage of leaching. All other parameters were significantly below IFC standards. These low levels of leaching observed in the laboratory tests are likely to be a function of the prevailing environmental conditions in the field; the high levels of rainfall will have pre-flushed the soil column meaning that any readily-mobile constituents will have leached out in-situ. However, iron and zinc showed the potential to be leached from the soils. 5.6.2 Sediment quality The sediment samples were generally characterised by higher gravel and lower silt content. The particle size distribution is likely to relate to the predominant river flow regime in the location the sample was taken; areas of fast flowing water characterised by gravelly sands and areas of low flow characterised by higher silt content. Sample locations are shown in Figure 5.9. The sediments were found to be mildly acidic to circum-neutral (pH 5.3 to 6.5) and are dominated by aluminium, manganese and iron, reflecting the geology of the local area. With the exception of boron, all parameters were present at concentrations not exceeding the three times average crustal concentration. In addition all parameters were detected at concentrations lower than CCME sediment quality guidelines, with the exception of chromium which was found to be elevated in two samples (MSd005 and MSd006) collected from the Rokel River. U3823_Marampa_ESIS_Final.docx September 2012 Page 94 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 5.7 Air Quality An air quality baseline study was undertaken by specialists from SRK (SA) to measure the baseline ambient conditions from which air quality impacts can be predicted (see SD 2 of Volume 3 for the full study report). The monitored pollutants (sulphur dioxide, nitrogen dioxide, particulate matter and dust fallout) were chosen based on the expected emissions from the planned operations and the level of risk to human health posed by these pollutants. Air quality sampling was carried out at numerous locations around the mine site (Figure 5.10 shows locations of particulate matter, dust fallout and gas monitoring points) for the following parameters as per the programme summarised in Table 5-3. Table 5-3: Air quality baseline monitoring programme at mine site Parameter Sampling locations Method Frequency Analysis Dust fallout MIOL Office (Lunsar), Sample Monthly (exposure for Sealed buckets Catholic School, Konta buckets that 4 weeks) sent to Bana, Maso, Matukia, were sealed Mhlathuze Mafuri, Magbungbu, and Water (South Marampa Guest House swapped Africa) Particulate MIOL Office (Lunsar) with new Continuously Mhlathuze matter (PM buckets after Water (South 10 30 days. and PM ) Africa) 2.5 Sulphur MIOL Office, Konta Bana, Radiello Quarterly (3 monthly) M&L dioxide (SO ) Natukia, Mafuri, Magbungbu passive gas Laboratory 2 (24-hour exposure Services monitoring period) Nitrogen MIOL Office, Konta Bana, badges with Quarterly (3 monthly) M&L dioxide Matukia, Mafuri, Magbungbu absorbent (1-hour exposure Laboratory (NO ) gas Services 2 cartridges. period) Air quality results were compared to the World Bank/IFC guideline on emissions and ambient air quality, US EPA standard for air quality monitoring and South African National Standards (SANS) for dust deposition, as Sierra Leone does not have a standard for air quality. The measured NO and SO concentrations are below both IFC and US EPA standards in all 2 2 3 locations, except at the MIOL offices in June 2011 were a SO2 concentration of 21.7 µg/m 3 was measured. This slightly exceeds the World Bank/IFC SO2 guideline value of 20 µg/m 3 (but falls below the US EPA standard of 370 μg/m ). The higher SO concentrations in 2 Lunsar, Magbungbu and Mafuri are attributed to higher vehicle circulation in Lunsar town and the villages and other anthropogenic activities. The NO concentrations were very low across 2 the sample locations. The highest concentrations were in Magbungbu, Mafuri and Matukia attributed to biogenic release from the burning of sugar cane plantations, the major agricultural activity in the area. The highest NO2 concentration measured was 7.05 μg/m3 in June 2011 at the MIOL offices in Lunsar, falling below the World Bank/IFC Guideline of 200 3 3 μg/m and the US EPA standard of 190 μg/m . Baseline SO and NO levels suggest the level 2 2 of these gases in ambient air is low. U3823_Marampa_ESIS_Final.docx September 2012 Page 95 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 5.10: Air quality and noise monitoring locations Eight dust monitors were situated around the study area to determine the spatial coverage of dust fallout. The fallout results for June to November 2011 (corresponding with the wet 3 season) were consistently below the SANS target level of 300 mg/m /day at all monitoring locations. Results for December 2011 to March 2012 (corresponding with the dry season) showed a trend of exceedances of the action limits (and in some cases the alert thresholds) at U3823_Marampa_ESIS_Final.docx September 2012 Page 96 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 3 almost all locations. Most notable were Konta Bana (where a reading of 5,470 mg/m /day was 3 obtained for December 2011, exceeding the SANS alert threshold of 2,400 mg/m /day), 3 Matukia (where 11,886 mg/m /day was recorded in March 2012, again exceeding the alert 3 threshold), and Mafuri (where 1,408 mg/m /day was recorded in January 2012, exceeding the 3 Action Industrial threshold of 1,200 mg/m /day). These increased dust concentrations could be attributed to increased traffic or construction in these areas (such as the Magbungbu monitoring point, where construction for a railway and road was taking place nearby). PM10 levels were recorded at the MIOL Office in Lunsar between March and April 2012. The samples indicate daily PM10 concentrations are below both World Bank/ IFC Guideline and US EPA standards through most of the year. However there were 89 exceedances of 24-hour 3 PM10 guideline concentrations of 50 μg/m during the monitoring period, eight of which 3 exceeded the US EPA standard of 150 μg/m . All exceedances occurred during the dry season (November 2011 – February 2012), suggesting that dust generating activities increased during that period, and possibly also the influence of the Harmattan winds, which occur at this time of year. Average daily PM2.5 concentrations were measured between March 3 and July 2011 (study cut short due to technical errors), and were high (21 to 26 μg/m ) in 3 March and April, exceeding World Bank/IFC Air Quality Guideline of 20 μg/m . This high level is attributed to increased vehicle entrainment of dust and windblown dust from the roadside, during the dry season. Samples from May to July 2011 were below the daily guideline levels. The 24-hour PM2.5 concentrations show 37 instances where the 24-hour World Bank/IFC air 3 quality guideline of 20 μg/m was exceeded, over the 127 days of data recording. The US 3 EPA standard of 35 μg/m was exceeded for 6 instances during the period. The highest 3 concentration during the monitoring period was 50 μg/m recorded on the 9 April 2011. In summary, the air quality around the Project is of a generally good standard with regard to NO and for the majority SO concentrations. Dust fallout and PM concentrations show a 2 2 10 strong seasonal trend, are within acceptable levels for international air quality standards during the wet season but showed exceedances (in some cases exceeding the alert threshold for dust fallout) during the dry season. The high PM2.5 concentrations indicate that sensitive human receptors within the study area may be at risk of respiratory diseases as the World Bank/IFC guideline on air quality was exceeded. As these results were only collected at one site (MIOL Office, Lunsar), the rural areas closer to the mine site may differ. Due to the absence of large industrial plants or highways in the area and wind speeds being low, the main air pollution sources were windblown dust (natural pollution) and vehicle entrainment of dust. Vehicular movement was higher around Lunsar than other monitoring stations, evidenced by higher SO levels recorded in Lunsar. 2 5.8 Noise Noise surveys were carried out to determine background noise levels and to provide input to predictive noise modelling required to evaluate potential impacts from the Project. The Project area is made up of acoustically soft ground which absorbs sound waves; however the low-lying topography lacks barriers to noise propagation. The main existing noise sources are traffic through Lunsar and the surrounding areas, and community noise (in the villages). Noise monitoring was conducted by specialists from SRK at four locations, shown in Figure 5.10, in March 2011 (see SD 3 in Volume 3 for the full specialist report). The monitoring sites were selected to represent different parts of the Project area and were located in village or town centres to represent sensitive receptor locations. All measurements were conducted U3823_Marampa_ESIS_Final.docx September 2012 Page 97 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report using Svantek brand Svan 949 model Type-1 sound level meter (“SLM”). The microphone was covered with a sponge protector to reduce wind noise effects and set up 1.5 m above the ground. Automatic measurements were taken on an hourly basis over a 24 hour period at each location. No noise regulations exist in Sierra Leone so the World Bank/IFC noise guidelines for residential, institutional and educational receptors were used. Table 5-4 shows the IFC night time noise guidance level was exceeded at all locations, and the daytime level was exceeded in Makomp and Rogbesseh. The difference in day and night noise levels appears to be negligible. As no busy highways or industrial establishments are present in the area, the high noise levels are attributed to community noise. Noise levels differ in Lunsar as it is a large town with differing community activity patterns. Although Lunsar is more crowded and active than the villages, the activity is widespread in comparison to small villages where the activities are concentrated. Rosint is the smallest village with the lowest population, which may explain the lower noise levels. The results are based on hourly measurements conducted over 24 hour periods in March 2011 only. Community activities depend on the hour, day of the week and month so further noise measurements should be recorded at a different time of year to observe potential variations in baseline levels. Table 5-4: Baseline noise level measurements March 2011 (dBA) IFC Guideline Parameter Period (exceedances Lunsar Makomp Rogbesseh Rosint shown in red) LA, min 24 hours 36.8 31.4 29.8 25.3 L 24 hours 43.5 42.9 40.0 39.6 A, 90 L 24 hours 49.8 56.0 54.3 50.6 A, eq (24h) L 24 hours 51.2 57.9 55.6 53.1 A, 10 LA, max 24 hours 86.3 93.0 93.9 81.9 L 07:00 - 22:00 55 50.3 57.6 58.0 52.9 A, day L 22:00 - 07:00 45 49.8 53.9 52.6 47.3 A, night 5.9 Biodiversity A rapid biodiversity assessment was undertaken by ECOREX Consulting Ecologists between th st st th 18 and 21 October 2010 (wet season) and 21 and 24 February 2011 (dry season) to summarise the baseline conditions of the Project area, which is located within the Western Guinea Lowland Forests terrestrial ecoregion and the Northern Upper Guinea aquatic ecoregion. A further round of dry season aquatic biomonitoring was conducted by Nepid Consultants in February 2012. Full copies of both the aquatic biomonitoring and biodiversity impact assessment reports are included as SD 4 in Volume 3. IKONOS satellite imagery was used to initially identify and delineate broad habitat types and land-use patterns within the study area, the boundaries of which were ground-truthed during the initial field visit. Sampling methods are described in detail in the specialist study reports. The assessment of terrestrial habitat types and faunal associations included the following activities: • Vegetation was sampled within each major habitat type using quadrants of 20 x 20 m to measure presence, cover and abundance. • Mammals were recorded incidentally while surveying vegetation and other faunal groups, through indirect evidence such as spoor or dung, in conjunction with limited visual or U3823_Marampa_ESIS_Final.docx September 2012 Page 98 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report audio confirmation. • Birds were sampled using the Timed-Species Count Method, identifying species seen or heard using binoculars or a digital recorder. • Reptiles were sampled through active searching along transects. The aquatic study focused on measuring biological receptors (benthic diatoms, aquatic invertebrates, and fish) that are sensitive to changes in water quality at different temporal scales, as a measure of aquatic ecosystem health. Data was collected from 16 sampling sites (including five sites identified for long-term biomonitoring) in and around the Project area (Figure 5.5 shows locations). The sampling methods for assessing the aquatic receptors included the following activities: • Assessment of river flow conditions (to assist with habitat classification), • Assessment of water quality (major cations, anions and metals), • Benthic diatoms were assessed using the Specific Pollution Sensitivity Index (SPI), • Benthic aquatic macro-invertebrates were assessed through the Namibian Scoring System version 2 (NASS2) bio-monitoring method, • Fish were sampled using a 30 x 30 cm hand-net during the November 2010 sampling round, and seine and double fyke nets during the February 2011 sampling round. Sampling was supplemented by examination of fisherman’s catches. The conservation status of species identified was determined using the IUCN Red List of Threatened Species (IUCN Red List), the Global Biodiversity Information Facility (GBIF) database, Fishbase, and other reference documents for species in the area (Hawthorne & Jongkind, 2008; Kingdon, 1997; Van Cakenberghe et al., 2009; Borrow & Demey, 2002; and Frost, 2010). The presence of critical habitat was determined in accordance with IFC Performance Standards definitions. 5.9.1 Terrestrial habitats and faunal associations Six types of terrestrial habitats were defined within the study area; secondary forest/ farmbush mosaic, rice wetlands, lowland forests (which includes gallery forest and swamp forest), flooded natural grassland, and secondary savannah. The predominant habitat types are secondary forest / farmbush and rice wetlands, reflecting the transformed and disturbed nature of the habitats within the study area. Photographs of these six habitat types are shown in Figure 5.11 and the spatial distribution is shown in Figure 5.12. Based on the information available from the surveys, no critical habitat was identified at the locations sampled during the baseline, with respect to home range, feeding, breeding or nesting of the species present. Secondary forest / farmbush: this habitat type covers approximately 75% of the study area and the present ecological state of this habitat is classified as considerably modified. The state of regeneration is more advanced within some parts of the study area (i.e. Area 3). The secondary vegetation is dominated by Oil Palm (Elaeis guineensis) and scattered large Mango (Mangifera indica), Kapok (Ceiba pentandra) and Gold Coast Bombax (Bombax buonopozense) trees. Species composition is dominated by widespread species that are typical colonisers in secondary regrowth. The invasive exotic species Triffid Weed (Chromolaena odorata) has become well established in many areas. U3823_Marampa_ESIS_Final.docx September 2012 Page 99 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Secondary forest / farmbush Rice wetland Gallery forest Flooded natural grassland Swamp forest Secondary savannah Figure 5.11: Photographs of terrestrial habitats within the study area This habitat supports the most widespread bird assemblage, with 122 bird species observed during the field visits (65% of the species observed). The most abundant species were Blue- spotted Wood Dove, Common Bulbul, Whistling Cisticola, Pied Crow and Red-eyed Dove. Rice wetlands: this habitat type covers almost all valleys (approximately 15% of the study area) and the present ecological state of this habitat is classified as considerably modified. There are narrow ecotones (regions of transition) between the rice paddies and terrestrial vegetation that contain remnants of original grass flora, of which Anadelphia leptocoma is most prominent. U3823_Marampa_ESIS_Final.docx September 2012 Page 100 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 5.12: Distribution of terrestrial habitats across the study area The lack of structural diversity in rice monocultures and the lack of open waterbodies reflects the fairly low bird assemblage within this habitat (56 species). Ten species of forbs were identified in the rice wetland habitat, however these are fairly widespread generalist species. U3823_Marampa_ESIS_Final.docx September 2012 Page 101 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Flooded Natural Grassland: this habitat type is located adjacent to the swamp forest on the northern back of the Rokel River and the present ecological state of this habitat is classified as slightly modified. Anadelphia leptocoma is dominant at the slightly drier, higher-lying ground. Rhytachne rottboellioides is closely associated with Anadelphia, but occupies the flooded part of the wetlands. Where patches of open water are present, floating hydrophytes are common. As the majority of habitats within the study area are highly transformed, this habitat represents the only patch of untransformed natural grassland. Lowland forest: this habitat includes all gallery or riparian forest and swamp forest. Gallery forest is most developed along the banks of the Rokel River in narrow strips (up to 20-30 m). There are also narrower strips of this gallery forest along other perennial tributaries in the study area; however it is often fragmented and discontinuous. The present ecological state of gallery forest is classified as slightly modified. Gallery Forest is characterised by high species richness and 60% of the plant species found during fieldwork were located in this vegetation community. Gallery forests have high functional value in terms of providing flood attenuation and riverbank stabilisation. Swamp forests are located along a tributary of the Rokel River in Area 3. The species composition of the swamp forests is similar to that occurring in riparian forest along the Rokel River. The present ecological state of this habitat is classified as moderately modified; largely due to removal of vegetation for fuel and small-scale logging. However, the swamp forest does still have a moderately high functional value, such as providing flood attenuation and riverbank stabilisation. This habitat connects the larger forest along the Rokel River to the gallery forests higher up the main tributary. A total of 64 bird species were observed with the lowland forest habitats (36% of the species observed). The forest bird species include forest specialists (18 species), forest generalists (29 species) and forest visitors (17 visitors). Forest specialists are considered to have higher conservation significance, as these species are unable to adapt to disturbed forest conditions. Secondary savannah: this habitat type is located in the northern part of Area 3 and the present ecological state of this habitat is classified as considerably modified. Vegetation structure is Short Open Woodland (sensu Edwards, 1983) with a dense grass understory. The absence of Elaeis guineense (Oil Palm), which is an indicator species of former forest conditions when growing in open “savannah” (Bakshi, 1963), means that this community is most likely representative of true savannah. Whilst this habitat type only occupies a small proportion of the study area, it is well represented in large areas between Lunsar and Port Loko. Within this habitat bird species richness was found to be high, with 85 species observed. The bird assemblage within this habitat is distinctive in species composition and supports a number of species more typical of the Sudan-Guinea savannah biome. 5.9.2 Terrestrial species of conservation significance During the field visits, the presence of three plant species of conservation significance was confirmed, all of which are restricted to forest habitat. Based on the habitat types within the study area, it is likely that other plant species of conservation significance, including three wetland species, three aquatic species and three forest species, may also be present. One Near Threatened mammal was confirmed within the study area, the Straw-coloured Fruit Bat, which can range widely over wooded habitat in the study area. Three other species have a high-moderate likelihood of occurrence based on their preference for habitats within the U3823_Marampa_ESIS_Final.docx September 2012 Page 102 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report study area – the Tree Pangolin (found in secondary forest / farmbush), and the Diana Monkey and Sooty Mangabey (both occurring in lowland forest). No bird species of conservation significance were observed during the field visits. However, five near threatened and one data deficient species have a moderate likelihood of occurrence in the area. Two of these (raptors) are most likely to be associated with over broad grassy valleys, two species are likely to be associated with edges of dense forest, and the fifth species is most likely to occur in flooded natural grassland or along grassy edges of rice wetlands and so could occur anywhere in the drainage lines of the study area. 5.9.3 Aquatic habitats and faunal associations Five types of aquatic habitats were identified within the study area by Ecorex during their wet season survey; seasonal valley head wetlands, seasonal mid-slope wetlands, perennial mid- slope wetlands, perennial upper foothill streams and perennial lower foothill river. However, following the February 2012 dry season survey by Nepid, due to the absence of flow in rivers previously classified as perennial, the classification of two perennial habitats was changed to seasonal, reducing the number of habitats to four. The classification presented below is therefore the revised classification by Nepid and differs slightly from that presented in the Ecorex report. Photographs of these habitat types are shown in Figure 5.13 and the spatial distribution is shown in Figure 5.14. Based on the information available from the surveys, no critical habitat was identified at any of the locations sampled during the baseline (due to the fact that the conservation status of one of the species identified is being downgraded). Seasonal valley head wetlands: these are low-gradient, stream-source wetlands. The wetlands within the study area were transformed, mainly by cultivation of rice, however they were structurally intact. There was no evidence of erosion or incision of the main channels. The present ecological state of these wetlands is classified as moderately modified. These wetlands do not provide dry season baseflows, so they are unlikely to be important for streamflow maintenance. The ecological importance of this aquatic habitat is related mainly to high numbers of fish from the families Nothobranchiidae and Poecilidae. Within this habitat 11 species of fish were recorded, the most common being the Nothobranchid Epiplatys lokoensis. This species is classified as Endangered by the IUCN, however it appears to be unaffected by rice cultivation and may have even benefited from this change in landuse. Seasonal mid-slope wetlands: these are low-gradient, mid-slope wetlands, usually with a defined channel and open-canopy riparian margins. The present ecological state of these wetlands is classified as moderately modified. These wetlands do not provide dry season baseflows, so they are unlikely to be important for streamflow maintenance. Most of these wetlands were used for cultivation of rice. U3823_Marampa_ESIS_Final.docx September 2012 Page 103 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Seasonal valley head wetland (wet season) Seasonal mid-slope wetland (wet season) Perenial lower foothill river Seasonal upper foothill stream (wet season) Figure 5.13: Photographs of aquatic habitats within the study area Their ecological importance is related mainly to high numbers of fish from the families Nothobranchiidae and Poecilidae. Eleven species of fish were collected in this habitat type, of which the most common and widespread was the poecilid Poropanchax normani. During their wet season survey, Ecorex also identified Perennial mid-slope wetlands, most prominent along the middle and lower reaches of the Baki Stream. Subsequent revision in this classification by Nepid resulted in the habitat being reclassified as seasonal mid-slope wetlands. Due to slight differences in habitat characteristics and species makeup, a brief description of the perennial mid-slope wetlands as originally identified, is provided. Instream habitats included closed (shaded) and open (sunny), shallow-fast, shallow-slow and deep- slow areas, usually with an abundance and high diversity of submerged and emergent aquatic vegetation. Their ecological importance is related to the diversity of instream habitats and associated fauna. Twelve species of fish were recorded within this habitat type, with characteristic species being barbs (Barbus macrops and B. leonensis) and alestids (Brycinus spp). Most of these wetlands within the study area had been transformed by deforestation and cultivation of rice. U3823_Marampa_ESIS_Final.docx September 2012 Page 104 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 5.14: Distribution of aquatic habitats across the study area and locations of baseline and biomonitoring sampling sites Seasonal upper foothill streams: the lower Morea Stream was the only area classified as a Seasonal Upper Foothill Stream. The present ecological state of these wetlands is classified as moderately modified. This stream supports a wide diversity of aquatic habitats, including stones in and out-of-current, deep pools with bedrock substrate, gravel bars, aquatic U3823_Marampa_ESIS_Final.docx September 2012 Page 105 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report vegetation and marginal vegetation in and out-of-current. This stream was originally classified as “perennial” in the Ecorex Biodiversity Impact Assessment Report following the wet season survey but this classification was revised to “seasonal” following the dry season aquatic biomonitoring survey by Nepid. Seven species of fish were recorded in the Morea Stream, with the characteristic species being banded jewelfish (Hemichromis fasciatus) and the anabantid (Ctenopoma kingsleyae). Perennial lower foothill river: the Rokel River in the vicinity of the study area is about 130 m wide, and is classified as a Perennial Lower Foothill River. Instream habitats include deep pools, rapids, sand bars, backwaters and margins with tree roots. The Bumbuna Hydroelectric Facility, located about 90 km upstream, could have a significant impact on the river, particularly during the dry-season. A total of 32 species of fish was recorded in the Rokel River during this study. The most diverse families recorded were cichlids (13 species) and mormyrids (10 species). The high diversity of fish indicates the river is in excellent ecological health. 5.9.4 Aquatic species of conservation concern During the field visits, the presence of one species of conservation significance was confirmed. This is Epiplatys Iokoensis (Endangered), which was found within the seasonal valley head wetlands. The conservation status of this species is currently being downgraded based on more recent information regarding this species. Based on the habitat types within the study area and previous studies within these areas, other aquatic species of conservation significance may be present. Marcusenius meronai (Endangered) has been recorded in the Bagbé and Rokel Rivers; Tilapia joka (Vulnerable) has been recorded in the Rokel River; Sierraia leonensis (Vulnerable) a species endemic to Sierra Leone; and Scriptaphyosemion roloffi, a species found mainly in the shallow and stagnant parts of pools, brooks, swamps and small streams in the coastal rain forest, and is known from the Little Scarcies River drainage system in Western Sierra Leone southward to the drainage system of the Lower Lofa River in Western Liberia (Lalèyè 2006). A number of Endemic species are also likely to be present. 5.9.5 Aquatic ecosystem health The findings of the February 2012 (dry season) aquatic biomonitoring survey are summarised below. Sampling sites referenced are shown in Figure 5.13. Water quality: data indicated elevated concentrations of manganese at sampling site A2-2. The other variables analysed were within recommended limits for drinking water and protection of aquatic ecosystems. Diatom analysis: the biological water quality was indicated to be Natural (Category A) at four of the five sites monitored, and slightly modified at site A3-5, and heavy metal concentrations to be below thresholds for biological concern. Aquatic invertebrates: the composition and abundance of aquatic invertebrates varied greatly amongst sampling sites and seasons, attributed mainly to differences in surface flow. Limited data regarding existing impacts could be obtained. Fish: the composition of fish species indicates significant deterioration in ecological conditions (Category B to category E) at Site A2-2 since the October 2010 sampling round. This is attributed to disturbance and sedimentation of the stream due to road construction in U3823_Marampa_ESIS_Final.docx September 2012 Page 106 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report the neighbouring mining concession (see Figure 5.15). Inadequate culvert design in the road was also cited as a problem in terms of fish passage and sedimentation of rivers. Excessive sediment in the Morea Stream - Poorly constructed culvert with inadequate February 2012. capacity - February 2012. Figure 5.15: Impacts on streams due to road construction on neighbouring concession area U3823_Marampa_ESIS_Final.docx September 2012 Page 107 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 6 SOCIO-ECONOMIC BASELINE DESCRIPTION This Chapter is based on the: • Socioeconomic Baseline Report, Marampa Iron Ore Project, SRK Consulting (UK) Ltd, February 2012 (SRK 2012ab specialist report in Volume 3, SD8); • Rural Livelihoods Specialist Study: Phase 1 – dry season survey findings, Wild Resources Ltd, May 2012 (WRL 2012 specialist report in Volume 3, SD8); and • Cultural Heritage Component of the Environmental and Social Impact Assessment, Marampa, Sierra Leone Nexus Heritage and IFAN, April 2011 (Nexus 2011 specialist report in Volume 3, SD8). The baseline studies were conducted in adherence with Sierra Leone legislation and international good practice guidelines from The World Bank and the International Finance Corporation (“IFC”) on social assessments. The study area for the baseline included three areas; Area 1 covers the potential locations of the processing plant, power generators, auxiliary infrastructure, a tailings storage facility and waste rock dumps; Areas 2 and 3 cover the geological target zones. Two corridors of approximately 100 m will be used for transporting the ore from the potential mining areas in Areas 2 and 3 to the processing infrastructure in Area 1 (Figure 6.1). Subsequent to the household survey being completed, in March 2011, the Project layout increased in area and the study areas were amended to accommodate these changes. It was discovered that Maso and Magbungbu villages, which were added to the list of affected villages, were not part of the household survey. However as the survey was based on a sample the findings are considered representative of the Project area villages. Maso and Magbungbu were included in the sample for the Rural Livelihoods Specialist (RLS) study survey held in March 2012. The villages covered in the survey for the two studies are presented in Figure 6.1. 6.1 Approach and methodology The specialist studies are based on primary and secondary sources of information and data. Secondary data was collected from the internet existing reports and articles and is referenced in the footnotes. Primary data was collected directly from community members, local government and non-government functionaries. For the socio economic study, data collection methods consisted of a household survey, individual interviews, village information sheets, stakeholder group interviews and observations (31 March – 6 April 2011). For the RLS study (phase 1) the data collection methods consisted of village focus group surveys and interviews; field survey, GPS recordings and survey of commercial activities related to natural resource use. Primary data was collected during 14-21 March 2012, in the dry season. The data collection methods, assumptions and limitations are described in the specialist baseline reports. U3823_Marampa_ESIS_Final.docx September 2012 Page 108 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 6.1: Location of villages covered under household survey and rural livelihoods study U3823_Marampa_ESIS_Final.docx September 2012 Page 109 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 6.2 Population 2 The Port Loko District where the Project is located covers an area of 5,719 km with a population of approximately 478,000. The Project is located in the Marampa Chiefdom, which 8 has a population of approximately 40,000 (2010) . However, the Project’s area of influence also covers the, Masimera and Maforki Chiefdoms. 6.2.1 Population in the study area Population figures for the study area are based on the village survey (Table 6-1). Table 6-1: Population in the study area villages Village name Males Females Total Number of Average Population households family size Gbese 120 134 254 23 11 Kalangba 68 65 133 15 9 Katick 171 162 333 35 10 Konta 71 75 146 11 13 Konta Bana 216 187 403 34 12 Konta Lol 19 18 37 7 5 Ma Sesay 4 3 7 2 4 Mafira 53 41 94 15 6 Mafuri 93 85 178 23 8 Magbafat 267 275 542 34 16 Marunku 260 259 519 40 13 Matukia 139 253 392 98 4 Mebesseneh 1208 1227 2435 259 9 Moria 12 5 17 2 9 Rogbaneh 86 84 170 14 12 Rolal c/o Maforay 45 47 92 15 6 Rosint 47 57 104 20 5 Total 2879 2977 5856 647 9 Source: SRK Village survey April 2011 The villages have an average size of 38 households, and the average population is 344. 49.2% of the population are males and 50.8% are female, which is indicative of the larger number of males killed in the civil war. The household survey indicated that 42% of the population is below the age of 15, 54% is between the ages of 15 and 64, and 4% is above the age of 64 6.2.2 Ethnicity There are 16 ethnic groups in Sierra Leone; the two largest groups are the Mende and the Temne. The dominant group in the Project area is Temne other groups include Limba, Mende and Kono. The official language spoken in schools and government administration is 9 English , though a majority of people mainly speak Mende, Temne or Krio. The main religions are Islam (60%) and Christianity (30%) and indigenous religions (10%). 8 As per the records from the Peripheral Health Unit (PHU), Lunsar (interview 5 April 2011) 9 Britannia Concise Encyclopaedia: Sierra Leone U3823_Marampa_ESIS_Final.docx September 2012 Page 110 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 6.3 Economy The main economic activities in the Port Loko District are small scale diamond mining, subsistence farming, production of charcoal, small businesses and small scale fishing. Table 6-2 presents the number of people engaged in different livelihood strategies across the study area villages. Table 6-2: Distribution of livelihood strategies (aggregated for all study villages) Village Total persons Percentage Agriculture 2095 82% Charcoal 955 37% Animal Husbandry 813 32% Fishing 714 28% Plantation 227 9% Beekeeping 183 7% Herder 153 6% Hunting 151 6% Herbalist 52 2% Artisan 60 2% Artisanal mining 52 2% Driver/mechanic 57 2% Government employee 18 1% Brewing 25 1% Commerce/shop/ 7 0.30% Source: SRK household survey April 2011 An overwhelming majority of people are engaged in farming (82%). In most cases other economic activities are undertaken in addition to farming (hence the overlap in percentages in the table). Other popular occupations in the study villages are charcoal making (37%), animal husbandry (32%) and fishing (28%). Further information on the characteristics of different livelihoods strategies is provided in Section 6.3.1. 6.3.1 Description of livelihoods in the study area This section, based on the rural livelihoods study (WRL, 2012), presents information on the nature of livelihood activities in the study area. It is mainly based on the RLS dry season survey and SRK household survey, and will be further supplemented by a wet season RLS survey in August 2012. Agriculture The sale of cash crops is probably the most readily accessible income for most villagers however, most farmers keep what they grow for household consumption. Produce can be sold within the villages, or taken to the daily market in Lunsar or weekly Tuesday market in Foredugu. Some of the generic problems with marketing agricultural produce include the lack of transport. Traders apparently visit the villages with vehicles to buy up larger quantities of produce, usually at relatively low prices and there are also wholesalers based in Lunsar. The agricultural season begins with preparation of fields in January to March, followed by planting mainly during April to July. Cutting of trees and charcoal making is usually done in April before the start of wet season. Harvesting begins in September thus the hungry period U3823_Marampa_ESIS_Final.docx September 2012 Page 111 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report can last from May to August. The main harvesting goes on till November/December. The agricultural potential in the Project varies depending on the land type. Topographic relief in the Lunsar area is subdued, and wide, flat river valleys meander across it. The height difference of just a few metres makes a significant difference to soil fertility, wetness and suitability for different crops and farming systems. During focus group discussions it became apparent that there are complex interactions between the use of different landscape units, crops and crop varieties as outlined below. • Inland valley swamps: The flat-bottomed valleys, often termed ‘inland valley swamps’, are characterised by hydromorphic soils with high clay content and low infiltration rates which, coupled with a shallow gradient, means they are flooded for much of the rainy season. In-wash of nutrients by the river and from valley sides means soils are relatively fertile and suited to rice cultivation. In some places (e.g. Masu) the flow and depth of water is controlled by the installation of contour-bunds. In the narrow, valley-head wetlands, headwater valleys and contour bunds are not used and different varieties of rice are utilised to take advantage of natural water levels. In the dry season, the soil is very difficult to work by hand. Most inland valley swamps are cultivated continuously. Examples are shown in Figure 6.2. Perennial inland valley swamp with rice Irrigated mound gardens in runoff zone at end of dry season Figure 6.2: Photographs of different agricultural methods • Runoff zone: This is the narrow zone where the upland slopes meet the flat valley floor and is called tembe. The soils here are silty and difficult to work when dry. As the flood waters recede, the soil is thrown up using hoes into mounds (m'bof). These mounds are used to grow a variety of crops which are usually planted in March and harvested in June. At the end of the dry season wells are dug into the valley floor to irrigate vegetables on the mounds while cassava is planted as the rains start. As the water rises, the mounds keep the crops from becoming waterlogged. • Uplands: Upland areas are generally covered with trees. The interfluves between the valleys have gravelly clay loam soils which are freely draining, and, are suitable for a range of perennial and rain-fed crops. The farming cycle on the uplands begins with the clearance of a parcel of bush towards the end of the dry season (March/April). Trees are cut at about a metre off the ground and timber removed as needed. Once the rains start the land is sown with rice. Cassava is one of the commonest upland crops and is the only crop routinely grown as a monoculture. The main time for sowing in the uplands is April/May with harvesting in November. If cassava has been planted this may be left for U3823_Marampa_ESIS_Final.docx September 2012 Page 112 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report up to four years and harvested at need. During the fallow years, there is regeneration of secondary forest trees and the resulting poles are used to build houses, used as firewood or turned into charcoal. There is also some differentiation of the uplands. Much of this area has an over storey of oil palm but there are also groves of fruit trees some of which are under planted with shade-bearing crops. A farmer who has access to these landscape units and uses them to full advantage can reap five harvests of rice a year and ensure a near continuous supply of fresh foodstuffs. Nevertheless there is a ‘hungry gap’ in August (paya) at the height of the rains when the crops are growing and the previous harvest has been depleted. Cassava and firewood are sold at this time There are at least 26 crops grown in the study villages (WRL 2012), some examples are given in Figure 6.3. Most are for home consumption but several are also cultivated for sale in Lunsar. This agro-diversity helps the famers take advantage of the different opportunities presented to them. The principal staple crops are rice and cassava with a large number of varieties grown in the area (WRL 2012). Corn (Maize) and cucumber field Harvesting palm fruits Figure 6.3: Photographs of different crops Commercial farms A few farmers have capitalised on the opportunity for incomes from farming close to Lunsar and the markets to become commercial farmers. The commercial crops selling at a good price are cassava, aubergine, cucumber, pepper, tomato and pineapples. One farmer reported revenues of Le 200,000 per month and an annual income of over Le 1,000,000 just from cassava. Pineapples are the most valuable commercial crop and retail at 10,000 each, because they are considered to be a curative for typhoid. Peppers sell at Le 150,000 a sack. Livestock Livestock owned by the surveyed households is summarised in Table 6-3. 78% of the sample households reported keeping one or more type of livestock. There are dedicated herdsmen, specifically in Mafira Village, while elsewhere livestock is kept near the homestead and tended by the women. The average number of animals kept per household is only indicative as the actual number of animals owned varies according to household. U3823_Marampa_ESIS_Final.docx September 2012 Page 113 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 6-3: Livestock husbandry in the Project area Animals Percentage households Average number Percentage households possessing livestock livestock per household selling livestock Goats 41% 3 34% Ducks 21% 5 17% Sheep 36% 3 31% Chickens 79% 19 68% Source: SRK household survey April 2011 • Poultry: Chickens were observed free-ranging in all villages and are kept for eggs and meat. Most are for household consumption but some are sold. Poultry cages are made of woven basketwork, or occasionally of metal. One villager mentioned that the parasitic disease coccidiosis is a problem. Ducks (and their eggs) were mentioned as being used in sacrifices in various traditional religious ceremonies. • Sheep and Pygmy goats: Both sheep and goats were seen free-ranging in and around the study villages. There was little indication of any supplementary feeding, though in Matukia women mentioned providing rushes as fodder for livestock. To protect crops from domestic animals, low fences of palm fronds and bamboo are sometimes set up (Figure 6.4). • Pigs: The only pigs seen were on a demonstration farm in Royail. Six sows and six boars were being kept for breeding experiments. • Cattle: There were only a couple of observations of cattle in the study villages. The household survey (SRK 2011) recorded 11 herders in Marunku, 1 in Magbungbu, 6 in Maforay and 15 in Matukia. • Dogs: Dogs were also seen in most villages, kept either as pets, or occasionally used for hunting or driving pests from crops. Owners mentioned using herbal ‘charms’ to help train their dogs to hunt for certain animal species. Figure 6.4: Photograph of crops fenced against livestock Fishing Fishing is a significant activity in the study area and both locally caught fish and marine fish brought into Lunsar are an important source of animal protein. Although men, women and children are involved in fishing, each group tends to use a different method and it is the women who spend most time engaged in this activity (Figure 6.5). Fishing occurs throughout U3823_Marampa_ESIS_Final.docx September 2012 Page 114 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report the year, though women tend to fish in the dry season and men in the rainy season. The fishing methods used in the study villages include, nets impoundments, traps, hand lines and sieves. When small numbers of fish are caught, these are normally destined for family use. Larger fish, or bigger catches, may be sold fresh in the nearest village, or taken to Lunsar Impoundments Fish smoking activity in Gbese Village Figure 6.5: Photographs of different fishing related activities Use of wild plants People in the study villages rely on the resources available in their immediate environment. This means the houses are made from poles cut from farm bush (fallows), wild foods are eaten as snacks or as a source of sustenance in times of famine and extensive use is made of plants in traditional medicine (medicinal use represents 87% of the use of wild plants recorded, as traditional medicine is the primary source of healthcare in the villages). Estimating the importance of these resources requires measures of the volume consumed and whether there are suitable substitutes. Though there are no data on the quantities required it is possible to make some assumptions based on the nature of the use. • Traditional medicine: Pooling the ECOREX (McCleland & Palmer 2011) and WRL plant species lists gives a total of 241 plants, of which roughly half are used as medicines (Figure 6.6). The majority of medicinal plants are obtained from lowland forest, which is an uncommon habitat in the area and is probably only found within sacred bush. Several informants reported that the dry season is best for gathering medicinal plants. Honey is used as a medicine or tonic. Wild honey is collected once a year, at the end of the dry season (March—April). The typical yield for a hive is 9 - 14 litres. It is sold for Le 5,000 for half a litre. The only medicinal use of animals was a mention of chameleons. • Wild foods: Although the people of the study villages are good farmers they continue to make use of wild foods, which can be an important contribution to food security especially if it is available in gaps between crop harvests. In Marunku the women listed wild foods they collect in the dry season as: Bush yam (wild yam = Dioscorea spp), Banga or palm cabbage (unopened bud of palms), matanka (probably Sorindeia juglandifolia), malimbo (unidentified) and blakomba (probably Dialium guineense). • Construction materials: The material culture of the local people was traditionally entirely derived from local resources (Figure 6.6). Although building materials are changing many houses, especially those of poorer families, are still made using traditional materials. In most villages there were houses being made from mud blocks. U3823_Marampa_ESIS_Final.docx September 2012 Page 115 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report These are made by specialists from outside the village and cost Le 500 each plus food for the workers. The RLS study lists all the species recorded as being used now or in the past for house construction (WRL 2012). A more recent innovation is cutting large forest trees into planks which are then used in building, for furniture and for sale. Exploitation of these tree species is likely to be unsustainable. Wild leaves used as malaria medicine Banana fruit as malaria medicine Construction material for building a small house (walls in progress) Timber board making Figure 6.6: Photograph of medicinal plants and plants used for construction Firewood & charcoal 94% of the sample households reported using wood as the energy source for cooking. The list of species used as firewood includes fruit trees such as guava and mango and indicates there is pressure on the supply of firewood. A typical upland farm patch yields 10-15 bags of charcoal. The prices vary from Le10,000 in the village, Le12,000 in Lunsar to Le15,000 in Freetown. It appears that most of the firewood and charcoal is derived from clearance of fallow land, making it more sustainable. However, there is some evidence that trees in the bush (not associated with farm clearance) are also cut to make charcoal. Hunting and trapping To facilitate questioning on hunting activities, a small leaflet and flashcards containing images of 60 species was used. Analysis of the results shows that a small number of species are caught regularly, with a secondary group of species seen regularly by hunters but caught less often (RLS study, WRL 2012). During interviews, villagers drew a distinction between “hunting” and “trapping”. “Hunting” was considered a specialist activity, whilst everybody who U3823_Marampa_ESIS_Final.docx September 2012 Page 116 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report farmed also “trapped” both as a means of providing food, but also to control crop raiding pests. Men, women and children are involved in hunting/ trapping to different degrees. Little evidence of bush meat species was seen during the field visit, which suggested the level of hunting was low. Specialist hunters hunt throughout the year, but may be busier during the rainy season if providing crop protection to other farmers. The majority of the most frequently hunted species, e.g. Maxwell’s duiker, Brush-tailed Porcupine and Giant Rat can withstand high levels of hunting pressure. At present, it would appear that there are relatively few guns being used by hunters in the Marampa area. In Marunku, farmers mentioned paying young men up to Le100,000 to trap animals on their land. As an indication of the areas that local hunters might cover during a typical trip, one hunter was asked to carry a GPS tracker unit and to follow his normal hunting route. He covered approximately 16 km. The majority of trapping takes place during the rainy season. Trapping is mainly by wire- cable snares. Two other types of trap were also seen: a home-made dead-fall wooden box- trap used to catch Giant Rats and a spring-loaded break-back trap used for smaller rats and mice (Figure 6.7). Some specialist hunters also use nets and dogs to hunt. It was found that most trapping of animals takes place to protect farm crops. Crop protection is a critical and time-consuming task, particularly bird-scaring which involves children of school-going age. See the RLS study WRL 2012 for more information on hunting and trapping activities. Dead-fall box trap Spring break-back traps in market Figure 6.7: Photographs of different types of traps Labour Manual labour is the biggest single input into the farm economy. Labour requirements for inland valley swamps alone can exceed the labour capacity of farm families and a shortage of labour was the most frequent complaint from farmers. The villages utilise labour gangs but with differences in rates paid and descriptions of arrangements. Women also hire men directly to undertake specialist tasks. It will cost a woman Le25,000 to Le30,000 to have men cut trees on an upland plot and Le50,000 to have charcoal made for her. Trade in wild products With a few exceptions sales of crops are seasonal, so products listed in Table 6-4 are used to supplement incomes. Other natural resources sold by people in the study are ferrocrete blocks and sand. Commercialisation of wild resources in the study villages is relatively low. The only resources that appear to be threatened by over-exploitation are timber trees. U3823_Marampa_ESIS_Final.docx September 2012 Page 117 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report However, loss of threatened habitats and increasing demand may initiate commercialisation of medicinal plants, which could result in over-exploitation of this resource. Table 6-4: Traded wild products Product Value Market channels Nuts of Cola nitida Price Le5,000 to – Wholesale (sold by the hundreds) from Le8,000 for 100. Le villages, retailed in local markets. May 30,000 for a ‘load’ reach the ancient pan Saharan trade network for this product. Leaves of Hallea stipulosa, Le500 per leaf if sold Probably sold within Temne cultural group direct or as wrapping for Kola individually in Lunsar area nuts as traditional wedding gift Dried calyx (flower bud scale) Le2,000 for a handful Direct retail in Foredugu market. Some of Xylopia aethiopica used a wholesale into national markets via Lunsar. tea. Sell (available) in dry season. Fruit of Dialium guineense Le1,000 for a fist- Sold in Foredugu market cooked with sugar to make a sized lump sweet Poles (2 m long) of bundles of 12 sell for Sold in large volumes for building and Anisophyllea laurina – 12 poles Le15,000 in Lunsar scaffolding across Sierra Leone in a bundle Firewood – many species – Le6,000 – Le7,000 bundles of sticks Charcoal - bag Le10,000 - Le15,000 Village, Lunsar and national market chains. Prices depend on market and season (higher prices in rainy season) Fresh fruit of Sorindeia Sold to bring income to poor families juglandifolia and Diospyros heudelotii Honey – wild bee hives Le5,000 for half litre Retail in Lunsar and perhaps Foredugu Sand mining Sand mining from the Rokel River is a key economic activity (Figure 6.8). It has a high commercial value due to a demand from the construction sector. Men, women and children are engaged in different activities contributing towards collecting sand. Each truck load is sold at between Le300,000 to Le500,000. Boy collecting sand Trucks usually take the sand to the markets Figure 6.8: Photographs of sand mining 6.3.2 Value addition There is little opportunity to sell most crops in a processed form but there are a few opportunities for value addition as listed below, with some examples shown in Figure 6.9. U3823_Marampa_ESIS_Final.docx September 2012 Page 118 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Palm oil extraction process Soap for sale in Foredugu market (the vendor had come from Makene by transport) Figure 6.9: Photographs of value addition to crops • Food preservation and baking: Drying is an efficient means of preserving perishable foods especially in the dry season. In the case of chillies, processing did not add any value. Fresh chillies retailed at Le1,500 per handful and dried retailed at Le1,200 per handful. Baking can add value however there was no evidence of ovens in the area. • Cassava: Cassava is a crop which perishes quickly therefore much of it is sold processed. A sack of raw cassava tubers sells for Le20,000, while a sack of raw cassava turned into fufu sells for Le50,000. • Palm oil: There are two varieties of oil palm; the tall, wild trees are lower yielding but produce tastier, redder oil preferred by the local people and kept for home consumption. The short Massankey cultivars produce less desirable oil, which is sold as good quality kernel oil. The villagers sell the Massankey nuts to people in Lunsar who use them to make soap. The oil is decanted into yellow gallon containers and sold or stored for household use. • Soap making process: To make soap the oil is boiled with caustic soda bought from the market with Raphia palm leaves. The resultant soap is medium hard soap sold for Le1,000. • Charcoal: Figures from the farm questionnaires suggest it costs Le25,000 to have trees cut, Le50,000 for the charcoal burner to turn a farm plot into 10-15 bags of charcoal which then wholesale for Le10,000 each. This gives a cost of production of Le70,000, for a return of Le100,000 – Le150,000. • Artisans and specialist skills: There were remarkably few artisans encountered in the study villages, the skills of those encountered are described in Table 6-5 and some examples are given in Figure 6.10. 6.4 Land tenure In Sierra Leone, there are two main systems of land holding: freehold rights in the Western Area and a customary system in the provinces where land is principally owned and controlled by families or traditional leaders. In the study area villages customary land tenure rules apply. According to customary law, chiefdoms and communities hold the ownership of property and therefore a plot of land can never be owned freehold. Title to land is vested in families based on ‘first settler’ rights with a small number of families U3823_Marampa_ESIS_Final.docx September 2012 Page 119 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report controlling land in each village. Family land is vested in the family as a group, although family land tenure prevails in the area it is locally acknowledged that the Paramount Chief is the custodian of the land. Family land is allocated to individual family members and can also be ‘lent’ or rented to less privileged families or strangers in need of growing space. Less formal arrangements, whereby a farmer or a family “borrow” land, were observed. In the context of resettlement, national policy states that, as much as possible, land disposal or acquisition should not render a land title holder (including customary land ownership), his kith, kin and descendants completely landless, save in the case of compulsory acquisition in the public interest. Table 6-5: Artisans and specialist skills in the study villages Craft Resources used Markets and prices Broom Mid-ribs of young palm fronds (a common and • Lunsar 1,000 Le per broom makers essentially free resource). The ribs are stripped, • Village 500 Le per broom tied into bundles and dried. Made by women and men. Wood Mortar carved from Yemani (Gmelina arborea) and • Previously sold but now carvers pestle from K’bap (unidentified). Carver learnt trade made for household use. by watching people make them. Basket Men weave baskets from Raphia leaf stem for use • Baskets 2,000 to 5,000 makers by fish sellers, winnows and mats. Also make large depending on size woven granaries (~1.5 m tall x 1 m diameter with • Granary sells for 50,000 Le lids) to order. Blacksmith Makes cutlasses from vehicle leaf-springs with • Village & Lunsar 20,000 Le handles made from Holarrina africana and per cutlass Samanea dinklagei. Skills passed from father to son. Drum makers Body of drum made from Yemani (Gmelina • Sold on commission for arborea). Skill passed from father to son. around 20,000 Le for a drum Palm wine Almost exclusively done by Limba people. Men • Wholesale: Plastic jerry can makers work in groups and share equipment. They pay sells for 20,000 Le and 15,000 Le per month to farmer to tap trees. Taps costs 13,000 Le to make put into base of young leaves at top of tree and giving a profit of 7,000 Le emptied twice a day in morning and evening. for ten litres. • Retail in village: Bottle of palm wine sells for 1,000 Le Professional There is an opportunity for specialist hunters, • Rates seem highly variable hunters especially those with guns, or groups with nets and (20,000 – 100,000 Le), trained dogs, to provide pest control on farms on a depending on the services contract basis. provided. Any animals caught are kept by the hunters. Fishermen In villages on the Rokel river there may well be • Numerous small traders specialist fishermen who use the large dugout were encountered passing canoes and large hand-casting nets to catch fish, from the fishing villages of though this equipment may available to everyone. Mbla & Masu, having purchased fish from fishermen there. U3823_Marampa_ESIS_Final.docx September 2012 Page 120 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Brooms Wood carvings Baskets Drums A blacksmith in the Konta Village Fishing nets (a net takes a week to make and sells for Le 10,000) Figure 6.10: Photographs of artisanal work 6.5 Living standards The household survey shows that only 8% of the adult population in the Project area (age 15- 60) have a stable regular income. The percentages of households in the survey who obtained income from different sources during the month of April 2011 are presented in Table 6-6. From this it can be seen that the sale of agricultural/farm produce was an important source of income in the study villages. U3823_Marampa_ESIS_Final.docx September 2012 Page 121 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 6-6: Income sources in the study area Income Source Percentage of households Sales of agricultural/farm produce (including livestock) 80% Self-employment (artisans/trade) 6% Employment 2% Remittances 5% Source: SRK household survey April 2011 6.5.1 Possessions and expenditure Household possessions are generally limited to basic furniture such as tables, beds, chairs/stools and items such as radios cell phones and bicycles, which are considered essential. Table 6-7 shows the average annual household expenditure for the principle items. The average expenditure on food is 44% of total expenditure. Monetised value of food produced further increases this percentage reflecting widespread poverty in the study area. It also shows people are not self-sufficient with regard to food. School fees, clothing, household energy, agricultural equipment, medical care and transport are also significant expenditure items. Table 6-7: Annual household expenditure in the study area Item Average cost per Average cost per Percentage of household per household per year in total expenditure year in Le USD10 Food 1,836,146 402.8 44.2% School fees 469,695 103.0 11.3% Clothing 333,337 73.1 8.0% Household energy 327,624 71.9 7.9% Agricultural equipment and inputs 314,796 69.1 7.6% Medical care 279,914 61.4 6.7% Transport 227,794 50.0 5.5% Buildings 158,905 34.9 3.8% Cellular telephone 77,932 17.1 1.9% Savings 70,694 15.5 1.7% Livestock expenses 53,662 11.8 1.3% Water 3,220 0.7 0.1% Total 4,153,719 911.3 100% Source: SRK household survey April 2011 6.5.2 Food Security The diet of local communities in the study area is based on locally produced staple crops and locally grown vegetables. Fish is eaten more regularly than meat, which is eaten occasionally due to its high cost. Decreasing crop yields, an increase in pest related crop failures and reduced availability of food resources from the forest have led to reduced food security11. In the household survey, 83% of households indicated they experience food shortages at some stage during the year, predominantly during the period July to September. 10 Exchange rate 1 USD=4558sll (September 2011) 11 Food security is considered ranging from 105 kg 157 kg of rice per capita per annum. U3823_Marampa_ESIS_Final.docx September 2012 Page 122 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 6.5.3 Habitation People live predominantly in settlements with some scattered housing near the fields for protecting the farms. Traditional housing consists of clay and earth structures, built with a thatch roof (18% of survey households had a traditional house – see Figure 6.11). Modern materials are now often incorporated into the house structures. 17% of survey households did not have a bathroom. Some houses were in bad condition as observed during the survey. Typical traditional house Improved traditional house Figure 6.11: Traditional houses 6.5.4 Energy sources The energy source for domestic lighting in the study villages was predominantly paraffin lamps (71%), battery operated lights (19%) and candles (10%), with about 17% of the people using a combination of the above three sources. 6.6 Social stratification Although the majority of the rural population is poor, some stratification exists. There are traditional elite families who can trace their ancestry (usually through the father's line) to a warrior or hunter who first settled in an area. These families control and administer land, people who want to acquire the right to farm must show respect to an elder from this family. Colonial administrators have historically exacerbated this social stratification. 6.7 Vulnerable groups Vulnerability is defined here as the inability to generate sufficient resources to meet basic human needs). The most vulnerable groups include those who cannot work the land (widows, the elderly and the sick), who have no other means of income generation and no family or other social support network. 6.8 Health There are six functional Peripheral Health Unit (“PHU”) in the Marampa Chiefdom. Each PHU has its own catchment area and together they cover a population of approximately 20,000 (or 50% of the Chiefdom population) including the population living in Lunsar town. The PHU in Lunsar is headed by nine government staff, a Community Health Officer, Nurse, Maternal and U3823_Marampa_ESIS_Final.docx September 2012 Page 123 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Child Aides, Nursing Aides, Vaccinator and Cleaners/Labourers. The study area is also served by other health institutions in Lunsar town: • The Saint John of God Catholic Hospital (a referral hospital) providing health service to the region at a nominal cost. • The Baptist Eye Hospital providing specialist services at a nominal cost. These have a good reputation nationally however the cost of treatment is too high for the majority of the people in the villages to afford. Marunku is the only village in the study area that has a health facility and managed by a Nurse and Traditional Birth Attendants (“TBAs”). Health and hygiene conditions in the study area are generally poor. The household survey showed that 81% of households deposit their household waste in the areas around their homesteads. The water quality was observed to be inferior and wells dry out during the dry season. Villagers often need to walk long distances to fetch water. According to the PHU in Lunsar, malaria is a leading disease in the chiefdom. Other diseases prevalent in the area are diarrhoea, pneumonia, clinical malnutrition, anaemia, measles, typhoid, skin infections, eye infections and hypertension. The incidence of HIV/AIDS has increased 17 cases in 2011. These 17 cases are receiving treatment from the PHU. STIs are on the increase in the chiefdom and the PHU records 17-18 cases every month. Table 6-8 lists health problems experienced by local residents during the past six months. These are based on symptoms identified by the residents and not necessarily based on professional medical diagnosis. Table 6-8: Most prevalent health problems in the Project area Disease Percentage occurrence Headache 32% Malaria 29% Respiratory Infections 15% Diarrhoea 9% Others 9% Cholera 6% Source: SRK household survey April 2011 The key challenges identified by this PHU are: • unable to meet the needs of increasing number of patients; • poor salary for staff and TBAs working with the PHU are currently unpaid; and • additional transport needed to increase their outreach and coverage. Self-medication is widely practiced (Section 6.3.1). Data from the household survey for medical care sought by people shows that in 80% of the cases contemporary medicine was used and in 20% traditional healers (Table 6-9). In addition to traditional beliefs, distance and cost are also deciding factors. Table 6-9: Consultation of medical services in the study area Medical Care Number (and percentage) of people seeking services Health professional (clinic) 51 (80%) Local traditional healer 13 (20%) Source: SRK household survey April 2011 U3823_Marampa_ESIS_Final.docx September 2012 Page 124 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 6.9 Education The levels of education and literacy are generally low in the study area. Table 6-10 summarises the education level for the population covered by the household survey. During the study, the importance of education was repeatedly stressed by the local population. Table 6-10: Educational levels in the study area Education level Number of people Percentage of population No education (>13 years old) 680 47% Started but did not complete primary school (>13 308 21% years old) Completed primary school (>13 years old) 207 14% Started but did not complete secondary 168 11% education (>18 years) Completed secondary education (>18 years) 91 6% Tertiary education (>25 years) 17 1% Total 1471 100% Source: SRK household survey April 2011 The education sector encounters several challenges, some of which are listed below: • lack of schools–. Children often have to walk long distances to reach school, resulting in low attendance and large numbers of drop outs; • shortage of trained and qualified teachers; • late or no payment of teachers leading to de-motivation; • dilapidated school buildings and shortage of classrooms, though MIOL has provided assistance to some local schools (Figure 6.12); and • overcrowded classes. Broken roof in a classroom New school build by MIOL in Konta Figure 6.12: Examples of educational facilities 6.10 Infrastructure The general infrastructure in the study area is in a poor state of repair. There is no state provided electricity in the area but mobile phone coverage is good. There are few paved roads between the villages, and some villages are accessible only by footpath. The area does benefit from a sealed road to Freetown (Makeni Highway), which provides access to markets U3823_Marampa_ESIS_Final.docx September 2012 Page 125 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report for buying and selling farm products. The main market for the study area villages is Foredugu near Lunsar. 6.11 Ongoing governmental and non-governmental programmes A large number of non-government organisations (NGOs) are working in Sierra Leone. The Government and private sector combined does not have the capacity to meet basic health, education and welfare needs. Some of the Government and NGO programmes active in the study villages are: • grain bank Projects run by GoSL in Gbese Village and by Saint John of Paul Church Health Centre (a NGO) in Katik Village; • training and seed money to women to encourage micro-credit groups of 10 to 20 members by an International NGO, called BRAC - the credit is usually used for farming activities and other small business activities; and • prevention of harmful practices against women and girls, specifically Female Genital Mutilation (“FGM”) by a local NGO called Amazonian Initiative Movement (“AIM”). 6.12 Contemporary social system and practices Land-use rights and most portable forms of wealth are inherited patrilinealy. Decision making in the village is done by the chief and the elders of the landowning families. Youth and women’s’ organisations are consulted in decision making. The Project could impact differently on men and women. Due to the many socio-economic disruptions, wars and break-ups of families, gender roles may have become less rigid. An overall picture from the household data shows that: • women are exclusively involved in cooking, cleaning, tending gardens, selling crops/local produce, and collection of water, firewood and wild flowers; • men are exclusively involved in cutting trees, clearing farms, making charcoal, building mounds, hunting and housing construction (and also entitled to own/inherit land); and • both men and women are involved in fishing, managing livestock, land cultivation, processing oil palm, upbringing of children, decision making and purchasing goods, however the extent to which these jobs are shared varies by task and by household. From FGDs it was learnt that some girls are falling pregnant at the age of 13 years. Parents also complained of changing social values in general and growing indiscipline among the youth. 6.13 Archaeology and cultural heritage A rapid archaeological scan was conducted in the Project Area in March 2011 (see Nexus 2011 specialist report in Volume 3, SD8). The ethnographic meetings and interviews resulted in the identification of 62 cultural heritage sites (49 sacred sites and 13 archaeological sites). These are shown on Figure 6.13 with detail on each site presented in the specialist study report. Every village in the area has one or more ‘sacred bushes’ normally linked to the secret societies within the villages. Most villages also have a burial ground, and where villages have both Muslim and Christian inhabitants, there will usually be two cemeteries. In addition there U3823_Marampa_ESIS_Final.docx September 2012 Page 126 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report are archaeological sites, which the villagers regard as ‘ancestral villages’ and attach great value to. Local people reportedly feel it is acceptable to relocate and restore the sacred bushes and cemeteries as long as the right procedures are followed 6.14 Community perceptions: needs and apprehensions Needs and apprehensions were identified through the stakeholder engagement process, as well as through interactions between the baseline specialists and the communities. Development needs and problems in the study area, identified through the focus groups discussions and household survey, are presented below. The key community needs are: • employment; • assistance with education fees/scholarships for children; • improvement of facilities – health, education and roads; • access to drinking water facilities and electricity; • assistance with agricultural activities, and • poverty alleviation in general. In general, potentially affected people seemed positive towards the Project. A summary of the stakeholder apprehensions, as gathered during the baseline survey is presented below. • Fear that community members will be marginalised in terms of job opportunities by outsiders (many already complained of jobs being given to outsiders). • Concerns about being compensated inadequately for loss of land and damage to crops during construction activities. • Concerns the Project activities will have a negative impact on drinking water sources in terms of contamination and/or reduced availability. • Concern the vibrations caused by blasting will damage their houses (some cited their experiences from the old Delco operations), and • Concern building of further roads will disrupt community access routes or connectivity to Lunsar and other villages (some people cited how they were already impacted due to the rail line). U3823_Marampa_ESIS_Final.docx September 2012 Page 127 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 6.13: Location of archaeological and cultural heritage sites in the study area U3823_Marampa_ESIS_Final.docx September 2012 Page 128 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 7 BIOPHYSICAL IMPACT ASSESSMENT This Chapter describes the biophysical impacts that could occur as a result of the Project. Socio-economic impacts are described in Chapter 8 and Community Health, Safety and Security risks in Chapter 9. The impacts have been identified based on consideration of the information presented in the preceding chapters. To avoid unnecessary repetition of supporting information, cross referencing to other sections of the report is given where necessary. The various impacts identified for the Project, as well as an indication of the Project phase (construction, operation, decommissioning and post-closure) in which the impact is expected to occur, are described in the subsections below. The Project phase is indicated by shading bars at the beginning of each impact description – the darker the shading in the bar, the more applicable the impact is to that Project phase. As the Project is phased over two consecutive development stages (Stages 1 and 2, as described in Chapter 4), the construction phase is assumed to extend in duration through the operation of Stage 1, until Stage 2 construction has been completed. The entire construction phase of the Project is therefore expected to last approximately three and a half years (18 months for construction of Stage 1 followed immediately by 18 to 24 months for construction of Stage 2). In general, operational impacts will commence with Stage 1 and increase in intensity as production capacity increases through Stage 2, and tail off towards decommissioning and closure 14 years later. A summary of issues or concerns as expressed by stakeholders during the information sharing consultations (Section 3.3.5), and where they are addressed in the various impact sub-headings below is provided in Table 3-7. These issues were considered when identifying and rating the importance or value of possible impacts. Identified impacts are discussed within impact groups (such as Land Transformation or Water Resources) to organise the discussion and keep it concise. Impact group reference codes have been assigned to help maintain links between the discussion of impacts in this section and the environmental management programme in Appendix F. Each impact group discussion includes the Project activities that may give rise to impacts and, where relevant, generic information supporting the overall impact group discussion. A summary of the impacts evaluated in this section, listed per impact group, is given in Table 7-1. As there are close linkages between a number of the impacts (for example those affecting multiple receptors) and to avoid repetition, these impacts have been listed and rated in the impact group most affected, with cross references to the other linked impacts, both within and between disciplines (biophysical, socio-economic and health and safety). Table 7-1: Summary of evaluated biophysical impacts Impact groups Impact headings • LT1: Change in land use as a result of mine and related infrastructure limiting use by local communities • LT2: Disruption of community access routes by mine infrastructure, resulting in Land social disruption transformation • LT3: Mine infrastructure and activities resulting in visual intrusion and loss of ‘sense of place’ for local communities • LT4: Loss of topsoil through erosion, decreasing land capability • LT5: Fugitive dust resulting in changes in soil chemistry and agricultural land capability U3823_Marampa_ESIS_Final.docx September 2012 Page 129 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact groups Impact headings • WR1: Pit dewatering potentially resulting in reduced groundwater availability to ecological systems and local communities • WR2: Surface water abstraction affecting downstream users • WR3: Project infrastructure causing altered flow conditions, affecting downstream users Water resources • WR4: Surface water diversions causing potentially changes to flood risk to adjacent agricultural areas and communities • WR5: Seepage from mining wastes potentially resulting in deteriorated water quality affecting communities and ecological systems • WR6: Discharge or runoff to surface water potentially resulting in deteriorated water quality affecting communities and ecological systems • EB1: Site clearance and positioning of Project infrastructure potentially resulting in habitat loss and fragmentation, and direct loss of fauna and flora • EB2: Soil disturbance facilitating the establishment and spread of invasive Ecology and species, affecting indigenous ecosystems biodiversity • EB3: Project activities potentially resulting in sensory or other disturbance to wildlife • EB4: Mine infrastructure and activities attracting nuisance species, resulting in impacts on indigenous ecosystems As described in Section 3.3.3, the individual impact discussions are generally concluded with an impact rating table. The header row of the table gives the impact definition. The following rows present the impact characteristics and significance ratings. The final row presents any additional management measures identified as required to appropriately control/enhance the impacts. These would be over and above the inherent management measures incorporated into the Project design and described in Chapter 4. Where such measures are stipulated, a rating for the ‘Residual impact’ is provided, assuming these measures are successfully implemented. Included in the summary table is a confidence assessment, which provides the reader with an indication of the assurance level placed on the rating process and addresses the concept of uncertainty. An indication is also given as to whether the impact is reversible or not. In addition to mitigation or enhancement measures, there may be a number of good practice management measures, which are unlikely to change the impact rating but are considered good international practice for managing that impact. These are listed below the summary table, where relevant. The impacts described in this section are based on normal activities expected during the relevant Project phases (construction, operation, decommissioning and post-closure). Some impacts may be exacerbated or caused by upset conditions due to natural hazards such as seismic events or floods, third party interference such as sabotage, equipment failure or human error. Such events are not considered normal and therefore where relevant the implications of upset conditions on the identified impacts have been described after the rating of normal conditions has been presented in the rating table. Such events would be handled as an emergency or incident as described in Section 11.6. Although the Project will occur in two development Stages, impacts have been assessed for Stage 2 (full Project) only, as this stage is expected to result in impacts of greater significance than Stage 1, due to the increased production throughput and larger overall footprint disturbed. Where there is some uncertainty regarding impact predictions, such as in situations where all the relevant detail was not available at the time of the impact modelling (specifically for water resources, air quality and noise impacts), a generic worst case reasonably foreseeable scenario has been used. This may result in over-estimation of these impacts, and additional impact modelling, once more accurate Project-specific information becomes U3823_Marampa_ESIS_Final.docx September 2012 Page 130 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report available, may be required for instances where the new information differs significantly from that used for the current impact assessment. 7.1 Land transformation Development of mine, transportation and associated infrastructure will disturb the land surface and result in a temporary or permanent change to the land and its capability for other uses. The Project area is relatively flat and low-lying and generally densely vegetated, either with cultivated crops or natural vegetation. Land transformation can occur due to direct modification of the land as the soil is cleared and moved for construction of Project infrastructure or covered by waste rock dumps, or where activities associated with the Project (such as access roads, resettlement areas and expansion of the surrounding residential areas as a result of an influx of job-seekers) affect land outside the immediate footprint area. The severity and extent of land disturbance may be increased beyond the directly disturbed footprint by indirect modification due to erosion, changes in drainage patterns, compaction of soil, chemical spills or leaks, and deposition of sediments by wind and water, affecting soil chemistry and the ability of the land to be beneficially used. Naturally occurring modification of land by wind and rain (erosion) may be exacerbated by Project related activities, including: • disturbance of the soil surface vegetation and soil crust (for example by vehicle and equipment use and land clearance for construction) increasing the susceptibility of the soil to wind and water erosion; • alteration of surface topography by construction of large infrastructure (such as the waste rock dumps) resulting in changes to the wind and stormwater runoff patterns and exposure of larger surface areas to wind and water erosion; and • changing the route and hydrology of natural drainage lines (such as stream or stormwater runoff diversions around Project infrastructure or to create water storage facilities). Implementation of good practice measures, such as erosion control and minimising the area and degree of disturbance, may reduce the spatial scale of the impact; nonetheless a relatively large area (>2,000 ha) will be subject to permanent change. These measures are listed in the sections below. Some of the disturbance can be reversed at closure by rehabilitation of disturbed areas and removal of Project infrastructure with no ongoing use. 7.1.1 LT1: Change in land use as a result of mine and related infrastructure limiting use by local communities Construction Operation Decommissioning Post-Closure The local communities are heavily reliant on the land for their various livelihood strategies and use the area extensively for subsistence agriculture (including rice cultivation in the floodplains and cultivation of cassava and tropical species such as oil palm, pineapple and mango in the upland and secondary forest areas), as well as harvesting of natural resources (such as wood and wild plants), hunting and fishing. Agriculture is the most significant current land use and livelihood strategy (practiced by 82% of the population) in the area, and intercropping methods are used by local farmers to take full advantage of the available U3823_Marampa_ESIS_Final.docx September 2012 Page 131 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report habitat. Natural vegetation, particularly forest, is also used extensively for the harvesting of wild herbs (primarily for medicinal uses), firewood, and for cultural purposes. This impact will begin with the clearing of land for construction of the Project infrastructure, increasing in magnitude through operation and decreasing post-closure with rehabilitation of the area, the aim being that communities could eventually resume their use of some of the land for agriculture or some other useful purpose. The recovery of natural vegetation to support harvesting of natural resources is likely to require longer periods and is discussed in Section 7.3.1 (EB1). The areas that will be directly disturbed through construction of the mine infrastructure, together with the current land uses of these areas, are indicated in Table 7-2. The total area directly transformed due to mine surface infrastructure is approximately 2,200 ha, of which approximately 89% (~1,950 ha) is land currently used for agriculture. This is however an underestimation of the actual land surface area directly impacted, as it does not account for access roads, laydown areas and other minor infrastructure. Table 7-2: Current use of land12 directly disturbed by mine infrastructure Current land use Approximate area permanently modified (ha) Gallery Forest 1.2 Secondary Savannah 5.5 Urban 7.8 Transformed - Subsistence Cultivation 7.9 Transformed - mining 8.4 Transformed - Oil Palm Plantation 26.2 Transformed - Mango Plantation 120. 0 Rice Wetlands 326.0 Secondary Forest / Farmbush Mosaic 1,452.0 Total agricultural land 1,955.0 (89%) Loss of agricultural land and habitat for indigenous vegetation - either permanently through construction of Project infrastructure or temporarily through soil compaction and clearing of vegetation from surrounding areas for access routes and lay down areas during construction - is therefore expected to affect these communities in terms of food security and livelihoods (discussed further in RL1 and RL4 in Section 8.2). In a number of cases, whole villages will be directly impacted due to the positioning of Project infrastructure, and relocation of these villages will therefore be necessary. In other cases, land used by villages will be lost or otherwise impacted through land acquisition but the villages themselves will not be relocated. It is estimated that, in general, an area with a radius of approximately 2 km around the village is used for natural resource uses (WRL, 2012). Impacts relating to relocation and land acquisition are addressed separately in Section 8.2 (Impacts RL1 to RL4). The loss or disturbance of sites of cultural heritage (such as sacred bush) is discussed in Section 8.4.1 under impact AC1. Due to the close association between this impact and Impact RL1 (impoverishment through loss of shelter, land and communal natural resources) in terms of impacts on communities, and to prevent double rating, this impact has not been rated in this section. The rating provided for Impact RL1 in Section 8.2.1 therefore applies. Implementation of the 12 Calculated from Ecorex 2011 report, included as SD4 of Volume 3 U3823_Marampa_ESIS_Final.docx September 2012 Page 132 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report management measures listed for Impact RL1, in addition to the good practice measures listed below, is recommended to assist communities in adapting to the change and resuming or adopting new livelihoods more quickly. With rehabilitation, the intention is that the impact will be partially reversed and the land will once again be made available for use by local communities (though post-rehabilitation use may differ from pre-mining land use). Good practice measures recommended include the following: • Develop a Construction Management Plan that includes requirements to: o Minimise the footprint area disturbed during construction, operation and decommissioning of the Project. o Minimise the duration of the disturbance by starting rehabilitation as soon as possible and progressively rehabilitating disturbed areas that are no longer being used for the Project, and making them available for communities to use. • Prohibit unnecessary off road driving, and use planned and designated access routes and lay-down areas only. • Review and update the Closure and Rehabilitation Plan periodically to address current site conditions, community expectations, and the results of ongoing routine monitoring. 7.1.2 LT2: Disruption of community access routes by mine infrastructure, potentially resulting in social disruption Construction Operation Decommissioning Post-Closure Another factor affecting local communities is the disruption of access routes, resulting from construction of the mine infrastructure blocking these routes. Apart from the beneficiation plant and staff accommodation village, Project infrastructure, including haul roads, will not be fenced allowing for a degree of access across Project areas. However, the presence of large infrastructure such as the TSF, WRD and pits would in itself prevent access or thoroughfare to areas on the other side of it. In cases where access across infrastructure may still be possible, safety (in the case of haul roads and other access roads) or ease of crossing (such as in the case of above ground pipelines) may be compromised. It is also likely that community members will use the haul roads and other mine access routes making for easier access to Lunsar and the Makeni Highway. This access would however increase the safety risk for community members and their livestock due to mine-related traffic as discussed in Impact TS2. It is expected mine infrastructure associated with the change in land use will have a negative impact on community access, particularly for more localised routes used between villages, and could ultimately impact on community members’ livelihoods and ultimately income generation. Due to the linkages between this impact and the associated social impacts the overall effect on communities is evaluated and rated in Section 8.2 (Impact RL2). U3823_Marampa_ESIS_Final.docx September 2012 Page 133 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 7.1.3 LT3: Mine infrastructure and activities potentially resulting in visual impacts for local communities Construction Operation Decommissioning Post-Closure Visual intrusion and loss of a “sense of place” may occur directly as a result of mine infrastructure and changes to the landscape (due primarily to vegetation clearing and construction of the open pits, tailings facility and waste rock dumps). Indirect impacts may also result from dust blown from exposed surfaces and from blasting creating a plume, as well as lighting of site infrastructure in an otherwise relatively unlit environment, both of which could be visible from a considerable distance. Ecological impacts resulting from visual intrusion are discussed in Section 7.3.3 (Impact EB3) and the impacts on road safety in particular resulting from dust are discussed in Section 9.3.1 (Impact TS2). Air quality impacts resulting from dust are discussed separately in Section 9.1 (Impact AQ1). Non-mining waste such as building rubble and domestic waste, both directly and indirectly (due to increased population and development in the area) related to the Project, is another aspect that could result in a negative change in visual character of the area. Although a waste landfill is planned as part of the Project, indiscriminate dumping of litter and rubble resulting from secondary developments could contribute to visual degradation of the area on a local scale. The scale or intensity of the visual impact may be perceived differently depending on the sensitivity of the viewer and their location relative to the impact. Sense of place is defined as a person’s sense of belonging to a place or area. The screening effects of topography or dense, tall vegetation (such as forest) may reduce the impact slightly, though this is unlikely to have a significant effect due to the generally flat topography and lack of forested areas in the vicinity of the mine infrastructure (these are restricted to a small area along the Rokel River close to the Gafal West waste rock dump). As the area is not recognised for its scenic beauty or touristic value, combined with the fact that other mining Projects exist in the area (also impacting on the area’s visual character) potential viewers are expected to have relatively low sensitivity towards these changes. It is, however, recognised that the perception of a visual impact is by nature highly subjective and, where one viewer may consider the impact to be negative, another might perceive the increased development and lighting of the area positively. For this reason a change to the sense of place of an area is difficult to rate according to standard methodologies. Although local people may associate a particular sense of place with the Marampa area, what is difficult to gauge is the importance people attach to that sense of place and how this will change over time when the cumulative effects of other Projects in the area are considered, together with how potential Project benefits may ameliorate any loss. Visual disturbance and loss of sense of place impacts are difficult to manage and the loss is theoretically irreversible regardless of post-closure rehabilitation (although this will ameliorate this impact to some degree). The perception of the area may change over time with people becoming accustomed to a new sense of place and thus the actual impact is partially reversed. The closure measures proposed, such as backfilling of the pits with waste rock and tailings material thereby reducing the height and visibility of the WRD and TSF, removal of mine infrastructure with no continuing use and rehabilitation of the site will assist in reducing the impact at closure. The most significant impacts will therefore occur during construction (especially during clearing of vegetation when dust levels will be highest), operation and U3823_Marampa_ESIS_Final.docx September 2012 Page 134 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report decommissioning (when additional earth-movement is expected). As the impact involves differing perceptions by receptors, the confidence in the impact is given as medium. Due to the relatively degraded current visual nature of the site, local communities are not expected to be highly sensitive to the impact. Without earnest attention to post-closure rehabilitation of the area, however, the changes to the landscape will remain visually intrusive beyond the life of the mine, if not permanently. The development will be visible from outside the direct Project area (e.g. from roads and villages) and, although it is not possible to hide the development and associated infrastructure, it may be possible to reduce the negative visual perceptions associated with the mine and create a more visually harmonious impression post-closure through rehabilitation. Impact LT3: Mine infrastructure and activities potentially resulting in visual impacts for local communities Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity Low Low Receptor importance or Low Low Magnitude value description Extent of change / threshold Moderate Moderate compliance Magnitude rating MINOR MINOR Duration Long term Medium term Timeframe Frequency - - description Timeframe rating LONG TERM MEDIUM TERM Spatial Scale INTERMEDIATE INTERMEDIATE CONSEQUENCE RATING MEDIUM LOW PROBABILITY RATING POSSIBLE UNLIKELY SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility / sustainability Partially reversible Confidence Medium Management measures • At closure, remove mine infrastructure that does not have a continued use. • Revegetate and landscape the site on closure, to reflect the surrounding topography and vegetation as much as possible. • Consider the use of screening tools such as dense vegetation where practical and appropriate to the surroundings. • Clear vegetation in phases so that only those areas required for immediate development are cleared. • Develop and implement a waste management plan that includes provision for waste resulting from secondary developments and domestic waste linked to the Project. Good practice measures: • Paint buildings and structures or use materials with colours that reflect and complement the natural colour and textures of the surrounding landscape. U3823_Marampa_ESIS_Final.docx September 2012 Page 135 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report • The slopes of the WRD and any other visually intrusive stockpiles should be reduced during closure to be consistent with the surrounding natural topography. • Use directional lighting in areas operating at night, if communities are affected by lighting. • Refer to dust control measures under Impact AQ1 (Section 9.1.1). 7.1.4 LT4: Loss of topsoil through erosion, decreasing land capability Construction Operation Decommissioning Post-Closure Activities such as vegetation clearing for Project infrastructure, or other damage to vegetation, particularly groundcovers that bind and stabilise the topsoil, will result in large areas of exposed topsoil which will be susceptible to erosion through wind and water if not carefully managed. The soils in the area are broadly characterised as sandy and ferrallitic, typical of tropical regions, and have a reasonable proportion of fine particles (<0.1 mm in size), making them moderately susceptible to erosion. Organic content of the soil is overall moderate to high (due to the dense vegetation cover), but relatively low in cultivated areas (due to harvesting of crops). As organic content would reduce the soil erosion potential, cultivated areas would therefore be more prone to erosion. The longer the exposed area is subject to erosive forces, the more severe the effect. Sloped areas are also more susceptible to erosion through stormwater runoff, with the secondary impact of sedimentation of surface water resources (discussed in Section 7.2.6 (Impact WR6). Whilst the study area is relatively flat, the high annual rainfall and high frequency of severe rain events may also contribute to increased erosion of disturbed areas. Clearing of vegetation, combined with high winds or heavy rainfall, would increase the soil’s erosion potential and lead to a reduction in land capability if appropriate management measures to prevent erosion are not implemented. Topsoil is essential to support vegetation growth as it harbours the required nutrients as well as a natural seed bank reflecting its former vegetation cover. It takes many years to develop and is therefore essentially non-renewable – complete loss of topsoil from an area would require import of topsoil from another area (preferably with similar vegetation makeup) in order to support vegetation growth. Loss of topsoil therefore compromises the capability of the soil to support both agriculture and ecological processes, both of which are important current land uses for local communities in terms of food security. Without appropriate management and preservation of topsoil the area would therefore remain sparsely vegetated and not be suitable for post closure land use (rated below). In addition, it will contribute to dust generation and visual impacts (discussed under Impacts AQ1 and LT3 in Sections 9.1.1 and 7.1.3), and loss or fragmentation of habitat (discussed under Impact EB1 in Section 7.3.1). Due to the reliance of local communities on land capability for their livelihoods and food security, the pre-management magnitude of the impact is rated as moderate. The impact has the potential to extend beyond the life of the mine as, without the successful implementation of topsoil maintenance and erosion control measures, loss of topsoil could result in increasingly negative impacts on land capability and livelihoods in the area. The spatial scale is restricted to cleared and disturbed areas within the Project footprint. Through appropriate management via implementation of erosion control measures, such as re-vegetation to retain and preserve topsoil, the impact significance could be reduced as the topsoil would be stabilised in a relatively short period of time and loss of topsoil would therefore be less likely. Although the impact could be largely reversed through the import of topsoil material from U3823_Marampa_ESIS_Final.docx September 2012 Page 136 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report outside, this is too costly to be a viable solution for large areas and only leads to negative impacts in the source area. Impact LT4: Loss of topsoil through erosion, decreasing land capability Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity Medium Medium Receptor importance or Medium Medium Magnitude value description Extent of change / threshold Medium Medium compliance Magnitude rating MODERATE MODERATE Duration Long term Medium term Timeframe Frequency - - description Timeframe rating LONG TERM MEDIUM TERM Spatial Scale SMALL SMALL CONSEQUENCE RATING MEDIUM MEDIUM PROBABILITY RATING POSSIBLE UNLIKELY SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility / sustainability Partially reversible Confidence High Management measures • Avoid disturbance of slopes or sensitive areas such as drainage areas, where possible. • Implement erosion control measures where steep slopes or large unvegetated areas are created, or where sensitive areas such as river banks are disturbed. • Inspect disturbed, rehabilitated, and sensitive areas such as river banks affected by Project infrastructure for visual signs of erosion and/or deposition affecting either the Project’s or community’s use of the land. If problems are identified, initiate remedial action. • Clear and stockpile topsoil separately from subsoil / fill material, for use during rehabilitation. • Implement rehabilitation and establishment of vegetation cover as soon as possible. Good practice measures: • Maintain topsoil stockpiles to prevent their erosion or contamination with subsoil or other materials. • Ensure stockpiled topsoil is used within two years and is not excessively compacted to preserve a viable seed bank. • Avoid driving over or otherwise compacting or disturbing topsoil. • Design roads, pipeline routes and landscape features to minimise disruption of natural drainage patterns. U3823_Marampa_ESIS_Final.docx September 2012 Page 137 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 7.1.5 LT5: Fugitive dust potentially resulting in changes in soil chemistry and agricultural land capability Construction Operation Decommissioning Post-Closure During operations, and to a lesser extent during decommissioning and post-closure, there is the potential for some finer tailings dust to be mobilised from the TSF (and later from the Matukia pit, which will be backfilled with tailings) during dry windy conditions (refer to discussion in Impact AQ1). It is however proposed that a pond will be maintained on the TSF, preventing the generation of tailings dust from the surface of the TSF. Some of this dust will be deposited on the land downwind of the tailings storage areas potentially affecting the physical and chemical characteristics of the soils in the deposition areas. Meteorological data obtained from the site showed the predominant wind direction to be South-westerly and consistent throughout the year. Although the area is subject to the Harmattan winds during the dry season (November to April), the data suggests the region is shielded from the full effects of these winds, possibly by mountain ranges to the northeast of the country (for further detail see the Climate and Air Quality Baseline Report in SD 2 of Volume 3). The most affected areas would therefore be those to the north-east of the Project area. The soils baseline study (SD 5 in Volume 3) found soils in the area to be moderately acidic (pH 4.7 to 5.8), with a low cation exchange capacity (10.5 to 19.7 meq/100g) and dominated by iron and aluminium. The sediments are predominantly quartz-rich sands and gravels, with a mildly acidic to circum-neutral pH (5.3 to 6.5 s.u.). Sediment chemistry is dominated by aluminium, iron and manganese, which reflects the geology of the deposit, and is generally highly leached, with frequent flushing by water. Preliminary geochemical ARDML characterisation of the predicted tailings material found arsenic levels to be elevated above the Geochemical Abundance Index in some samples, but the metal leaching and acid generation potentials to be negligible in general (for more detail refer to the full ARDML report in SD 6 of Volume 3). Windblown tailings deposited on downwind soils will have the potential to increase the concentration of metals and other constituents in the native soils. However, other sources of fugitive dust will mix with the windblown tailings, thereby diluting the deposited material. Changes in the soils downwind of the TSF (and Matukia pit once that is used for tailings storage) from the deposition of windblown tailings have the potential to result in indirect impacts to: • storm water runoff quality, thereby affecting aquatic ecosystems and community users (refer to Impact WR6 in Section 7.2.6); and • agricultural and natural vegetation by direct contact (covering foliage) and metal uptake via roots. Runoff from rain events may remobilise tailings dust from the soil and vegetation and redeposit it in drainage channels where it may accumulate and affect storm water runoff quality. Plants may be affected if their foliage is covered by dust or metals are transported by storm water infiltrating into the root zone. However, the plants in the area appear to be unaffected by existing high fugitive dust levels in the dry season and infiltrating storm water will be diluted through mixing with storm water unaffected by windblown tailings thereby reducing the effects of mobilized tailings on overall plant uptake. U3823_Marampa_ESIS_Final.docx September 2012 Page 138 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report The magnitude of this impact is considered to be minor because, although food security is a critical issue, the predicted tailings material is relatively innocuous and there are already elevated dust levels in the area due to existing land uses. Frequency of occurrence would also be low due to the tropical climate that predominates in the area, with regular rainfall and low wind speeds for most of the year, which results in relatively low levels of windblown dust. Without management of dust from the tailings material, the impact could continue at a low level beyond the life of the mine (if not permanently) and could extend beyond the Project footprint. Provided rehabilitation of the tailings storage areas is successful and the tailings material is protected from erosion, mobilisation of tailings material post-closure would be unlikely, although the process of remobilisation of deposited material may continue after closure. Impact LT5: Fugitive dust potentially resulting in changes in soil chemistry and agricultural land capability Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity Low Low Receptor importance or Medium Low Magnitude value description Extent of change / threshold Low Low compliance Magnitude rating MINOR MINOR Duration Long term Medium term Timeframe Frequency Low Low description Timeframe rating LONG TERM MEDIUM TERM Spatial Scale INTERMEDIATE INTERMEDIATE CONSEQUENCE RATING MEDIUM MEDIUM PROBABILITY RATING POSSIBLE UNLIKELY SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility / sustainability Irreversible Confidence Medium Management measures • Implement dust control measures, such as wetting down and maintaining a pond at the tailings storage areas. • On closure, put in place measures (such as revegetation) to ensure continued erosion control of the tailings material. Good practice measures: • Using data collected during the monitoring programme to develop a Soils Management Plan to monitor the effects of blowing tailings dust on soils and determine whether further management measures may be required to mitigate impacts from windblown tailings. The plan should determine: o expected incremental increases in metals and effects of dilution; o extent and effects of remobilisation; U3823_Marampa_ESIS_Final.docx September 2012 Page 139 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report o potential eco-toxicological effects; and o removal standards if needed. 7.2 Water resources Although impacts to water resources are traditionally assessed in environmental impact assessments, water resources themselves are not actual receptors and are rather pathways to receptors or water users. In-keeping with the norm, impacts on water resources are considered and assessed in this report but often the significance of the intrinsic changes to water resources themselves can only be interpreted meaningfully in conjunction with consideration of the affected receptors. Human water resource users in the Project area include local communities using groundwater as their primary source of drinking water and other domestic uses as well as the use of wetland ecosystems for the cultivation of rice and fishing. Climatic data for the area indicates a clear wet season extending from May to November and a dry season between December and April, when evapotranspiration exceeds rainfall. Availability of water resources would therefore be particularly important for local communities during the dry period. Ecological receptors include the flora and fauna associated with the aquatic habitats of the rivers and wetlands as well as the riparian habitats along the banks of the rivers. Aquatic habitats in general are expected to be sensitive to change, especially to changes in turbidity and sediment loads, and the majority of surface waters have little or no ability to resist changes to pH from any acid inputs because of a low buffer capacity (Section 5.5.3). Larger rivers, where dilution plays a role, may be more tolerant to minor changes. The impacts assessed can be divided into two categories – those affecting the flow and availability of water resources and those affecting its quality (via discharges from the mine and related activities). Impacts affecting water flow and availability can be caused by: • pit dewatering (Impact WR1); • surface water abstraction (Impact WR2); • mine infrastructure causing changes to flow (Impact WR3); and • surface water diversions altering flood risk in the surrounding area (Impact WR4). A preliminary water balance established for the Project indicates that, on an annual basis, the 3 3 plant make-up water averages approximately 62,000 m /day with 50,000 m /day derived from 3 surplus tailings water and the remainder (approx. 12,000 m /day) derived from either pit dewatering and/or abstraction of surface water from the Rokel River. Discharges to water resources can result from various activities - they can arise directly from point source activities or indirectly from diffuse sources. A point source release generally refers either to a controlled release of wastewater into the environment or to an uncontrolled release arising from an accident or incident (such as a pipeline breakage or a truck overturning). Potential impacts arising from point source releases include the following: • deterioration in water quality, reducing its potential for utilisation by downstream users; and • damage to aquatic ecosystems due to substances contained in the released material. Diffuse pollution occurs over a larger area and is generally more difficult to control than point source pollution. Examples include seepage of process water and surface runoff from mine wastes, such as the TSF, WRDs and low-grade ore stockpiles (Impact WR5). U3823_Marampa_ESIS_Final.docx September 2012 Page 140 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report The impacts that could arise as a result of mine-related pollution are dependent on the type of contaminant contained in the water and thus released. Different users also have different sensitivities to potential pollutant levels. In this case, ‘users’ refers to both human use of water (for domestic, agricultural or industrial purposes) and ecological use. Impacts on water resources were modelled based on a range of parameters measured during the water monitoring programme established for the Project, hydrogeological data from Coffey Geotechnics Limited and data from geochemical investigations by SRK. The modelling results and methodologies are described in further detail in the specialist report in SD 7 of Volume 3. 7.2.1 WR1: Pit dewatering potentially resulting in reduced groundwater availability to ecological systems and local communities Construction Operation Decommissioning Post-Closure Pit dewatering to ensure dry working conditions for the mine and assist with slope stability will be required to manage rainfall runoff and groundwater inflow. Dewatering is likely to be achieved through a combination of perimeter groundwater abstraction wells and in-pit sump pumping. It may however reduce the availability of this resource to other users through drawdown of the groundwater surface surrounding the pit. In this case, ‘users’ refers to both human use of water (for domestic, agricultural or industrial purposes) and ecological use. The significance of groundwater drawdown is a function of the extent and duration of drawdown and the presence of receptors (ecological and human) within the zone of influence. Groundwater levels in the area mimic topography; further detail on the hydrogeology of the Marampa area is provided in Section 5.5.1. Mine inflows are dictated by both direct rainfall and groundwater inflows to the open pits. For the Matukia pit, groundwater inflows are 3 predicted to be in the order of 9,000 m /day and surface water inflows are predicted to be 3 33,000 m /day (Coffey, 2011). These figures are for one pit only, and indicate a range of flows based on seasonal conditions. Pit dewatering requirements are dominated by the high surface water inflows (during the wet season); however given the high groundwater yields, groundwater drawdown will occur as a result of pit dewatering. The extent of groundwater drawdown has been modelled by SRK for the Gafal and Matukia pits13 based on the input parameters provided in the Coffey Phase 1 Study Groundwater Assessment Report (2011). The analytical model predicts drawdown at the end of Stage 2 of mine development for Gafal West and Matukia pits. Due to uncertainties regarding pit geometry and mining schedules, the following assumptions have been made in the modelling to ensure a conservative approach is maintained in the calculations: • both pits will reach a final depth of 280m below ground surface (bgs); • the unsaturated zone extends to 11mbgs at Gafal West and 7mbgl at Matukia; • hydraulic properties of the bedrock are uniform throughout the full thickness of the pit; and • the lifetime of each pit is 13 years. Preliminary estimates (taking into account the likely hydraulic properties of the rock, pit geometry and duration) predict the impact will be limited to villages located within 1000 m of the proposed pits. As would be expected, impacts are predicted to be greatest in the villages 13 Rotret and Mafuri pits were not included in Cofey’s Phase 1 assessment U3823_Marampa_ESIS_Final.docx September 2012 Page 141 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report located closest to the pits. Excluding villages proposed for relocation, these would be Rotret (260 m from the Gafal pit) and Makump and Gbila (520 m and 570 m from the Matukia pit respectively). The estimated drawdown ranges from 67 - 100 m at Rotret, 12 – 18 m at Makump and 8 – 12 m at Gbila village, indicating an exponential increase in drawdown closer to the pit. The drawdown estimations are highly sensitive to changes in hydraulic properties, pit geometry and mining life. Given the current uncertainties regarding these properties further hydrological test work will be undertaken to better constrain the hydraulic properties at Marampa, thus enabling a more robust prediction of likely drawdown around the pits. Local villages rely on groundwater abstraction, via water supply wells and boreholes, as part of their water supply. In many villages however this supply diminishes or completely ceases during the dry season or the wells are no longer functional and villagers resort to the use of surface water resources (involving walking to the nearest supply area and carrying the water back to the village) for drinking and other domestic purposes. The levels of drawdown predicted could therefore potentially significantly impact on groundwater availability to these villages, as well as surface water resources and wetland ecosystems in the area that are supplemented by groundwater, particularly in the dry season. The impact would affect both domestic and agricultural users, as well as fishing, thereby affecting food security in the area. As many villages in the area already suffer from limited or no access to groundwater during the dry season, and the impact is likely to diminish their nearby available surface water resources as well, local communities are likely to be highly sensitive to a further reduction in water availability, the pre-management magnitude of the impact is considered to be major. The impact would last for the life of the mine until decommissioning, when pit dewatering will cease and groundwater levels will presumably return to pre-mining levels, though this is likely to take a significant amount of time. Based on predicted pit inflows for the life of mine, preliminary estimations show that it will take up to 200 years for the pit lake to recover and reach an equilibrium with the surrounding groundwater. Through appropriate management (provision of water to affected villages) this impact could be relatively easily reduced to insignificant. Due to the high reliance on assumed input parameters the confidence in the significance is low. Impact WR1: Pit dewatering potentially resulting in reduced groundwater availability to ecological systems and local communities Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity High Medium Receptor importance or High Medium Magnitude value description Extent of change / threshold High Medium compliance Magnitude rating MAJOR MODERATE Duration Medium term Medium term Timeframe Frequency - - description Timeframe rating MEDIUM TERM MEDIUM TERM Spatial Scale SMALL SMALL U3823_Marampa_ESIS_Final.docx September 2012 Page 142 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact WR1: Pit dewatering potentially resulting in reduced groundwater availability to ecological systems and local communities CONSEQUENCE RATING MEDIUM MEDIUM PROBABILITY RATING DEFINITE UNLIKELY SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility / sustainability Reversible Confidence Low Management measures • Provide affected villages with adequate water supply (including for irrigation of crops). • Consider installation of new wells / maintenance or repairs to existing village wells. • If necessary, make alternative wetland areas available for rice cultivation. 7.2.2 WR2: Surface water abstraction affecting downstream users Construction Operation Decommissioning Post-Closure 3 A preliminary water balance established for the Project, indicates approximately 8,000m of make-up water per day would only be required during the dry season (to supplement recycled process water and stormwater collected in the TSF settlement ponds). This make-up water will be pumped directly from the Rokel River at a location south of the beneficiation plant. Once the Project is operational it is anticipated that containment, controls and mine dewater input will provide routine closed cycle use with top-up from the river supply if and when required. Water abstracted directly from rivers has the potential to reduce the volumes of annual flow, change the seasonal distribution of flows through the year and increase the length of low flow periods. A qualitative assessment of the impact of abstraction from the Rokel River on flow rate has been made by SRK based on baseline data and the abstraction rates estimated in the preliminary mine water balance provided by MIOL. Under high flow conditions, the abstraction proposed is likely to be negligible compared to the likely flow rates in the river. Assessment of the low flow conditions in the Rokel River reveals 3 the lowest average flow rate near the Project area during the dry season is 6.1m /s (around March). The maximum abstraction rate for make-up water for the mine is estimated to be 3 0.35m /s, or 5.7% of the available river flow at the driest recorded conditions (worst case). In terms of constraints on the flow downstream where it might support communities (e.g. for irrigation and drinking) and aquatic ecosystems, the impact of such a reduction is likely to be negligible taking into account contribution to flow from elsewhere in the catchment (outside the concession). This preliminary prediction will be confirmed based on further monitoring of the Rokel River and once abstraction needs for operation are confirmed. Due to the relatively small proportion of river flow abstracted, the impact is expected to be minor but would extend for the life of the mine, albeit at a low frequency (only in the dry season). As the abstraction is unlikely to impact on downstream users the impact is considered to be of low significance and no management measures are required. Good practice measures are however listed. U3823_Marampa_ESIS_Final.docx September 2012 Page 143 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact WR2: Surface water abstraction affecting downstream users Residual or optimised impact (taking Impact characteristics Initial impact cognisance of management measures) Type (+ / - /neutral) Negative - Sensitivity Low - Receptor importance or Low - Magnitude value description Extent of change / threshold Low - compliance Magnitude rating MINOR - Duration Medium term - - Timeframe Frequency Low - description Timeframe rating MEDIUM TERM - Spatial Scale INTERMEDIATE - CONSEQUENCE RATING MEDIUM - PROBABILITY RATING UNLIKELY - SIGNIFICANCE RATING LOW (-ve) - Reversibility / sustainability Reversible - Confidence High - Good practice measures: • Minimise the abstracted volume, as far as practicable. • Monitor either river stage or flow for the life of the mine to detect any negative impacts to river flow. 7.2.3 WR3: Project infrastructure causing altered surface water flow conditions, affecting downstream users Construction Operation Decommissioning Post-Closure The positioning of Project infrastructure will in some cases lead to changes in stormwater runoff regimes over the site, affecting catchment characteristics and responses. The changes that could arise are as follows: • Alteration to catchment area and characteristics (topographical, land use, slopes) • Potential alteration in catchment response time and peak flow in rivers and streams associated with reduced catchment areas and altered characteristics Proposed stormwater management measures at the main mine infrastructure (WRD, TSF and open pits) are described in Chapter 4, and consist mainly of stormwater settlement ponds (to collect water from the WRD and area surrounding the pits). Due to the surrounding topography, stormwater will naturally be directed away from the TSF and additional stormwater management at this site will not be required. In addition to this, a number of streams run through the area of the proposed Mafuri and Gafal pits (see Figure x). To accommodate pit development, significant alteration of the drainage network via the diversion of the Kagbu River will be required. The river will also be impounded U3823_Marampa_ESIS_Final.docx September 2012 Page 144 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report upstream of the pit area to create a water storage reservoir, the spillway for which will serve as an outflow into the above-mentioned diversion. Preliminary diversion plans are summarised in Section 4.2.2 and described in more detail in the preliminary Surface Water Management Plan for the Project (Mining Solutions, 2012), which is included as Appendix E. The stream diversion and water storage reservoir are expected to cause the most significant impacts on stream flow conditions resulting from the Project, particularly affecting downstream catchments and river flow, as described below and illustrated on Figure 7.1. Assessment method A qualitative (and where possible quantitative) assessment of changes to surface flow conditions was performed by SRK using data gathered as part of the baseline water resources study and other relevant reports produced for the Project, as follows: • Reduction in catchment areas quantified using ArcGIS; • Expected changes in catchment characteristics modelled (using hydrologic engineering centre’s river analysis system (HEC-RAS)) and assessed based on the surface water management plan (Mining Solutions, 2012); and • 1 in 100 year peak flows calculated (based on rainfall extremes, in the absence of monthly average flow estimates). The results indicate that sub-catchment areas will be reduced (due to the footprint of the mine pits), but the increase in compacted or impermeable surfaces (through construction of roads, buildings, WRD and any other hard surfaces) would cause an increase in runoff rates. These catchment alterations will result in changes to the rivers’ response to rainfall events, with a likely increased susceptibility to flooding. The predicted net effect on river peak flow (for a 1 in 100 year rainfall event) will be a reduction in 26 of the 36 sub-catchments in the area (see Table 7-3), which will be most significant in the subcatchments directly downstream of the water storage reservoir and stream channel diversion around the Mafuri pit (as described in Section 4.2.2, and shown relative to the subcatchments and flow directions in Figure 7.1). The locations of the various catchments and subcatchments are shown on Figure 5.5. The diversion spillway controlling flow will result in a reduction in flow in subcatchments KA10, 2 KA17 and KA18. In KA17 this reduction (due to a decrease in catchment size from 46.1 km 2 to 0.6 km (99%)) is predicted to be as much as 97% (at 100 year peak flow – under average flow this is likely to be significantly less). A significant increase in peak flow (81%) is predicted 2 2 in subcatchment KA8 only due to an increase in catchment size (from 2.2 km to 44.1 km (95%)) resulting from the proposed stream diversion flowing into this subcatchment. Subcatchments in other parts of the Project area are also predicted to show significant reductions in peak flow (up to 83%, as shown in Table 7-3) due to the positioning of Project infrastructure, reducing catchment area. In most cases the predicted proportional reduction in catchment area and peak flow are similar. Changes to flow under average or low flow conditions have however not been determined (due to lack of monthly flow estimates), but are expected to be significantly less than the 100 year peak flow. U3823_Marampa_ESIS_Final.docx September 2012 Page 145 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 7-3: Predicted changes to 1 in 100 year peak flows and catchment areas for sub- catchments in the Project area Maximum predicted increase/decrease (%)14 Sub-catchment Area (%) Peak flow (%) KA1 - 15.6 - 16.8 KA2 No change No change KA3 No change No change KA4 No change No change KA5 No change No change KA6 No change No change KA7 - 65.0 - 65.0 KA8 + 95.0 + 81.4 KA9 - 10.2 - 11.1 KA10 - 8.4 - 62.1 KA11 No change No change KA12 - 6.5 - 7.1 KA13 - 3.6 - 3.9 KA14 - 2.8 - 3.1 KA15 - 2.6 - 2.9 KA16 - 4.5 - 5.0 KA17 - 98.6 - 97.3 KA18 - 7.6 - 72.7 BA1 - 16.8 - 18.0 BA2 - 9.3 - 10.2 BT1 - 83.3 - 83.3 BT2 - 65.8 - 66.5 BT3 No change No change BT4 No change No change BT5 - 8.4 - 9.3 BT6 - 6.9 - 7.6 BN1 - 68.0 - 69.7 BN2 - 53.2 - 55.8 BN3 - 41.0 - 43.6 BN4 - 45.3 - 48.2 BN5 - 36.1 - 38.4 RL1 - 66.7 - 66.7 RL2 - 68.4 - 69.8 RL3 - 61.2 - 63.9 RL4 - 5.0 - 5.3 RL5 No change No change Expected impact on other users The above-mentioned changes in river peak flow could impact on both human and ecological users downstream. Decreases in flows could affect water availability to villages downstream, particularly those in the area of the Gafal and Mafuri pits due to the stream diversion and water storage reservoir as discussed above. However, most of the villages in this area will be 14 Indicated by a + (increase) or – (decrease) U3823_Marampa_ESIS_Final.docx September 2012 Page 146 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report relocated to accommodate the pits, and those remaining are located close to the Rokel River, which it is assumed would provide an alternative surface water resource if necessary. Due to the size of the Rokel River, and the fact that changes to the flow in the Kagbu River under low and average flow conditions at its confluence with the Rokel are likely to be minor, impacts on flow in the Rokel River are considered to be minimal. This will be further assessed and confirmed quantitatively once a further wet season survey (including monitoring of river flow) has been conducted. The most significant impact is expected to be on aquatic ecosystems in the area, due to habitat loss and/ or alteration caused by the stream diversion. In-stream habitats will be lost from the sections of the streams to be diverted from their natural flow path (approximately 600 m). Most of the affected aquatic ecosystems are seasonal midslope wetlands, and are classified as moderately modified (mainly due to transformation for rice cultivation) and of low- medium ecological importance (Nepid, 2012). Despite the relatively limited diversity of instream habitats, they are characterised by a high diversity of taxa, particularly fish species (Ecorex, 2011); therefore the stream diversions will need to include key habitat features to maintain fish populations during the dry season. A recent decline in fish populations in the area was however observed during the Nepid 2012 dry season survey, and could be attributed to existing disturbance (possibly caused by construction linked to other Projects in the area). Downstream of the Mafuri pit, the diverted section will reconnect to a tributary of the Kagbu River, which will also be affected due to altered stream flow as described above. The impact will therefore extend beyond the mine footprint area. Although the pits will be backfilled post-closure, much of the other mine infrastructure will remain in place (including the stream diversion and water storage reservoir). The changes to flow dynamics are therefore considered to be permanent. Management measures are recommended to reduce the likelihood of the impact (through replacement of instream habitats lost) and reduce its significance. Additional studies to determine the impact under low and average flow conditions are required, and the confidence of the impact rating is therefore medium. Changes to flood risk for surrounding areas due to the above-mentioned water diversion and impoundment is discussed and rated separately in Impact WR4 (Section 7.2.4). Increases in erosion potential associated with increased runoff rates are discussed under Impact LT4 (Section 7.1.4), and the resultant increased sedimentation of surface waters (affecting ecological systems) is discussed under Impact WR6 (Section 7.2.6). U3823_Marampa_ESIS_Final.docx September 2012 Page 147 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 7.1: Catchment areas affected by surface water diversion and storage infrastructure, indicating flow directions U3823_Marampa_ESIS_Final.docx September 2012 Page 148 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact WR3: Project infrastructure causing altered flow conditions, affecting downstream users Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity High Medium Receptor importance or Medium Medium Magnitude value description Extent of change / threshold High Medium compliance Magnitude rating MAJOR MODERATE Duration Long term Long term Timeframe Frequency - - description Timeframe rating LONG TERM LONG TERM Spatial Scale INTERMEDIATE INTERMEDIATE CONSEQUENCE RATING HIGH MEDIUM PROBABILITY RATING DEFINITE POSSIBLE SIGNIFICANCE RATING HIGH (-ve) MEDIUM (-ve) Reversibility Irreversible Confidence Medium Management measures • Implement erosion control measures listed in LT4. • Design surface water diversion channels to mimic the natural instream habitat as closely as possible, and rehabilitate using indigenous vegetation.  • Include key instream habitat features, such as deeper pools, to maintain fish populations during the dry season in stream diversion channels. Good practice measures: • Avoid disturbance of drainage lines and riparian zones where possible, through careful routing of roads and servitudes. • Use semi-permeable materials where possible in preference to impermeable materials for surfaces such as roads and paving. • Monthly average flow for each river should be measured for at least a year, and used to determine impacts during non-peak river flow. 7.2.4 WR4: Surface water diversions potentially causing changes to flood risk to adjacent agricultural areas and communities Construction Operation Decommissioning Post-Closure When changes to a river’s course are made (such as the proposed stream diversion to accommodate the Mafuri and Gafal pits), this can alter its flow regime local to that diversion and impacts may occur either upstream or downstream relative to that alteration. In the case of the Kagbu River Diversion (also referred to as the Mafuri West Diversion), the change in U3823_Marampa_ESIS_Final.docx September 2012 Page 149 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report direction of flow and slope and the impact this has on flood risk of the surrounding area have been assessed (through hydraulic modelling by SRK) both upstream and downstream of the diversion itself. For this particular diversion the likely risk areas are: • Immediately upstream of the diffluence (upstream connection), where some backing up of water could occur as a result of the rather sharp change in direction of flow caused by the diversion. • Downstream of the confluence (downstream connection), where the change in flow direction and likely change in bed slope as the diversion re-joins the old river alignment may result in scour of the left bank and some degree of eddying. • Along the diversion itself, given its close proximity to the Mafuri Pit West (within 50m). As no specific details for the design of a flow control structure (weir, spillway or sluice) are available at this stage in planning, various assumptions were made when modelling potential impacts, including that flow through the diversion is controlled by the geometry of the new diversion channels. Flood routing and peak outflow through the water storage reservoir were calculated, and used as input for the hydraulic modelling. Due to the significant increase in catchment area and peak flow of catchment KA8 resulting from the stream diversion (as described in Impact WR3), the area with the greatest flood risk is predicted to be the middle to lower reaches of the diversion. Due to the river size however, change in water level (and therefore flood risk) downstream of the diversion is likely to be low. The HEC-RAS modelling results predict that during a 1 in 100 year flood the water will remain within the banks of the diversion channel, although water level will increase (by 0.31 – 0.59 m) downstream of the diversion. As the modelling is based only on preliminary design data, revised modelling will be required to confirm these results once the design has been finalised. Other subcatchments in the area could also be affected by the diversion (as discussed in Impact WR3 and illustrated on Figure 7.1) but this will be by way of reduced flows and therefore will reduce flood risk in these catchments. Almost all valleys within the Project area are cultivated, mostly with different varieties of rice. 2 The water storage reservoir created will cover a surface area of approximately 400,000 m and although much of this area is currently river, it will also extend into areas currently used for subsistence agriculture (rice paddies and small patches of mango plantation). However as villages in the area will be relocated it is uncertain whether these areas would still be used for agriculture as the villages may seek to cultivate areas closer to the new village locations (still be determined). The impact on livelihoods associated with loss of access to land and natural resources is discussed in Impact LT1 (Section 7.1.1), and rated in Impact RL1 (Section 8.2.1). Flooding is one of the most common natural disasters affecting Sierra Leone, and between 1980 and 2010 affected approximately 200,000 people (EM-DAT, 2012). It is therefore expected that local communities will be sensitive to an increased flood risk. The relatively flat topography of the study area and location of villages close to rivers (supporting access to water and use of floodplains for agriculture) both support the notion that local communities are highly susceptible to flooding. However, as most villages in the immediate downstream area of the diversion will be relocated due to positioning of the mine pits, impacts on local communities are considered to be unlikely. Although the stream diversion is likely to be a permanent feature, the frequency of occurrence of the impact would be low (i.e. during flood events only). No management measures are proposed. U3823_Marampa_ESIS_Final.docx September 2012 Page 150 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact WR4: Surface water diversions potentially causing changes to flood risk to adjacent agricultural areas and communities Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity Medium - Receptor importance or Medium - Magnitude value description Extent of change / threshold Medium - compliance Magnitude rating MODERATE - Duration - - Timeframe Frequency Low - description Timeframe rating LOW FREQUENCY - Spatial Scale INTERMEDIATE - CONSEQUENCE RATING MEDIUM - PROBABILITY RATING UNLIKELY - SIGNIFICANCE RATING LOW (-ve) - Reversibility Irreversible - Confidence Medium - Good practice measures: • Implement erosion / sedimentation control measures listed in Impacts LT4 and WR7 in and around diversion channels. • Include flood risk in the Emergency Response and Preparedness Plan and raise awareness with potential affected communities of the risks and what to do in the event of a flood. • Update the preliminary water management plan. 7.2.5 WR5: Seepage from mining wastes potentially resulting in deteriorated groundwater quality affecting communities and ecological systems Construction Operation Decommissioning Post-Closure Groundwater quality has the potential to be negatively impacted due to seepage of process water from mine wastes at the following locations: • waste rock dumps • tailings storage facility • low-grade ore stockpiles Seepage may occur directly from these facilities or from their associated storm water control facilities, and infiltrate through the soil into the underlying groundwater system, where it would spread through the aquifer. Regional groundwater flow in the area is to the southwest, so any seepage entering the groundwater is most likely to affect users to the southwest of the source. Pit dewatering (as discussed in Impact WR1) may also affect the spread of the seepage-affected groundwater during mining and the post-mining recovery stage, causing U3823_Marampa_ESIS_Final.docx September 2012 Page 151 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report groundwater in the vicinity of the pits to flow towards the pits. Seepage to groundwater occurring within the cone of depression for each pit (estimated to extend up to 1 km from each pit, which includes most of the WRDs), is therefore likely to be drawn into the pits. Dilution effects reduce the concentrations of constituents from the seepage, but even so these could potentially negatively impact on groundwater users in terms of deteriorated water quality. Many local villages use groundwater drawn from village wells as their primary source of potable water. Deteriorated water quality could therefore potentially impact negatively on the health of local communities. At closure, the TSF and WRDs will continue to be sources of seepage as they are permanent features. These aspects are briefly examined below and qualitatively evaluated based on planned design concepts and the results of geochemical investigations conducted to date. Waste rock dumps and ore stockpiles Geochemical investigations have been completed on waste rock samples from the four pits, as well as the expected ore, concentrate and tailings materials. These reveal low potential for acid generation. Leaching of metals from the waste rock is considered unlikely, and as discussed above, the WRDs generally fall within the cone of depression surrounding the pits. TSF Geochemical characterisation of the tailings material indicates it is unlikely to generate acidity, but will also have limited buffering capacity. Net acid generation (NAG) test leachate analysis of tailings samples also revealed little potential for leaching of iron or trace metals from the metallurgical samples. A decant system and under drainage will be constructed in the TSF to recover supernatant water from consolidation of the tailings material. This system will also reduce the potential for seepage losses to soil and groundwater. Based on the discussion above no significant impacts on groundwater quality in the area are expected to result from seepage from mine wastes, and no management measures are therefore proposed. Due to the inherent design measures listed above and the low likelihood of metal leaching or acid generation from the sources examined, seepage from mining wastes is unlikely to occur. The potential for the impact to occur would however last beyond the life of the mine if not permanently as (apart from the ore stockpiles) these sources will remain on the site, and any contaminated groundwater would affect villages beyond the Project footprint. Further geochemical characterisation of the expected waste rock and tailings material is however required to confirm the preliminary findings. U3823_Marampa_ESIS_Final.docx September 2012 Page 152 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact WR5: Seepage from mining wastes potentially resulting in deteriorated water quality affecting communities and ecological systems Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative - Sensitivity Low - Receptor importance or Low - Magnitude value description Extent of change / threshold Low - compliance Magnitude rating MINOR - Duration Long term - Timeframe Frequency - - description Timeframe rating LONG TERM - Spatial Scale INTERMEDIATE - CONSEQUENCE RATING MEDIUM - PROBABILITY RATING UNLIKELY - SIGNIFICANCE RATING LOW (-ve) - Reversibility / sustainability Irreversible - Confidence Medium - Good practice measures: • Further geochemical characterisation of expected waste rock and tailings material to confirm preliminary findings. 7.2.6 WR6: Discharges or runoff to surface water potentially resulting in deteriorated water quality affecting communities and ecological systems Construction Operation Decommissioning Post-Closure Impacted discharge waters i.e. mine site run-off that potentially has low (acidic) pH or contains elevated levels of naturally occurring metals or sediment has the potential to be generated in the following areas: • discharge of excess water from open pit dewatering; • drainage from waste rock dumps; • drainage from the tailings storage facility; • stormwater runoff from exposed surfaces; and • accidental spills (e.g. from pipelines or during transportation). Each of these is briefly discussed below and qualitatively evaluated based on planned design concepts. The most significant impact to surface water quality however is expected to arise from mobilisation of soils from exposed surfaces during mining activities at all stages of the Project, and may also be associated with the effluent discharges listed above. U3823_Marampa_ESIS_Final.docx September 2012 Page 153 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Discharge of excess water from pit dewatering The excess water from open pit dewatering will be pumped to settlement ponds before release to the natural watercourses draining to the Rokel River, with a proportion directed to the TSF during the dry season. Further monitoring and characterisation of groundwater chemistry in the vicinity of the pits is being undertaken but, based on currently available data, there are no specific contaminants of concern. Drainage from waste rock dumps Drainage channels will be constructed around waste rock dumps and through the waste dump slopes, as necessary, to direct the surface water flow to the settlement ponds. The settled water in the ponds will be released to the environment with regular water quality tests performed to monitor the quality of the discharge. If the water in the pond exceeds the agreed water quality standards, it will be contained until it complies or be redirected to the TSF if it cannot meet the required standards. Drainage from the TSF A decant system and under drainage will be constructed in the TSF to recover supernatant water from consolidation of the tailings material. This system will also reduce the risk of embankment failure. Water collected in the under drainage system will be pumped back to the plant for re-use during processing. An emergency spillway will also be installed as part of the TSF design to manage discharge under emergency conditions, should this be needed (to ensure the safety of the dam wall – refer to Impact OH2 in Chapter 0). Stormwater runoff from exposed surfaces Leaching of metals from exposed soils (via stormwater runoff) may cause chemical changes to surface water systems. The mobile constituents are those that can be easily removed from the soil via rainfall and flood waters, and include both metal ions and soil nutrients. Short- term leaching tests conducted on the soil samples indicate low levels of leaching, with the exception of iron and zinc that are mobile constituents and may be leached from the soils. Accidental spills There is a risk of uncontrolled release of ore, waste rock or tailings material, or domestic wastewater (e.g. from the accommodation camp) to surface water resources arising from an accident or incident during transportation of waste or materials on the site (such as a pipeline breakage or a truck overturning). Geochemical characterisation of these materials is discussed above, and provided standard precautionary measures are in place (such as secondary encasement of pipelines crossing watercourses and enforcement of safe driving practice); this impact is not considered to be significance. Product export outside the mine site has not been assessed in this ESIA. Mobilisation of soils in stormwater runoff Vegetation stripping and ground exposure makes the soils prone to erosion. Stormwater runoff from disturbed areas may pick up fine particles and other pollutants (such as mobile constituents) which may be discharged into down-gradient surface waters. Changes to surface water flow regimes resulting from changes to stormwater patterns are discussed under Impact WR3. The impact on land use potential as a result of loss of topsoil through erosion is discussed and rated under Impact LT4 (Section 7.1.4). The discussion below will therefore focus on impacts on surface water resources due to increased sedimentation. U3823_Marampa_ESIS_Final.docx September 2012 Page 154 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Mobilisation of soils is likely to be greatest during the construction phase, as a result of land modification necessary for the construction of the mine pits and associated surface infrastructure. Impacts associated with disturbance of soils are considered to be lower during the operational and closure phases than during construction as exposed ground areas will be minimal, haulage roads will be sealed and traffic movements restricted, stockpile areas stabilised and topsoil reinstated following remediation. Site works during closure for remediation and rehabilitation of the site will result in some exposure of ground areas, but this will be on a much smaller scale than during construction and areas will be re-vegetated. Particularly due to the high rainfall during the wet season, effective drainage networks will be required to manage stormwater around mine infrastructure. The water management plan for the mine will be further developed to provide a strategy for segregating impacted and non- impacted (clean) water. Storm water settlement ponds will form part of the drainage network to collect impacted water runoff from the mine infrastructure. During normal operations, the sediment ponds will be cleaned out during the dry season, with the collected sediment placed on the waste dumps for long term storage. Summary Baseline surface water quality in the area is characterised by low metal concentrations, and moderately acidic to near-neutral pH, with little or no buffering capacity against acid inputs. Different users also have differing sensitivities to pollutant levels. In this case, both human users of water (for domestic, agricultural or industrial purposes) and downstream ecological systems could be impacted by decreased water quality, causing negative health effects. Due to the inherent design measures in place, and the relatively inert nature of the impact sources, chemical pollution of surface water resources is considered to be unlikely and of minor significance. Sedimentation is therefore considered to be the most significant impact relating to surface water quality, in some cases making it unsuitable for domestic use, and is the impact rated below. As the impact is most likely to occur during the rainy season when groundwater levels are elevated however, domestic users are likely to have access to other water sources, reducing the significance of the impact on them. Impacts on aquatic ecosystems could however be significant, affecting filter feeding organisms, aquatic vegetation (through reduced light penetration), and predator-prey interactions (through reduced visibility). Increased turbidity and siltation is considered to be the most significant threat to aquatic ecosystems in the area resulting from the Project. Current turbidity levels in local streams are low, resulting in good natural light levels penetrating the water column. Although ecological habitats in the Project area are classified as moderately modified, abundance and diversity of submerged aquatic vegetation and fish species are high, including some species of conservation concern. Impacts on aquatic organisms would in turn affect local communities in terms of decreased stocks and quality of fish and other organisms harvested from local watercourses. Downstream ecological systems in particular are likely to be highly sensitive to this impact, which is likely to extend in duration until decommissioning has been completed and the area has been rehabilitated. With effective management (primarily via erosion control mechanisms) however, the impact would be unlikely to occur, reducing its significance rating to low. U3823_Marampa_ESIS_Final.docx September 2012 Page 155 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact WR6: Discharge or runoff to surface water potentially resulting in deteriorated water quality affecting communities and ecological systems Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity High High Receptor importance or High High Magnitude value description Extent of change / threshold High High compliance Magnitude rating MAJOR MAJOR Duration Medium term Medium term Timeframe Frequency - - description Timeframe rating MEDIUM TERM MEDIUM TERM Spatial Scale INTERMEDIATE INTERMEDIATE CONSEQUENCE RATING MEDIUM MEDIUM PROBABILITY RATING DEFINITE UNLIKELY SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility / sustainability Irreversible Confidence High Management measures • Plan and implement a comprehensive erosion control programme, including erosion and dust control measures listed in Impacts LT4 and AQ1. • Use sedimentation control techniques such as installation of straw bales buffers in drainage lines downstream of potential sources of increased sediment load. • Implement a Water Management Plan for the site. • Implement a comprehensive Rehabilitation and Closure Plan, which includes rehabilitation of the backfilled pits, WRD and TSF to prevent post-closure discharge, and revegetation to ensure continued erosion control. • Where practicable, separate clean and “dirty” (i.e. with elevated levels of contaminants) stormwater and handle to two categories differently. • Ensure clean water is piped to the outlet point and not allowed to flow freely where it may cause erosion. Good practice measures: • Avoid construction activities in the Bankasoka River catchment area (northern portion of the TSF area), which is ecologically sensitive. • Implement a water quality monitoring programme (continuing post-closure) to detect changes to surface water quality and take the required remediatory actions. • Implement a surface water biomonitoring programme (as per the specialist recommendations) to monitor effects on aquatic ecosystems. • Implement a spill management programme, which includes preventive measures such as secondary containment of pipelines crossing water courses and bunding of hazardous liquids stored on site. U3823_Marampa_ESIS_Final.docx September 2012 Page 156 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 7.3 Ecology and biodiversity Many of the aspects discussed above which cause impacts to land and water can cause impacts on natural habitats as well, thereby affecting the ecology and biodiversity of the mine footprint and surrounding areas (including aquatic habitat). This includes the following: • Temporary or permanent surface disturbance (including clearing of vegetation) for construction of Project infrastructure, resulting in direct loss of faunal and floral communities, and proliferation of alien invasive species; • Haul roads, fences, pipelines or other barriers to movement, resulting in habitat fragmentation; • Dewatering of pits resulting in groundwater drawdown, affecting wetland and other habitats; • Noise and vibrations from equipment and blasting, disturbing fauna; • Illumination of Project infrastructure, disturbing fauna; • Fugitive dust from Project activities, affecting vegetation and fauna (including aquatic species); • Surface water abstraction or diversion, affecting availability to downstream aquatic habitats; • Change in chemical characteristics of water bodies due to discharges; • Human population influx to the area, resulting in increased pressure on natural resources; • Decommissioning, reprofiling and rehabilitation of the mine footprint area Impacts on ecology and biodiversity include direct loss of fauna and flora, both at the individual and community levels as well as fragmentation, modification or loss of habitat, and indirect impacts through various types of disturbance, pollution or sedimentation of water courses. As much of the study area is already transformed, predominantly through subsistence agriculture and previous mining activity in the area, this is taken into account in the rating of the impacts described below. Impacts on both terrestrial and aquatic environments have been assessed. 7.3.1 EB1: Site clearance and positioning of Project infrastructure potentially resulting in habitat loss and fragmentation, and direct loss of fauna and flora Construction Operation Decommissioning Post-Closure Habitat loss as a result of the Project is likely to occur through: • direct modification of land through site clearance for Project infrastructure, as discussed under Impact LT1 (Section 7.1.1); • indirect modification of land adjacent to cleared areas, resulting in habitat loss due to anthropogenic effects and erosion (discussed under Impact LT4 in Section 7.1.4); and • indirect loss of wetland habitats through pit dewatering as discussed under Impact WR1 (Section 7.2.1). In addition to permanent changes to certain footprint areas within the mine area, there will be temporary disturbance during construction (and to a certain extent during decommissioning) of areas for laydown / storage of materials, access tracks and a construction camp. The location and extent of these areas have not yet been determined. Impacts on communities as U3823_Marampa_ESIS_Final.docx September 2012 Page 157 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report a result of loss of agricultural land, areas for hunting, fishing and harvesting or a reduction in land capability is discussed and rated separately under Impact RL1 (Section 8.2.1). Terrestrial habitats and species of conservation concern A number of the terrestrial habitat types identified and described in Section 5.9.1 will be affected by Project infrastructure. Some of these habitats (primarily gallery forest but also swamp forest and flooded grassland) are considered to be of high functional value due to their potential for high biodiversity, threatened species and present ecological state. However very little of these habitat types (only a small area of gallery forest) were identified within the direct mine footprint area. As no endangered or critically endangered terrestrial species were confirmed or are likely to occur within the study area, however, the habitat is not considered to be of critical conservation importance. The areas of each habitat type lost due to direct disturbance and construction of the major mine site infrastructure is shown in Table 7-4. A large proportion of the study area (including wetlands) is already transformed due to subsistence agriculture and shows secondary vegetation re-growth. The diversity of terrestrial mammals is therefore limited in the area. Only the lowland forest along the Rokel River (consisting of gallery and swamp forest, the indigenous habitat type) is of conservation concern, both due to its extremely limited distribution (covering less than 0.1% of the Project study area in excess of 40,000 ha), and the diversity of species it supports (including wild plants used by local communities). Of these, three plant species of conservation significance, one near-threatened mammal and two primate species are present in the gallery forest increasing the significance of the impact of loss of this habitat. Some of this habitat will be directly impacted and indirect impacts associated with changes to hydrogeological regimes are also possible (Impact WR3). Table 7-4: Area of each habitat type directly impacted by the Project Natural habitat type Area directly impacted (ha) Flooded natural grassland 0 Gallery forest 1.25 Rice wetlands 3,949.15 Secondary forest / farmbush mosaic 35,431.29 Secondary savannah 75.52 Swamp forest 0 Rivers 0 One of the major secondary impacts resulting from vegetation clearance and land disturbance is erosion – both of topsoil, which is discussed under Impact LT4 (Section 7.1.4), as well as erosion along river banks, resulting in further loss of riparian habitat. For this reason it is particularly important that the lowland forest found in narrow strips along the river banks, and providing flood attenuation and bank stabilisation, is not disturbed. This habitat type is however limited in the study area to a very small area along the northern bank of the Rokel River, close to the Rotret WRD, another area west of the Rotret WRD, and an isolated area where the TSF is planned to be located. Except for the TSF, these fall outside the direct mine site footprint. Habitat fragmentation as a result of the positioning of Project infrastructure and other areas of disturbance is likely to affect movement of fauna between areas for activities such as breeding and foraging or hunting for food and could result in injury or death through crossing infrastructure such as roads. U3823_Marampa_ESIS_Final.docx September 2012 Page 158 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report The area supports a wide diversity of bird species, particularly in the secondary forest / farmbush, which is widespread throughout the study area. Birds are likely to move away from the area and settle in similar habitat nearby once land disturbance begins. In the case of the lowland forest habitat that supports a large number of bird species (18 of which are forest specialists), similar habitat is extremely limited in the surrounding area. What is present in the area is generally close to mine infrastructure (mainly the Rotret waste rock dump) and therefore subject to sensory disturbance (discussed in Impact EB3 (Section 7.3.3)) possibly making it a less attractive habitat for most species. Secondary savannah habitat also supports high biodiversity of bird species. This habitat type is restricted to a small area in the Project area and will be partially lost due to construction of the Mafuri pit. Land disturbance and clearing of vegetation will lead to a localised reduction in food and habitat for mammals, birds and herpetofauna (reptiles and amphibians). Although much of the fauna would migrate from the area to adjacent undisturbed areas, accidental death of some small mammals and reptiles that are not able to move away prior to preliminary earthworks is expected. The closure phase is seen as an opportunity to re-establish vegetation consistent with the surrounding area. However, rehabilitation of disturbed areas will require ongoing maintenance (such as watering, erosion control and control of alien invasive vegetation) until the vegetation is established and sufficient groundcover has been achieved. Rehabilitation of the site would also be expected to encourage displaced fauna species to return to the area with time, however a return to the pre-mining ecological state (particularly in forest areas) is unlikely. The permanent features left after mining, such as the waste rock dumps and pits, provide a different habitat to that found pre-disturbance and may encourage slightly different ecosystems to form. Aquatic habitats and species of conservation concern As stated in Impact WR1 (Section 7.2.1), groundwater drawdown associated with pit dewatering may desiccate and thereby reduce the extent of wetland ecosystems within the area surrounding the pits (up to 1000 m radius for the Matukia and Gafal pits). Wetland habitat in the study area is important both for agriculture (rice cultivation), covering almost all wetland areas, as well as for supporting indigenous species in habitats such as the flooded natural grassland, swamp and gallery forest habitats. The Rokel River and its associated riparian forest are considered to be the areas of highest conservation importance, due to the species they host. The loss of rice cultivation areas will impact on local communities in terms of food security and is rated in Impact WR1 (Section 7.2.1). The five aquatic habitat types identified in the study area are classified as modified, but the high fish diversity in the Rokel River indicates it to be in good ecological health and thus vulnerable to indirect impacts from changes in the hydrogeological regime. The seasonal valley head wetlands (used mainly for rice cultivation) host high numbers of fish, including species of conservation concern. Two vulnerable, one near-threatened and one endangered species, Epiplatys lokoensis, were recorded in the Project area. The conservation status of E. lokoensis is however pending downgrading from its current status of “Endangered” to “Vulnerable” (Ecorex, 2011). Summary Much of the area is no longer ecologically pristine, and no terrestrial species or habitats of critical conservation importance are present in the area. However, due to the presence of a number of fish species of conservation importance, aquatic habitats in the area are U3823_Marampa_ESIS_Final.docx September 2012 Page 159 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report considered to be of conservation importance (though due to the above-mentioned downgrade in conservation status, this would not be critical). The impact is therefore considered to be of moderate magnitude. Without successful rehabilitation much of the area will remain ecologically impacted beyond the life of the mine, if not permanently. Loss of individuals and habitats will be unavoidable, but is unlikely to significantly affect the ecology outside the area surrounding the Project footprint as the individuals are not highly endemic or specific to a particular area with the exception of the bird species associated with the gallery forest. Effective management (primarily via minimising the disturbance footprint, especially of sensitive areas) could decrease the probability and extent of the impact, thereby decreasing its significance. Due to some uncertainty in the robustness of the ecological system to respond to these changes, the confidence in the rating is given as medium. Impact EB1: Site clearance and positioning of Project infrastructure potentially resulting in habitat loss and fragmentation, and direct loss of fauna and flora Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity Medium Medium Receptor importance or Low Low Magnitude value description Extent of change / threshold Low Low compliance Magnitude rating MINOR MINOR Duration Long term Long term Timeframe Frequency - - description Timeframe rating LONG TERM LONG TERM Spatial Scale INTERMEDIATE SMALL CONSEQUENCE RATING MEDIUM MEDIUM PROBABILITY RATING DEFINITE UNLIKELY SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility / sustainability Partially reversible Confidence Medium Management measures • Where possible adjust positioning of Project infrastructure during planning to avoid gallery forest and wetland habitats. • Clear vegetation in phases working progressively in one direction so that fauna have an opportunity to move to adjacent areas. • Stockpile topsoil and manage topsoil clearing as per the recommendations listed in Impact LT4, for use during rehabilitation. U3823_Marampa_ESIS_Final.docx September 2012 Page 160 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 7.3.2 EB2: Soil disturbance facilitating the establishment and spread of invasive species, potentially affecting indigenous ecosystems Construction Operation Decommissioning Post-Closure Clearing or disturbance of vegetation and soil for construction of the mine and associated infrastructure will result in these areas being vulnerable to erosion (discussed in Impact LT4 in Section 7.1.4) as well as to infestation by exotic (or alien – i.e. introduced from elsewhere) and invasive vegetation species. Due to their rapid growth and general resilience, exotic invasive vegetation tends to proliferate in disturbed areas preventing or retarding growth of indigenous vegetation through competition for sunlight, nutrients, space and water. Once established, they seed quickly and multiply rapidly, establishing a seed bank in the soil. Not being indigenous to the area they are often resistant to indigenous biological control organisms and unpalatable to local fauna. Exposed or disturbed soil therefore presents an ideal opportunity for exotic invasive species growing in the vicinity or brought in from outside to spread and proliferate. For a species to proliferate it would generally need to already be established in the surrounding area. The ecological baseline assessment found significant patches of secondary forest to be infested with the aggressively growing exotic species, Chromlaena odorata (Triffid Weed), which is native to North America (see Figure 7.2). This species easily spreads to adjacent vegetation, smothering the plants around it and preventing successful recruitment of forest canopy species, thereby preventing the recovery of secondary forest to its climax ecological state. It is therefore considered to be one of the major threats to biodiversity in the area and is reported to have become well established in secondary vegetation particularly in the southern parts of the Project area, but was also found in Savannah and Swamp Forest areas (Ecorex, 2011). It is likely that, without adequate management, areas cleared of vegetation or disturbed (primarily during construction and to a lesser extent during decommissioning) will become infested by this species, exacerbating the current problem with alien infestation. Soil erosion and other impacts leading to decreased land capability would also indirectly contribute to the growth of exotic invasive vegetation by retarding the growth of the current vegetation cover. Other development in the area would also increase the likelihood of this impact. As much of the area is already disturbed and the majority of the vegetation is no longer ecologically pristine, as well as the fact that no habitats of critical conservation importance are present in the area, the impact is expected to be of moderate magnitude. Without management, the invasive vegetation would continue to spread and proliferate within the disturbed areas beyond the life of the mine. Effective management would minimise the spread of invasive alien vegetation, and decrease the significance of the impact to low. U3823_Marampa_ESIS_Final.docx September 2012 Page 161 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 7.2: The invasive alien plant Chromlaena odorata (Triffid Weed) Impact EB2: Soil disturbance facilitating the establishment and spread of invasive species, potentially affecting indigenous ecosystems Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity Moderate Moderate Receptor importance or Low Low Magnitude value description Extent of change / threshold Moderate Low compliance Magnitude rating MODERATE MINOR Duration Long term Long term Timeframe Frequency - - description Timeframe rating LONG TERM LONG TERM Spatial Scale SMALL SMALL CONSEQUENCE RATING MEDIUM MEDIUM PROBABILITY RATING POSSIBLE UNLIKELY SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility / sustainability Reversible Confidence High Management measures • Implement an alien plant control management programme, including training of personnel to implement the programme. • Implement rehabilitation as soon as possible, and monitor rehabilitated areas for growth of invasive species. • Implement good practice measures listed in Impact LT1 to minimise the disturbed area. • Implement erosion control measures as listed in Impact LT4. • Remove invasive alien plants before they bear seed and dispose of removed plants appropriately. U3823_Marampa_ESIS_Final.docx September 2012 Page 162 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 7.3.3 EB3: Project activities resulting in sensory or other disturbance to wildlife Construction Operation Decommissioning Post-Closure The Project will result in a number of potential disturbances to species which may exacerbate the effects of loss of fauna and habitat as well as habitat fragmentation (discussed in Impact EB1). These disturbances include increased noise, vibrations, light, dust and a general increase in human and vehicular activity in the area increasing accidental road kill (discussed in Impact TS2) and hunting. As the operations will run for 24-hours a day, the disturbances will be continuous, affecting both diurnal and nocturnal wildlife, and will extend from construction until decommissioning. Increases in noise/vibration through blasting or the operation of mining equipment and light may act as a source of sensory disturbance to birds, herpetofauna, mammals and insects. Sensory disturbances may result in temporary avoidance of the area, disruption of feeding and breeding patterns or permanent displacement of individuals from the area. Although disturbance may result in a loss of fauna around the mine site, mobile animals are likely to move to adjacent replacement areas. For generalist species this is not expected to present a problem. However for habitat-specific species (such as forest endemics) the availability of suitable habitat nearby may be a limiting factor which could result in loss of those species to the area. Changes in species distribution could put pressure on the resources and resident species of surrounding habitats, but as densities of wildlife in the area are already low (due to disturbance) this is not expected to pose a significant impact. Note that light sources can also be an attractant (Impact EB4) to insects and their predators. Project activities during construction and operations will result in increased background dust concentrations and emissions from vehicles and other sources (extent of air quality impacts are discussed in Impacts AQ1 and AQ2). Increased dust deposition on vegetation reduces the photosynthetic capacity of plants and may limit growth and reproductive capacity leading to a decrease in population sizes and potential loss of species, this can be particularly critical for food crops. However, due to high background dust levels in the receiving environment in the dry season, particularly along unpaved roads, the vegetation is likely to be well-adapted to dust and it is unlikely to represent a significant impact. The Project area is already disturbed – Lunsar town borders on the area and villages are scattered throughout, with their associated livelihood practices such as subsistence farming, fishing and hunting; the Makeni highway and the railway to Pepel pass through the area; and two other mines are in operation in relatively close proximity. Hunting and trapping of wildlife already occurs, possibly contributing to the near absence of larger mammals. Improved access to the site (through access roads and other infrastructure providing access through dense vegetation) and more human activity in the area as a result of the Project may indirectly increase the incidence of hunting. However there are few species of conservation concern, and those that are present are unlikely to remain in the area. It is however strongly recommended that the remaining forest areas are protected from further disturbance (perhaps as formal conservation areas, in consultation with local communities) and mining activities close to these areas are minimised. Since much of the area is already disturbed, faunal densities are already low and there are few faunal species of conservation concern, the magnitude of the impact is rated as minor. U3823_Marampa_ESIS_Final.docx September 2012 Page 163 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Disturbances directly related to the Project are likely to decrease during decommissioning, and be largely reversed following closure of the site. Long term impacts are therefore not expected. The disturbance will however be inevitable and will extend beyond the Project footprint to adjacent areas. Due to its low significance, no management measures are proposed, but the implementation of the good practice measures listed is recommended. Impact EB3: Project activities resulting in sensory or other disturbance to wildlife Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative - Sensitivity Low - Receptor importance or Low - Magnitude value description Extent of change / threshold Low - compliance Magnitude rating MINOR - Duration Medium term - Timeframe Frequency - - description Timeframe rating MEDIUM TERM - Spatial Scale INTERMEDIATE - CONSEQUENCE RATING LOW - PROBABILITY RATING DEFINITE - SIGNIFICANCE RATING LOW (-ve) - Reversibility / sustainability Reversible - Confidence High - Good practice measures: • Develop and implement a Wildlife and Habitat Management Plan that: o protects gallery and swamp forest areas from disturbance (see Figure 5.12); o provides awareness training to staff and contractors on: prevention of injury of animals; identification of likely species found on site (and those of conservation concern); identifications of animal hazards (such as venomous snakes); and what to do if dangerous animals are encountered; o requires personnel to report kills of species of conservation concern to the mine’s Environment Management team, who may investigate the incident; o encourages personnel to report sightings of wildlife of conservation importance to the mine’s Environment Management team; and o allows for the monitoring and, if necessary, eradication of any invasive species occurring on site or in surrounding disturbed areas. U3823_Marampa_ESIS_Final.docx September 2012 Page 164 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 7.3.4 EB4: Mine infrastructure and activities attracting nuisance species, potentially resulting in impacts on indigenous ecosystems Construction Operational Decommissioning Post-Closure The Project infrastructure will provide new habitat opportunities for fauna. For example, buildings will provide shade and nesting opportunities for small fauna and birds, water storage areas will be an attractant particularly in the dry season, light will attract insects (and their predators) and waste disposal areas have the potential to provide a food source to scavenger animals such as rodents. However, these attractive nuisances are being created in a hazardous environment and will expose fauna to risks. Domestic waste such as food waste will be produced by the mine site and the accommodation camp and disposed in a landfill area on site which will attract (and pose a potential danger to scavenger animals such as rodents, birds and foxes (and possibly domestic dogs, pigs and goats from nearby villages) if not managed. As a minimum, regular and thorough waste compaction, ensuring wastes are completely covered with soil or other inert material after deposition and fencing of the landfill will be required to keep the presence of scavengers to a minimum. Construction and operation will result in 24-hour illumination of the mine site. Insects may be attracted to the lights at night and this may attract bats to the area which may be vulnerable to drowning in water storage facilities. Water storage facilities may also provide additional breeding areas for mosquitoes increasing their prevalence (and (in theory) potentially also the prevalence of malaria) in the area. The habitat opportunities described above will attract specific species towards the site and will increase the exposure of these animals to hazardous environments or situations, such as toxic water and moving machinery or drowning. This can have implications on local ecosystems with an increase in scavenger animals and their predators, however as there is already existing disturbance in the area the ecosystems are unlikely to be significantly affected. New habitat opportunities may result in a change to the diurnal and nocturnal species composition in the area and could, in theory, result in an increase in animal deaths due to the hazards present. Even with proposed management measures, the risk of animal deaths will be difficult to control but will cease on closure. Any impacts will be restricted to the Project footprint and adjacent disturbed areas. As there is already other developments (creating other sources of attractive nuisance) in the area and species are likely to move away from the area (and therefore are unlikely to be at risk), the magnitude of the impact is rated as minor. Negative impacts that can be directly related to the Project (and not secondary development in the area) would predominantly occur during operation of the site, and will largely cease on decommissioning. Negative impacts are not considered to be of high significance and would be unlikely to occur with effective implementation of the management measures listed. U3823_Marampa_ESIS_Final.docx September 2012 Page 165 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact EB4: Mine infrastructure and activities attracting nuisance species, potentially resulting in impacts on indigenous ecosystems Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity Low Low Receptor importance or Low Low Magnitude value description Extent of change / threshold Low Low compliance Magnitude rating MINOR MINOR Duration Medium term Medium term Timeframe Frequency - - description Timeframe rating MEDIUM TERM LONG TERM Spatial Scale SMALL SMALL CONSEQUENCE RATING MEDIUM MEDIUM PROBABILITY RATING POSSIBLE UNLIKELY SIGNIFICANCE RATING LOW (-ve) LOW (-ve) Reversibility / sustainability Reversible Confidence Medium Management measures • Develop and implement a waste management plan that accommodates all waste types produced on site, particularly food waste. • Manage the landfill site in accordance with good practice standards, including access control and fencing. • Monitor the incidence of drowning in water storage facilities and implement preventive measures if required. • If required, a pest control programme should be implemented, and should include monitoring of accidental death of non-pest species. Should the use of rodent control measures be required, the use of natural predators, for example raptors should be considered, and pesticides that bio- accumulate should be avoided. U3823_Marampa_ESIS_Final.docx September 2012 Page 166 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 8 SOCIO-ECONOMIC IMPACT ASSESSMENT As stated in Section 3.3.3 social issues are often unavoidable and the mitigation strategies are generally geared towards managing a social change process. Successful management of a potentially negative social issue usually presents opportunities for social development and improvement in the quality of life of local people. The economic benefits to the community which can be generated by large scale Projects are the key motivations for the community to support the Project. Furthermore, unlike environmental management plans, social management plans have a twofold objective, first aiming at mitigation of negative impacts and secondly aiming at improvement of standard of living. The potential socio economic impacts (both positive and negative), have been grouped in the categories as shown in Table 8-1. Table 8-1: Summary of evaluated social impacts Impact ED1: Employment generation by the Project resulting in increased standard of living for the local community Impact ED2: Employee training leading to skills development in the local community Economic development Impact ED3: Increase in government income (from taxes and royalty on mining) potentially leading to social development in the Project area Impact ED4: Opportunities for local suppliers and contractors leading to economic growth Impact RL 1: Impoverishment through loss of shelter, land and communal natural resources Resettlement and loss of Impact RL2: Changes to community access as a result of the Project potentially land and social and natural affecting livelihoods, access to communal social services and infrastructure and resources community cohesion Impact RL3: Added pressure on limited host community resources, potentially resulting in food insecurity and malnutrition Impact SO1: Influx of job seekers causing increased pressure on government services and infrastructure, potentially resulting in reduced standard of living Social order Impact SO2: Increase in social ills/problems Impact SO3: Real or perceived unequal distribution of Project benefits leading to social tension Archaeology and cultural Impact AC1: Disturbance to sacred bushes and cemeteries leading to loss of heritage community’s access cultural resources Decommissioning and Impact DC1: Closure of mine leading to economic decline closure As discussed in Chapter 4, potential socio-economic impacts resulting from export activities and the transport of product (and supplies) are not included in this assessment. Explanatory notes on the description and rating of the impacts in Chapters 8 is provided in the introductory text in Chapter 7. Potential impacts of the Project on the health and safety of communities in the vicinity of the Project are described in Chapter 9. 8.1 Economic development The economic benefits of the Project can be classified as direct, indirect and induced impacts. These are described below: • direct impacts – the immediate economic benefits (jobs and development Projects, revenue paid to the government) generated by the Project; • indirect impacts – the production, employment and income changes occurring in U3823_Marampa_ESIS_Final.docx September 2012 Page 167 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report businesses that supply inputs or provide services to the Project; and • induced impacts –the effects of spending by the employees working directly and indirectly for the Project on the local economy. 8.1.1 ED1: Employment generation by the Project resulting in increased standard of living for the local community Construction Operation Decommissioning Post-Closure The Project area is characterised by a lack of formal employment opportunities and widespread poverty (Section 6.5). The creation of jobs is regarded by the local population as the most important positive impact. Although a second mining development (by London Mining) is also underway in the Project area, there is still a significant gap between the availability and demand for jobs. The Project will require a labour force of up to 700 (peak estimate) during construction (over a 3 to 3.5 year period). About 60% are expected to be labour, which can be sourced locally15. The specialist construction workers are likely to be sourced outside of Sierra Leone due to the lack of skilled workers in-country (and competition for local skilled labour between mine developments). The Project will require a work force of up to 550 during the operational phase (15 years). The skill levels needed in this phase will be higher than during the construction phase. Hence it will be difficult to find suitably qualified Sierra Leoneans and therefore it is expected that the number of expatriate employees will initially be relatively high. The number of expatriates will reduce over the life of the mine as Sierra Leonean staff will be trained to take over skilled jobs and management roles. The increased capacity of the national staff will be an added benefit of the Project. Formal jobs with regular and stable incomes will result in greater financial security for those employed and their families. In the extended family structure typical of rural Sierra Leone each employed person supports a large number of dependents. The formal jobs at the Project are expected to be well paid in comparison to existing wage levels in the area. The security and stability gained from a formal job may lead to an improvement in nutritional/health status, investment in children’s education, investment in income generating assets and general quality of life. However, increased income, if not used constructively, can lead to short term gratification (such as drinking and gambling, often linked to conflicts and divorce) instead of investment in the future. Workers may therefore need training and support in the area of income management and life skills. The Project will generate indirect jobs, businesses and livelihood opportunities in the ancillary sector. These may include services and supplies directly to the Project or on account of additional spending by the Project workers. SRK’s experience on other mining Projects in developing countries and in Africa has shown that the ‘employment multiplier effect’ can vary from 1.5 to 9 depending on macroeconomic factors. Assuming an average multiplier of four, every direct job created by the Project can result in three additional jobs. Hence the Project can result in 2,100 additional jobs during construction and 1,650 additional jobs during operations, contributing to the national job sector as a whole. 15 Local here refers to the directly and indirectly affected villages and Lunsar town. U3823_Marampa_ESIS_Final.docx September 2012 Page 168 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report If not managed appropriately however, the employment opportunities at the Project have the potential to: • lead to community resentment against the Project leading to conflict; • become the cause of inter and intra village conflict on the issue of job distribution (further discussed under Impact SO3); and • be a major pulling factor for the in-migration of job-seekers potentially leading to a series of other social problems (Impact SO1). To avoid potential negative consequences, positive impact measures (see enhancement measures proposed below) will focus on increasing local employment opportunities, and ensuring a fair and transparent recruitment strategy. In the table below the impact has been evaluated for the operational phase, as the benefit in terms of increased standard of living will be measurable mainly due to the sustained benefits of regular income over a relatively long period of time. Employment opportunities created by the Project will cease to exist at the end of the operational phase (see Impact DC1) hence the benefit of the increased standard of living will not be sustainable without the enhancement measures in place. Appropriate management measures (during employment and retrenchment) and community development programmes can mitigate against the standard of living dropping to a pre Project level. However the outcomes of such programmes are difficult to guarantee and hence the confidence rating of the mitigation is medium. Impact ED1: Employment generation by the Project resulting in increased standard of living for the local community Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Positive Positive Sensitivity High High Receptor importance or High High Magnitude value description Extent of change / threshold Low Medium compliance Magnitude rating MODERATE MODERATE Duration Medium term Long term Timeframe Frequency - - description Timeframe rating MEDIUM TERM LONG TERM Scale INTERMEDIATE INTERMEDIATE CONSEQUENCE RATING MEDIUM HIGH PROBABILITY RATING DEFINITE DEFINITE SIGNIFICANCE RATING MEDIUM (+ve) HIGH (+ve) Reversibility/sustainability Partially sustainable Confidence High U3823_Marampa_ESIS_Final.docx September 2012 Page 169 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact ED1: Employment generation by the Project resulting in increased standard of living for the local community Enhancement measures • Develop a local employment strategy giving preference to local candidates, provided they meet the required eligibility criteria. • Develop a fair and transparent local recruitment plan • Require contractors (by means of their contract) to give preference to local employees, provided they meet the required eligibility criteria. • Organise training for workers on management of household incomes. • Develop a programme for gradual ‘indigenisation’ of the workforce. This includes a general and technical skills training programme • Develop and implement a construction and operational phase stakeholder engagement plan (SEP). As part of this SEP document and disclose the recruitment process to manage community expectations (also related to Impact SO2). Good practice measures: • Give preference to people directly affected by land acquisition to reduce the magnitude of impacts described in Section 8.2, and • develop a programme of training prior to Project start up to maximise potential for local employment. 8.1.2 ED2: Employee training leading to skills development in the local community Construction Operation Decommissioning Post-Closure Education and skills levels in the Project area are low (Section 6.9). There is limited exposure of the local population to modern technology, technical skills and a formal employment culture (for instance safe working practices). The Project workforce (including local people and other Sierra Leone nationals) will receive both formal and informal training, gaining them skills and competences in different work streams relevant to the Project (Section 4.9.3). The acquired skills will enhance their opportunities to gain alternative employment after mine closure. It is also likely that some of the skills acquired at the workplace, such as health and safety measures, financial management, communication and interpersonal skills will be transferred to a certain extent, to domestic and personal settings leading to an enhanced quality of life. During construction, training will be limited to on-the-job training and safety briefs. Systematic training including technical training will be organised mainly for the operations workforce. It is expected that with enhancement measures the benefit of training will sustain beyond the Project life. However the confidence in the prediction of optimised impact is medium as it is difficult to fully ascertain the ability of workers to benefit from training. U3823_Marampa_ESIS_Final.docx September 2012 Page 170 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact ED2: Employee training leading to skills development in the local community Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Positive Positive Sensitivity High High Receptor importance or High High Magnitude value description Extent of change / threshold Low Medium compliance Magnitude rating MODERATE MODERATE Duration Medium term Long term Timeframe Frequency - - description Timeframe rating MEDIUM TERM LONG TERM Scale INTERMEDIATE INTERMEDIATE CONSEQUENCE RATING MEDIUM HIGH PROBABILITY RATING DEFINITE DEFINITE SIGNIFICANCE RATING MEDIUM (+ve) HIGH (+ve) Reversibility/sustainability Sustainable Confidence Medium Enhancement measures • Prepare and implement a training and skills development plan for ongoing skills development of the Project workforce including contractors’ personnel. • Support a ‘vocational training programme’ to assist local people to qualify for semi-skilled positions. • Encourage workers to introduce the learned skills and practices in their homes. Good practice measures: • Continue technical and financial support to educational institutions and students. 8.1.3 ED3: Increase in government income (from taxes and royalty on mining) potentially leading to social development in Project area Construction Operation Decommissioning Post-Closure Sierra Leone is a candidate country for membership of the Extractive Industry Transparency Initiative (EITI). The EITI promotes transparency in flow of revenue from industry to the government to enhance utilisation of revenues for sustainable development in local communities affected by Projects. It is therefore expected that part of the revenue earned from the Project will be used by the Government for social development in the vicinity of the Project. The Government of Sierra Leone is expected to earn revenue from the Project as a result of taxation on profits, excise duties on imports, payroll taxes and value added tax. The increased government income, if allocated back to the Port Loko District for development, may to lead to enhanced social infrastructure and services. However the Project has no U3823_Marampa_ESIS_Final.docx September 2012 Page 171 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report control over this benefit as the allocation of government spending will be determined by the Government of Sierra Leone. To increase the probability of this benefit materialising the Project should focus on liaison with the government at the local and national levels to support the implementation of EITI principles. Impact ED3: Increase in government income (from taxes and royalty on mining) potentially leading to social development in Project area Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Positive Positive Sensitivity High High Receptor importance or High High Magnitude value description Extent of change / threshold Medium Medium compliance Magnitude rating MODERATE MODERATE Duration Medium Medium Timeframe Frequency - - description Timeframe rating MEDIUM TERM MEDIUM TERM Scale SMALL SMALL CONSEQUENCE RATING MEDIUM MEDIUM PROBABILITY RATING UNLIKELY POSSIBLE SIGNIFICANCE RATING LOW (+ve) MEDIUM (+ve) Reversibility/sustainability Not sustainable Confidence Low Good practice measures: • disclose information on Project’s payment to government to the local communities and other interested stakeholders as part of the SEP, and • liaise with government to promote the use of revenue from the Project in the Project’s area of influence for local development. 8.1.4 ED4: Opportunities for local suppliers and contractors leading to local economic growth Construction Operation Decommissioning Post-Closure The construction of the mine and associated infrastructure will require a capital investment of 2.4 billion during the construction phase, whereas the operational cost is estimated about USD to be approximately USD 9.5 billion. Over the life of mine this translates to approximately USD 12 billion. This spending provides economic opportunities for suppliers of equipment, goods and services. The supply market in Sierra Leone is currently not capable to meet the demands of this type and scale of Project. Hence the Project is unlikely to source the majority of goods and services from within Sierra Leone, with the exception of consumables such as fuel, food and stationary. Where possible however, additional goods should be sourced within Sierra Leone which would lead to economic growth at local and the national levels. U3823_Marampa_ESIS_Final.docx September 2012 Page 172 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report The probability of this benefit from occurring will depend on the Project’s efforts to increase engagement of local suppliers by implementing the measures listed below in the table. The local purchase opportunities will be greatest in the construction phase, will diminish and stabilise during the operational phase and may continue into the decommissioning phase. The benefit will cease to exist after closure. Confidence in this benefit materialising is medium as there is limited capacity in Sierra Leone to meet the needs of the Project. Impact ED4: Opportunities for local suppliers and contractors leading to stimulation of local economic growth Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Positive Positive Sensitivity High High Receptor importance or High High Magnitude value description Extent of change / threshold Low Medium compliance Magnitude rating MINOR MINOR Duration Medium term Medium term Timeframe Frequency - - description Timeframe rating MEDIUM TERM MEDIUM TERM Scale EXTENSIVE EXTENSIVE CONSEQUENCE RATING MEDIUM MEDIUM PROBABILITY RATING UNLIKELY POSSIBLE SIGNIFICANCE RATING LOW (+ve) MEDIUM (+ve) Reversibility/sustainability Not sustainable Confidence Medium Enhancement measures • Identify the types of goods and services required and those that can be sourced from within Sierra Leone. • Develop a procurement programme to maximise the use of local suppliers. Good practice measures: • Develop a supplier and contractor database, along with a process to review, monitor and strengthen capabilities of local suppliers and contractors. 8.2 Resettlement and loss of land, social and natural resources The Project’s foot print area at the mine site (open pits, TSF, WRD, processing areas and haul roads) is estimated to be at least 1,900 Ha. This area is currently in use by local residents for village settlements (housing and social infrastructure), farming (permanent and shifting), collection of wild plants, charcoal production, grazing, fishing and hunting. Although the location of the Project facilities have been designed to minimise direct impacts on existing villages it will lead to displacement of 10 villages (namely Marunku, Magbungbu, U3823_Marampa_ESIS_Final.docx September 2012 Page 173 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Konta, Gbese, Mafuri, Rosint, Ma Sesay, Maso, Rolal c/o Gafal and Matukia). These villages will lose houses and community structures, access to farmland, plantations, irrigation structures, roads and other land based resources. These villages will therefore need to be resettled and compensated in accordance with the Resettlement Action Plan (RAP) based on the Resettlement Framework presented in Appendix D. In addition to this, 13 other villages (namely Makel, Mafira, Magbafat, Rolal c/o Mafuri, Monbaia, Konta Bana, Konta Lol, Manonko, Molumpo, Royail, Kalangba, Royema and Matoko) on the peripheries of the footprint area may not need to be resettled but may face impacts due to loss of land, access to natural resources and loss of social support networks resulting from relocation of neighbouring villages. These villages may also need to be considered in the RAP. Sacred sites and grave sites within the Project footprint area will also require relocation (see Impact AC1). In the absence of mitigation measures, physical and or economic displacement can result in long-term impacts on the social and economic wellbeing of affected populations. Therefore mitigation measures will be planned for the management of the following potential impacts: • relocation of households (Impact RL1) • loss of income and livelihood opportunities (Impact RL1); • reduced access to communal facilities such as wells, irrigation works, schools, and health clinics) (Impact RL2); • breakdown of social support networks such as access to farm labour and credit (impact RL3); and • loss of sacred sites (see Impact AC1). Resettlement of affected households to a new area could result in positive and negative impacts on the host community16(if applicable) or communities close to the resettled villages.. These would need to be assessed once resettlement sites are identified (Impact RL4) 8.2.1 RL1: Impoverishment through loss of shelter, land and communal natural resources Construction Operation Decommissioning Post-Closure Preliminary assessment of the potentially impacted population reveals that: • 10 villages, comprising of 162 households (or 1,780 people) will require replacement housing and access to alternative land for farming and collection of natural resources to sustain their livelihoods; and • an additional 13 villages, comprising of 270 households (or 2,936 people), who are affected by partial loss of land used for farming and collection of natural resources, will require replacement land and access to communal natural resources for sustaining their livelihoods. In total approximately 432 households (4,716 people) will lose some access to land based resources. In addition, some absentee landowners, who live in Freetown, may also be impacted by the land acquisition process. 16 Who is receiving the resettled people. U3823_Marampa_ESIS_Final.docx September 2012 Page 174 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report The RLS study shows that there could be possible impacts on communities further away from the directly impacted villages due to changes to flood regimes and traders dependant on the supply of products from displaced villages. The impacts will occur during the construction phase. However their effects can be long term if not mitigated against. The impacts will be mitigated using a resettlement programme that includes: • provision of improved standard replacement housing and community structures , in consultation with the affected local communities; • compensation for land in the form of cash or preferably in the form of replacement land for long term sustainability of livelihoods; • cash compensation for loss of any standing crops, plantations and trees; • assistance for redevelopment of farms and plantations on new land; and • livelihood restoration for people facing loss of income or livelihood opportunities. Special attention will be needed in the RAP for the issues listed below: • Due to depletion of natural resources and sub-optimal methods of farming, food insecurity is an issue in the area, with households lacking adequate food supplies for between one and four months every year (Section 6.5). Hence the mitigation measures will need to focus on alternative livelihood options (such as employment by the Project) and improving farming methods. Some communal resources, such as palm oil trees (for palm wine trapping or commercial harvesting) are leased to people outside the identified villages. Hence the mitigation measures will need to consider the impact on people potentially affected due to severance of such leasing arrangements. • Replacing access to communal natural resource areas with areas of similar value will be difficult due to general depletion of natural resources in the larger area. Loss of wild plants, which are largely restricted to degraded patches of communal forest (protected in the form of sacred bush), would impact on the traditional system of medicine and could be difficult to replace. Hence a combination of mitigation measures will be needed to compensate for loss of access to natural resources. These will need to be explored with the affected people, but could include: planting of medicinal plants, providing support to farmers and exploring alternative livelihood options with an objective to enhance food security. Impact RL1: Impoverishment through loss of shelter, land and communal natural resources Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity High High Receptor importance or High High Magnitude value description Extent of change / threshold High Low compliance Magnitude rating MAJOR MODERATE U3823_Marampa_ESIS_Final.docx September 2012 Page 175 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact RL1: Impoverishment through loss of shelter, land and communal natural resources Duration Permanent Short to Medium term Timeframe Frequency - - description Timeframe rating LONG TERM MEDIUM TERM Scale SMALL SMALL CONSEQUENCE RATING HIGH MEDIUM PROBABILITY RATING DEFINITE DEFINITE SIGNIFICANCE RATING HIGH (-ve) MEDIUM (-ve) Reversibility Reversible Confidence High Mitigation measures • Prepare a Resettlement Action Plan (RAP) in agreement with affected population, the Paramount Chief and key government and non-government stakeholders as per the RF (Appendix D). The plan should provide details of: • affected people; • entitlements (cash or preferably in the form of replacement land for long term sustainability of livelihoods); • cash compensation for loss of any standing crops, plantations and trees; • assistance for redevelopment of farms and plantations on new land; • provision of improved replacement residential and community structures as per the preference of local communities. • Build alternative access routes in consultation with users of affected routes. • Undertake a community development programme for people facing loss of livelihood opportunities. • Iteratively consult with affected people to identify and resolve their issues in a timely manner. • Implement a grievance mechanism for identification of resettlement related issues and address them in a timely manner. • Undertake post resettlement monitoring of affected parties to timeously detect issues and take action if necessary. Good practice measures: • Preferentially employ eligible members from directly affected families. 8.2.2 RL2: Changes to community access as a result of the Project potentially affecting livelihoods, access to communal social services and infrastructure and community cohesion Construction Operation Decommissioning Post-Closure Local communities live in small villages scattered throughout the Project area many of which are only accessible on foot. Close social linkages exist between these villages, as well as linkages through trade and shared natural resource use. Community members therefore travel on foot on a regular basis between villages, water access points, farming, fishing, hunting or harvesting areas, places of community service (schools, clinics) and areas of cultural importance (such as sacred bush). Due to the dense vegetation, many of these U3823_Marampa_ESIS_Final.docx September 2012 Page 176 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report routes are not visible from aerial photographs of the area. The most direct and easiest access routes would preferentially be used and in many cases the use of alternative available routes would add significantly to the journey time and effort which, in turn, would cut into time available for other livelihood practices. In some cases, positioning of Project infrastructure may intersect these preferred routes blocking or disrupting access. The communal social infrastructure available to villagers mainly comprises facilities such as schools, health centres, churches, grain banks, hand pumps and access roads. Land reduced by the Project would lead to loss of communal social infrastructure in the 10 directly affected villages, although this is mitigated by resettlement of those villages. The RAP will plan for replacement of lost facilities at the relocation sites, which should improve the affected people’s standard of living. Making an inventory of impacted infrastructure and planning for their replacement will be part of the RAP (Impact RL1). Relocation of some facilities that have a larger catchment area (such as the Health centre in Marunku) could also impact several neighbouring villages currently using the facility. This aspect may need to be assessed during the resettlement planning process and included in the mitigation measures. Given the Project area is characterised by a low density of social infrastructure, the resettlement programme will provide an opportunity for net improvement in the situation. Hence it is reasonable to expect that the post mitigation the impact would be minor, last for a shorter duration and be reversible. Displaced communities (and to a lesser extent the villages left behind) that are relocated too far from their present location can also be affected by a loss of non-tangible community resources such as: reciprocal labour sharing arrangements (usually spread across 3-4 villages), links with traders and access to social networks (neighbours, friends, relatives) that form the social support within the village community. To mitigate loss of social networks, consideration will be given to relocation of certain households so as to preserve the social ties and networks and reduce the potential severity and duration of the impact. As with Impacts RL1 this aspect will be further investigated during RAP process and addressed through identification of measures using community knowledge and preferences. Due to the local communities’ reliance on access routes between villages and other areas, the pre-management magnitude of the impact is rated as moderate. The impact will be felt beyond the life of the mine, if not permanently, and will affect communities beyond the direct Project footprint area, either directly or indirectly, through disruption or loss of connectivity with areas outside the village that are commonly frequented. Through appropriate management, the impact significance could be reduced as communities would be assisted by way of developing suitable route alternatives, having alternative facilities provided and the period of route disruptions could be minimised. Positive impacts resulting from the provision of safe and easy new access routes together with a reduction in travel time and vehicle maintenance costs (through the improvement in road condition) would also contribute to the reduction in significance of this negative impact. As the impact relates to communities perceptions of the change, the confidence in the rating is given as medium. U3823_Marampa_ESIS_Final.docx September 2012 Page 177 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact RL2: Reduced access to communal social services and infrastructure Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity High Low Receptor importance or High Medium Magnitude value description Extent of change / threshold High Low compliance Magnitude rating MAJOR LOW Duration Long term Short term Timeframe Frequency - - description Timeframe rating LONG TERM SHORT TERM Scale SMALL SMALL CONSEQUENCE RATING HIGH LOW PROBABILITY RATING DEFINITE POSSIBLE SIGNIFICANCE RATING HIGH (-ve) LOW (-ve) Reversibility/Sustainability Reversible and potentially sustainable Confidence Medium Mitigation measures • Implement measures under Impact RL1 relating to resettlement planning. • Provide safe crossing points across or around mine infrastructure where existing tracks are affected. • Liaise with the affected communities to determine alternate routes around mine area that cannot be crossed. • Maintain the selected bypass roads in the vicinity of the mine operations for the duration of the life of the operation. • At closure, liaise with communities to determine if previous routes should be restored. 8.2.3 RL3: Added pressure on limited host community resources potentially resulting in food insecurity and malnutrition Construction Operation Decommissioning Post-Closure The communities at the host site may experience added pressure on land and natural resources due to the increase in population on account of relocation of Project affected people. To mitigate this potential impact the resettlement plan would assess the host site in terms of potential shortage of food resources, increased pressure on social infrastructure and other community resources that can lead to impoverishment in the host community. The host community may also experience positive impacts from influx of resettled people for instance local businesses may increase their customer base. The scale, intensity and nature of impacts (both positive and negative) will depend on the characteristics of the host site in terms of its impact bearing capacity and ability to U3823_Marampa_ESIS_Final.docx September 2012 Page 178 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report accommodate population influx. Other determining aspects could be the number of host sites chosen, magnitude of population to be resettled at each site, all of which have not currently been identified. It is therefore not feasible to further describe and evaluate this impact at this stage. Impacts on the host site will be assessed and appropriate management measures designed as part of the RAP process. 8.3 Social order The Project is expected to create changes in the existing social systems and practices. One of the main potential impacts on the existing social order may be is the sudden increase in population caused by arrival of Project workers and speculative job seekers driven by direct and indirect employment and business opportunities. The inflow of workers (and associated migration) is expected to start and peak in the construction phase with the start of construction activities. The influx of job seekers during operations is expected to slow down. The potential impacts and risks associated with increase in population are further described in Sections 8.3.1 and 8.3.2. By identifying and understanding these changes the Project would have the opportunity to mitigate the negative impacts on affected communities. 8.3.1 SO1: Influx of job seekers causing increased pressure on government services and infrastructure, potentially resulting in reduced standard of living Construction Operation Decommissioning Post-Closure The economic opportunities created by the Project are expected to lead to an influx of workers and job seekers. With the ongoing development of the London Mining Project in the immediate vicinity, some in-migration has already taken place. With the start of the Project, Lunsar town and surrounding areas could potentially be perceived as employment hotspots increasing further in-migration. This has been observed as a phenomenon at recent Projects in rural Sierra Leone (for instance AML’s Tonkolili Iron Ore Project). Currently the local communities perceive in-migration and growth of human settlements as a positive indicator because it represents growth in the consumer base. In the long term however, the increase in population due to in-migration can exacerbate secondary impacts, contributing to deterioration in standard of living. These include; • pressure on local social infrastructure; • pressure on natural resources (which are already rapidly depleting); • increase in the cost of living; and • encroachment on the limited Project related opportunities for unskilled labour by immigrants leading to resentment among the local community members (this aspect is further discussed under Impact SO3). All the above factors can cause a build-up of resentment among the community ultimately manifesting as conflict. The Project cannot keep people from moving into the area. However, indirect measures to pre-empt and discourage the flow of migrants into the area can be employed. A preferential local recruitment and procurement policy may discourage potential in-migrants from moving into the area. Nevertheless some in-migration will still take place and will add pressure on existing resources. The Project could provide support to the government to build additional infrastructure, as well as to local NGOs to deal with any potential social issues emanating U3823_Marampa_ESIS_Final.docx September 2012 Page 179 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report from increases in population (Impact SO2). Population influx is an indirect impact and the Project has limited control on the outcome of mitigation measures, hence the confidence in residual impacts ratings is medium. Impact SO1: Influx of job seekers causing increased pressure on government services and infrastructure, potentially resulting in reduced standard of living Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity Medium Medium Receptor importance or Medium Medium Magnitude value description Extent of change / threshold Medium Low compliance Magnitude rating MODERATE MINOR Duration Long term Medium term Timeframe Frequency - - description Timeframe rating LONG TERM MEDIUM TERM Scale SMALL SMALL CONSEQUENCE RATING MEDIUM LOW PROBABILITY RATING DEFINITE POSSIBLE SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility Partially reversible Confidence Medium Mitigation measures • Encourage local recruitment and procurement (see Impact ED1 and ED4). • Encourage local communities to use the grievance procedure for resolving their concerns. Good practice measures: • Facilitate joint planning with other industries, local government, Paramount Chief and other stakeholders to minimise speculative migration. 8.3.2 SO2: Increase in social ills/problems Construction Operation Decommissioning Post-Closure The presence of Project workers (including expatriates and workers from other parts of Sierra Leone) and influx of speculative job seekers (predominantly single males) may result in an increase in the following social ills typically seen in other mining Projects in developing countries: • increases in crime such as theft and robbery due to income and economic disparity between mine workers and others; • increases in alcohol and drug abuse, which is sometimes associated with an increase in violence; U3823_Marampa_ESIS_Final.docx September 2012 Page 180 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report • increases in prostitution and promiscuous sexual activities due to presence of single males with disposable incomes (as a consequence, a potential increase in communicable diseases (including TB, HIV and other STDs) among the local population and Project workers (Impact SR2); and • erosion of traditional cultural values. • To prevent or mitigate the above problems the Project will: • aim to prevent economic disparity by maximising local people’s participation in the Project workforce and provide access to other benefits implemented through community development programmes (through measures under Impact ED1); and • support education and awareness programmes for workers and community members that would cover topics such as: life skills for responsible use of increased incomes; prevention measure against communicable diseases; cultural sensitivity for expatriates and visitors; and conflict management for local leaders. If not managed the impacts would start manifesting in the construction phase and continue beyond the Project life. With a combination of the mitigation measures listed above the extent and duration of the impacts can be reduced as shown in the ratings table. However the ratings after mitigation are made with medium confidence, since it is difficult to make firm predictions about behavioural change as a result of information campaigns. Impact SO2: Increase in social ills/problems Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity High Medium Receptor importance or High Medium Magnitude value description Extent of change / threshold Moderate Low compliance Magnitude rating MODERATE MINOR Duration Long term Medium term Timeframe Frequency - - description Timeframe rating LONG TERM MEDIUM TERM Scale SMALL SMALL CONSEQUENCE RATING MEDIUM LOW PROBABILITY RATING DEFINITE POSSIBLE SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility Partially reversible Confidence Medium U3823_Marampa_ESIS_Final.docx September 2012 Page 181 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Mitigation measures • Undertake awareness and educational campaigns (directly or through existing institutions) for prevention of social ills. • Provide employees and visitors to the site with cultural awareness training. • Provide assistance to the local health department (and NGOs) to strengthen programmes for control of communicable diseases. • Implement the management measures given under Impact SO1. 8.3.3 SO3: Real or perceived unequal distribution of Project benefits potentially leading to social tension Construction Operation Decommissioning Post-Closure Some discontent due to perceived unequal distribution of jobs, development aid benefits and unfulfilled expectations been raised by areas of the community. Further tensions may arise in the local community as the Project moves into the implementation phase. Some of the specific triggers for such tension are likely to be: • real or perceived unfair compensation for land and assets (tangible and non-tangible); • real or perceived unfair recruitment policy and/or practices; • encroachment by outsiders/in-migrants depriving the local workers and affected people of job opportunities; • potential corruption of local leaders and Project staff influencing recruitment; • real or perceived unfair procurement and supply practices; • real or perceived unfair access to the Project’s social development Projects; and • increased economic disparities between those with jobs and those without. Mitigation of the potential impacts will include: • management of people’s expectations and perceptions during the resettlement through effective implementation of the RAP focused consultation meetings; • an appropriate and transparent grievance mechanism; and • a local employment policy and transparent recruitment strategy. Without mitigation measures it is expected that the frequency of unresolved complaints would be high, this can be brought down to low frequency by an active grievance mechanism and effective implementation of the measures for maximising the participation of locals in the jobs (Impact ED1) and decreasing the in-migration (Impact SO1) which would further minimise grievances and conflicts. Overall the mitigation measures also aim to reduce the extent and severity of the impacts, the majority of which are reversible if managed diligently. U3823_Marampa_ESIS_Final.docx September 2012 Page 182 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact SO3: Real or perceived unequal distribution of Project benefits potentially leading to social tension Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity High High Receptor importance or High High Magnitude value description Extent of change / threshold High Moderate compliance Magnitude rating HIGH MODERATE Duration - - Timeframe Frequency High frequency Low frequency description Timeframe rating HIGH LOW Scale SMALL SMALL CONSEQUENCE RATING HIGH MEDIUM PROBABILITY RATING DEFINITE POSSIBLE SIGNIFICANCE RATING HIGH (-ve) MEDIUM (-ve) Reversibility Reversible Confidence High Mitigation measures • Maintain transparency in the recruitment process. • Maintain regular communication with local communities and other stakeholders to minimise tensions. • Maintain and monitor grievance mechanism for timely resolution of community grievances. • Implement measures under Impacts SO1, ED1 and ED4 to minimise population influx. 8.4 Archaeology and cultural heritage 8.4.1 AC1: Possible disturbance to sacred bushes and cemeteries leading to loss of community’s access to cultural resources Construction Operation Decommissioning Post-Closure Acquisition of land, for the Project resulting in relocation of 10 villages, will cause the loss of access to sacred bushes and burial grounds, which play an important role in the cultural life of the local population. Loss of access to and potential destruction of the sacred bushes may negatively impact on people’s emotional wellbeing. To mitigate the impact, the sacred bushes and burial grounds will require relocation near resettlement site(s). The cultural specialist study (Section 6.13) indicates local people feel it is acceptable to relocate and restore the sacred bushes and cemeteries as long as the right procedures are followed. The relocation process will be part of the RAP and will be preceded by sufficient formal consultation with sacred society members (both male and female) on the rituals needed for transfer of sacred qualities to the relocation site, and the botanical requirements for selection of the new sacred bush sites. The exact numbers of sacred bushes U3823_Marampa_ESIS_Final.docx September 2012 Page 183 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report and cemeteries will be estimated as part of the census conducted during the resettlement planning process. There is evidence of the presence of archaeological remains of ancestral villages in the area. However the reconnaissance study does not provide any evidence of the presence of sites of sufficient importance as to merit preservation. Nevertheless a chance find procedure will be put in place for the areas disturbed by construction activities. Additional management recommendations may be identified through the RAP process. If mitigation measures are implemented the severity and duration of the impact on cultural sites will be significantly reduced. However there is no guarantee that the new sacred sites will fully replace the historically spiritual value of the original sites hence the impact is only partially reversible. Impact AC1: Possible disturbance to sacred bushes and cemeteries leading to loss of community’s access to cultural resources Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity High Medium Receptor importance or High Medium Magnitude value description Extent of change / threshold Major Low compliance Magnitude rating MAJOR MODERATE Duration Long term Short term Timeframe Frequency - - description Timeframe rating LONG TERM SHORT TERM Scale SMALL SMALL CONSEQUENCE RATING HIGH LOW PROBABILITY RATING DEFINITE POSSIBLE SIGNIFICANCE RATING HIGH (-ve) LOW (-ve) Reversibility Partly Reversible Confidence High Mitigation measures • Implement measures in Impact RL1 regarding protection of natural resources. • Record mythological stories associated with specific sacred sites as part of their relocation. 8.5 Decommissioning and closure As the Project is likely to be a key contributor to the local economy (and to some degree national economy) over a period of at least 15 years, its closure may cause economic decline with impacts on the retrenched workers, the local society and the local economy. U3823_Marampa_ESIS_Final.docx September 2012 Page 184 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 8.5.1 DC1: Closure of the mine leading to economic decline Construction Operation Decommissioning Post-Closure Closure of the mine will lead to loss of income for the workers (with accompanying decline in their purchasing power), the secondary industries dependent on the mine and loss of revenue for the government. The loss of business in the secondary and support industry will also lead to further job losses and impact on the economy. Thus there is a correlation between loss of income and economic slowdown, one exacerbating the other. As it is difficult to predict the socio economic environment in which the mine closure will take place, the Project would start planning for the closure phase three to five years in advance. Other closure related impacts could include: • out-migration of skilled workers from the Project area leading to erosion of the local skills and consumer base and impacting on the local business sector; and • psychological impacts on individuals manifesting in depression, apathy, helplessness and a sense of inadequacy. Closure of the mine will also result in a reduction in the revenue base of the government leading to a reduction in the allocation of funds for provision of social infrastructure and services with a corresponding deterioration in quality of life. A more detailed assessment of potential impacts from the Project’s closure will be identified during closure planning However key mitigation strategies are expected to include: • allocation of closure funds at least 3 years prior to closure of the Project; • retraining of retrenched workers; • sustainable livelihoods programme for the local community; • counselling support for community members and staff; and • handover of any suitable social infrastructure and services provided by the Project. The mitigation measures of the closure plan aim at building the capacity of the community to adapt to the changes caused by Project closure and to sustain some of the economic benefits created by the Project. The confidence in assessing the impacts, mitigation measures and the residual impact is medium due to the premature nature of the assessment. Impact DC1: Closure of mine leading to economic decline Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity High High Receptor importance or High High Magnitude value description Extent of change / threshold Major Moderate compliance Magnitude rating MAJOR MAJOR Duration Long term Short to medium term Timeframe Frequency - - description Timeframe rating LONG TERM SHORT TO MEDIUM TERM U3823_Marampa_ESIS_Final.docx September 2012 Page 185 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact DC1: Closure of mine leading to economic decline Scale SMALL SMALL CONSEQUENCE RATING HIGH MEDIUM PROBABILITY RATING DEFINITE POSSIBLE SIGNIFICANCE RATING HIGH (-ve) MEDIUM (-ve) Reversibility Partly Reversible Confidence Medium Mitigation measures • Conduct an independent social impact assessment prior to closure. • Develop a social closure plan including the following: o design and implement a retrenchment policy and strategy in consultation with workers and other stakeholders; and o plan for post-Project sustainability of community development activities. • Allocate funds (in advance) for implementation of the social closure plan. • Re-train workers for increasing their chances for re-employment elsewhere after Project closure. • Conduct stakeholder consultations on closure issues as part of the ongoing stakeholder engagement process. Good practice measures: • Consider re-training of staff (voluntary training after hours) so they build skills to work in other sectors following closure of the mine. • Promote and support building the capacity of local suppliers to diversify their customer base and move beyond the Project area. U3823_Marampa_ESIS_Final.docx September 2012 Page 186 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 9 COMMUNITY HEALTH, SAFETY AND SECURITY IMPACT ASSESSMENT This section covers health, safety and security impacts on communities as a result of the Project, and includes “nuisance” impacts as well as health impacts and safety/security issues posing a physical risk of injury, if not fatality, to the public (and in some cases also livestock and wildlife). Nuisance impacts include those that do not result in direct and proven consequences to human health, but are nonetheless generally considered to be unpleasant (such as small increases in ambient noise or unpleasant odours). Health impacts in contrast could potentially cause harm to human health and include air quality issues and exposure to communicable diseases. Security impacts can include matters arising from conflict between communities and also those arising from the use of security at the mine. Usually safety issues or hazards would occur on an infrequent basis, as a result of an accident or unexpected event. Unexpected events that may lead to health and safety risks for local communities include: • Road accidents; • Engineering structural failure; • Accidental spillage of hazardous or toxic materials; • Uncontrolled fires; • Fly rock due to blasting; and • Human error. The most significant Project hazards are discussed in more detail under Section 9.5. Because of the number of variables affecting the consequence and probability of such events, accurate significance rating of possible impacts should the risk materialise is not possible. Significance ratings have therefore been provided for impacts only (Sections 9.1 to 9.4), and not for hazards. Explanatory notes on the description and rating of the impacts are provided in the introductory text in Section 7. Impacts on villages that are proposed to be relocated due to positioning of Project infrastructure (as listed in Section 8.2) have not been assessed. The impact ratings provided therefore apply only to those villages that will not be relocated. Each event must be evaluated on an individual basis, in accordance with the Company’s standard event reporting system. For the purposes of this assessment it is assumed health, safety and security risks to employees of the Project, both during construction and operations, will be addressed through an occupational health and safety plan, and are therefore not included in the discussion below. The Project developers will also prepare an Emergency Preparedness, Response and Recovery Plan (EPR&R) to identify and prevent potential emergency situations, plan responses and recovery from emergency events (Section 11.6). U3823_Marampa_ESIS_Final.docx September 2012 Page 187 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 9-1: Summary of evaluated community health and safety impacts or risks Impact groups Impact headings Air quality • AQ1: Dust emissions causing nuisance and health impacts on local communities • NV1: Blasting causing air overpressure and vibrations, resulting in disturbance of Noise and vibration local communities • NV2: Operation of mining equipment and vehicles resulting in increase in background noise levels for local communities • TS1: Increase in Project-related traffic on local and national roads causing increased Traffic safety wear and tear and risk of road accidents • TS2: Use of mine site roads by local communities causing increased safety risks due to road accidents Security/Social risks • SR1: Risk of human rights abuses due to conflict with communities • SR2: Increased exposure to communicable diseases due to an influx of workers, resulting in a deterioration in public health • OH1: Blasting, resulting in fly rock Other hazards • OH2: Community exposure to toxic or hazardous substances potentially resulting • OH3: Fire or explosions due to storage of explosives and use of combustible in injury materials • OH4: Failure of the TSF 9.1 Air quality As in the case of water resources, impacts on air quality are traditionally assessed in environmental impact assessments, although the air itself is not the receptor but merely the pathway by which the source of the impact would reach the receptor (in this case humans breathing in the air). Impacts on air quality are considered and assessed in this report, and are interpreted in terms of the relevant international guidelines considered appropriate by the specialist, in conjunction with consideration of the potentially affected receptors. The focus of this impact assessment is on public health issues potentially resulting from Project-related releases to the air. Therefore, with the exception of the accommodation camp, ambient air quality inside the mine footprint area has not been included in this assessment. The health of workers inside the mine site boundary is regulated by Sierra Leone and international occupational health and safety standards and guidelines. Air pollutant emissions take place in particulate and gaseous forms. Gaseous pollutants emitted by the Project are mainly sulfur oxides (SO ) and nitrogen oxides (NO ). Lesser x x pollutant emissions may include carbon monoxide, volatile organic compounds and unburned hydrocarbons. Particulate matter (PM) refers to airborne particles, and includes dust, smoke and soot. PM is defined by size, with coarse particles being between 2.5-10 microns, fine particles less than 2.5 microns, and ultrafine particles less than 0.1 microns in aerodynamic diameter. PM below 10 µm (PM ) is referred to as inhalable particulates, and also includes 10 the PM fine particulates. 2.5 Based on the Project as described in Chapter 4, dust (PM , PM and dust fallout) is 10 2.5 considered to be the main potential pollutant of concern and has therefore been assessed in this study. While gases such as SO and NO have also been identified as potential 2 2 pollutants, they are considered to be minor pollutants that are unlikely to have a major impact on the Project environment. Dispersion of these gasses therefore has not been modelled, and impacts relating to them have not been assessed. PM may have adverse effects on humans such as respiratory illnesses (asthma and bronchitis) or cardiovascular diseases. PM2.5 can be breathed deep into the lungs, and therefore presents higher health risks. PM can also affect vegetation in two ways, namely, by inhibiting the plant’s photosynthetic properties by coating the leaves thereby blocking light U3823_Marampa_ESIS_Final.docx September 2012 Page 188 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report penetration. Secondly, from the deposition onto soils of various metals in the particulate matter which are absorbed by vegetation thereby hindering plant growth. The uptake of metals by plants has the potential to contaminate vegetables and fruit that may be consumed by humans and animals. Impacts on vegetation are discussed under impact LT4 however and are not included in the impact assessment below. Disturbance of wildlife resulting from dust generation is rated under impact EB3 (Section 7.3.4). Increased dust emissions in the area of unpaved roads (such as haul roads) will reduce visibility for drivers and pedestrians on these roads, contributing to traffic safety risks, which are discussed and rated in impact TS2 (Section 9.3.2). PM2.5 can be generated both as a primary and secondary pollutant. Primary pollutants are those directly emitted into the atmosphere, for example power generation and mobile equipment generate PM2.5 as a result of combustion processes. Secondary pollutants form through physico-chemical reactions such as phase change, adsorption on solids, chemical reactions etc. PM has extended atmospheric residence times (days to weeks) and 2.5 therefore can be transported long-ranges (100’s to 1,000’s km). In contrast, the coarse particulates have short residence times (minutes to hours) and are removed within short ranges (1 to 10’s km) via dry deposition. 9.1.1 AQ1: Dust emissions causing nuisance and health impacts on local communities Construction Operation Decommissioning Post-Closure Potential sources of dust resulting from the Project include the following: • Drilling and blasting; • Fugitive dust from grading, mining and waste material handling and storage; • Wind erosion of areas disturbed or cleared during construction and decommissioning; • Wind erosion of tailings material; and • Road dust caused by vehicle movement on unpaved roads (vehicle entrainment). Materials handling, wind erosion (e.g. from the TSF and waste rock dumps) and vehicle- entrainment of dust from unpaved roadways are expected to be the main sources of dust in the area during operation of the mine. Changes to air quality resulting from the Project and compliance with the relevant ambient air quality standards and guidelines were assessed and modelled by specialists from SRK (SA) using dispersion modelling software. Predicted maximum daily and annual average concentrations for PM10, PM2.5, and TSP were simulated using the US-EPA approved AERMOD (AMS/EPA Regulatory Model) model. Worst case predicted concentrations of PM , PM and TSP resulting from the operation of 10 2.5 the mine were then determined and mapped (via concentration contours or isopleths) for the surrounding area, and compared against the World Bank (WB) IFC guidelines17, the US EPA standards for ambient air quality and the South African National Standards (SANS 1929:2005) for dust deposition. Dust deposition is a measure of nuisance dust and exceedances of the SANS 1929:2005 guideline levels suggests an increase in nuisance levels for the various defined categories. The South African standard was selected for the impact assessment as it 17 As published in the Environmental, Health and Safety General Guidelines document of 2007 U3823_Marampa_ESIS_Final.docx September 2012 Page 189 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report has been designed to accommodate areas close to mines. Further detail on these standards and the modelling and assessment of impacts on air quality are provided in the Air Quality Impact Assessment Report included in SD2 of Volume 3. Source emissions Source emission data modelling predicted the sources responsible for the highest dust emissions after mitigation to be unpaved roads, followed by the tailings storage facility (assuming one third dry beach) and the active operational areas of the waste rock facility. The open pits were excluded as a potential dust source as they were confirmed (through additional modelling for three different pit depths) to be an insignificant contributor to dust emissions for the Project. This is due to the topography of the area, and the finding that dust generated would remain within the pit and not rise above ground level. Crushing and grinding were not included in the dispersion modelling as dust generation from these activities is considered to be negligible. Similarly, drilling and blasting were also not included as they would be non-routine and short-term activities. Construction, decommissioning and post- closure phase dust emissions also were not included as they are considered to make a minor contribution to air emissions (due to their relatively short-term nature in the case of decommissioning and construction phases). Due to the highly seasonal nature of rainfall in the area (with approximately six months of the year falling in the dry season), dust generation is also expected to follow a seasonal trend (as the baseline monitoring results described in Section 5.7 have shown). Dust emissions (predicted maximum daily and annual average concentrations for PM , PM , and TSP) were 10 2.5 modelled for two scenarios during mine operation, to predict the impact before and after the implementation of management measures (such as wetting down or use of chemical dust suppressants on unpaved roads). It is noted that the scenarios model what can be considered worst case environmental conditions in terms of dust generation (i.e. during the dry season, under windy conditions), which in reality are likely to be relatively rare. A conservative approach was also taken with regard to the predictions of average 24-hour concentrations – the highest average concentration over the three-year simulation period has been used for the assessment. The th 98 percentile values are reported for predicted PM10 concentrations, as per accepted statistical methodology, to exclude anomalous concentrations. Dispersion modelling results Ambient ground level concentration isopleths for PM10 before and after successful implementation of mitigation measures are shown in Figure 9.1 and Figure 9.2 and represent interpolated values from the concentrations predicted by the AERMOD model. Similar isopleths for PM2.5 and dust fallout concentrations are included in the Air Quality Impact Assessment report (SRK, 2012), included in SD2 of Volume 3. Predicted maximum concentrations of PM10, PM2.5 and dust fallout at local villages before and after implementation of mitigation measures are shown in Table 9-2 with exceedances of the relevant guideline levels highlighted. Villages that are planned to be relocated (due to positioning of Project infrastructure) are highlighted in bold text, and have been excluded from the impact assessment and rating. The results reveal a reduction in predicted dust emissions by approximately 50% when management measures are implemented. As expected, the maximum predicted dust (PM10, PM2.5 and dust fallout) concentrations are predicted to occur around the mine activities and decrease with distance from these sources. U3823_Marampa_ESIS_Final.docx September 2012 Page 190 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report With management measures in place, PM10 emission concentrations resulting from the Project are predicted to remain below 150 µg/m³ (the US EPA guideline level) at all local villages except Mafuri and Royail Kalagba, both of which are scheduled for relocation, though the more stringent World Bank guideline is exceeded for a number of locations (note that the World Bank Guideline, which is based on World Health Organisation guidelines, also includes interim guidelines which are less stringent). PM2.5 emission concentrations are predicted to remain below 20 µg/m³ (the World Bank guideline level) at all villages except for Royail Kalagba, and dust fallout concentrations are predicted to be below 300 mg/m2/day (the SANS 1929:2005 target level) at all villages except those scheduled for relocation, as well as Konta, where a slight exceedance of the residential limit is predicted, and Magbafat, where the target level may be exceeded. Cumulative concentration was calculated by adding the maximum 24-hour baseline monitored concentration at a point (as described in Section 5.7) to the maximum concentration (with mitigation measures implemented) predicted to result from the operation of the Project. The cumulative PM10 concentration at the MIOL site office is 117.1 µg/m³, and the PM2.5 concentration is 23 µg/m³, both of which fall above the World Bank/IFC guideline but below the US EPA guideline levels. As PM concentration was not monitored at other locations in the Project area, quantitative predictions of cumulative concentrations cannot be provided. Predicted cumulative dust fallout concentrations were calculated for eight dust fallout monitoring locations (see Air Quality Impact Assessment Report in SD2 of Volume 3 for results). The SANS 1929:2005 target limit was exceeded at all monitored locations except the MIOL site office in Lunsar. The residential limit was exceeded at Konta Bana, Matukia and Mafuri, the latter two of which will be relocated, as well as Maso, where the industrial limit will be exceeded. It is noted however that average daily monitored concentration at Konta Bana already exceeds this limit, and the predicted additional contribution due to the mine is less than 10%. At the Catholic School (in Lunsar), the relative contribution predicted to result from the mine is also less than the baseline contribution by approximately 50%. U3823_Marampa_ESIS_Final.docx September 2012 Page 191 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 9.1: Maximum predicted 98th percentile PM10 concentrations over the Project area, without management U3823_Marampa_ESIS_Final.docx September 2012 Page 192 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 9.2: Maximum predicted 98th percentile PM10 concentrations over the Project area, with management U3823_Marampa_ESIS_Final.docx September 2012 Page 193 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Cumulative concentrations are useful for providing an indication of the relative contributions of baseline and predicted concentrations to ambient air quality, as well as for determining ambient air quality as experienced by the receptor, regardless of the source. However, as cumulative concentration is reliant on data obtained from monitoring at points on site, and takes into account sources of dust other than the Project, the impact on air quality has been assessed based on the predicted maximum concentrations at local villages rather than cumulative concentrations. The specialist report concluded that the dust dispersion results showed the TSF and WRD to be well located with regard to air quality impacts, as the topography of the surrounding area will reduce the likelihood of windblown dust from these sources affecting local villages. The locations of the haul roads (predicted to be the main sources of dust) are also concluded to be suitable provided mitigation measures are implemented to prevent vehicle entrainment of dust. Table 9-2: Predicted 24-hour dust concentrations at local villages18 Predicted 24 hour concentrations Maximum Dust fallout Village 98th Percentile PM Maximum PM concentration concentration (µg/m³) 10 concentration (µg/m³) 2.5 (mg/m2/day) Before mgt Post-mgt Before mgt Post-mgt Before mgt Post-mgt Gbalan 226.4 113.0 29.9 8.6 477.9 228.4 Gbese 249.9 124.0 31.4 9.9 425.3 154.7 Konta 253.3 126.4 28.1 14.8 1229.4 614.4 Konta Bana 56.3 26.0 12.4 4.2 132.4 50.6 Konta Lol 56.5 27.6 12.8 4.5 119.0 51.5 Lunsar 129.5 63.3 20.4 7.0 212.3 91.1 Ma Sesay 290.3 143.4 43.7 5.4 5070.9 275.2 Mabesseneh 122.8 60.6 18.2 6.2 241.4 99.3 Mafira 98.3 48.5 13.7 4.2 356.1 77.7 Mafuri 334.5 166.9 46.1 5.1 534.0 309.0 Magbafat 261.5 129.3 36.7 16.6 1123.9 524.2 Magbungbu 64.0 31.1 13.3 4.4 4548.2 98.0 Makel 105.8 52.2 16.4 7.0 763.6 266.9 Makindo 294.5 146.1 36.8 9.4 440.3 179.8 Makump 178.1 86.9 24.1 10.9 510.6 248.9 Manonko 56.7 25.1 22.3 4.5 440.6 69.0 Masetle 173.8 86.1 23.7 7.9 275.7 121.3 Maso 211.6 102.8 31.3 3.8 4443.5 493.0 Matinkani 49.7 22.0 16.9 4.0 176.0 50.6 Matukia 84.7 40.2 14.5 5.3 213.0 91.3 Mayepeh 170.0 84.7 21.7 4.2 213.0 88.3 Mayoka 132.9 66.3 16.8 2.9 143.9 63.8 18 Villages planned to be relocated due to positioning of Project infrastructure are indicated in bold text U3823_Marampa_ESIS_Final.docx September 2012 Page 194 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Predicted 24 hour concentrations Maximum Dust fallout Village 98th Percentile PM Maximum PM concentration 10 2.5 2 concentration (µg/m³) concentration (µg/m³) (mg/m /day) Before mgt Post-mgt Before mgt Post-mgt Before mgt Post-mgt Molumpo Marampa 157.4 78.1 22.1 7.2 486.3 221.1 Monbaia 172.9 86.1 21.6 2.2 91.5 39.6 Rofunk 101.4 50.3 13.9 1.5 72.4 28.1 Rogbaneh 31.4 14.9 9.6 2.8 73.1 30.6 Rolal c/o Gafal 74.6 34.3 18.1 5.9 284.4 87.3 Rolal c/o Mafuri 182.9 91.3 22.9 2.1 118.4 44.6 Rosint c/o Mafuri 264.4 131.1 38.2 6.8 403.2 118.3 Royail Kalagba 539.8 268.2 64.3 31.1 3078.2 1533.4 Royema Marampa 105.1 48.3 20.5 7.7 779.6 133.3 Applicable 2 guideline PM (µg/m³) PM (µg/m³) Dust fallout (mg/m /day) 10 2.5 19 World Bank / IFC >50 >25 Not specified US EPA >150 >35 Not specified 300 1,200 (Target ) (Industrial) 600 2,400 SANS 1929:2005 Not specified (Residential) (Alert) The worst-case dust concentrations reported are highly conservative estimates, and the actual concentrations generated will (under normal operating conditions) be much lower – this has been considered in the assessment of signficance. Without management, the guideline limits will be exceeded at most villages directly surrounding the Project site, resulting in potential nuisance or health impacts on the inhabitants. However the management proposed by MIOL should decrease the extent and likelihood of dust generation, so recommended limits are likely to be met at almost all villages except those to be relocated (which have therefore been excluded from the impact significance rating). The impact will continue until the site has been rehabilitated post-closure, and will affect receptors within a radius of up to a few kilometres. 19 The World Bank Standards are based on the World Health Organisation Air Quality Guidelines Global Update, 2005. As well as the overall guideline of 50 for PM10, the guidelines include interim targets at 75, 100 and 150. For PM2.5 the interim targets are 37.5, 50 and 75. U3823_Marampa_ESIS_Final.docx September 2012 Page 195 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact AQ1: Dust emissions causing nuisance and health impacts on local communities Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity High High Receptor importance or High High Magnitude value description Extent of change / threshold High Moderate compliance Magnitude rating MAJOR MAJOR Duration Medium term Medium term Timeframe Frequency Low Low description Timeframe rating MEDIUM TERM MEDIUM TERM Spatial Scale INTERMEDIATE INTERMEDIATE CONSEQUENCE RATING MEDIUM MEDIUM PROBABILITY RATING DEFINITE UNLIKELY SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility Partially reversible Confidence Medium Management measures • Refer to the erosion control measures listed under Impact LT4. • Maintain or reduce vehicle speeds on unpaved roads to 40 km/hr, especially on roads passing near villages. • Implement dust suppression measures in areas close to receptors, such as wetting, use of chemical dust suppressant and / or paving, on roads with high vehicular activity (e.g. haul roads). • Control dust emissions on ore stockpiles through use of water spraying and/ or wind breaks. • Use dust suppression measures such as rock cladding or grassing, on the side walls of the TSF and other exposed built up areas. • Minimise the dry beach area of the TSF and wet the TSF surface if monitoring results indicate dust generation from this source. • Minimize lengths of access roads and eliminate unnecessary traffic. Good practice measures: • Investigate and respond to any air quality complaints picked up by the Grievance Mechanism. • Provide site workers with appropriate Personal Protective Equipment (PPE), and implement standard international occupational health and safety procedures. • Limit vehicle idling and keep vehicles well maintained. 9.2 Noise and vibrations An assessment of the noise and vibrations predicted to result from the Project was undertaken by Eddie Jewell Acoustics, using diurnal and nocturnal baseline noise monitoring U3823_Marampa_ESIS_Final.docx September 2012 Page 196 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report data collected at four villages in the Project area by a noise expert from SRK (Turkey). Meteorological data for the Project area was obtained from an automated weather station at the MIOL office Lunsar, as described in Section 5.8. The methodology used and findings of the baseline noise study are summarised in Section 5.8, and full copies of the baseline and the impact assessment reports are included in SD3 of Volume 3. Potential sources of noise and vibrations resulting from the Project include the following: • Mining equipment • Construction equipment (also used during decommissioning) • Processing equipment • Materials handling • Drilling and blasting • Pumps (e.g. for water supply) • Power generation equipment (HFO generators) • Vehicle related noise and vibrations (construction and operation) Although the primary receptors for noise and vibrations will be staff working at the mine, this is an occupational health and safety issue and therefore has not been included in the impact assessment. The use of the appropriate Personal Protective Equipment (PPE) by mine site workers is however recommended. The identified receptors for the purposes of the impact assessment are therefore the local villages in the Project area. In the absence of applicable guidelines or standards specific to Sierra Leone, the assessment of impacts on these villages has been made in accordance with the following references and standards, which are internationally accepted and used: • The IFC Environmental, Health and Safety Guidelines – Section 1.7: Noise; • Australian Standard (AS) 2187:2-2006 Explosives – Storage and use – Part 2: Use of explosives; • ISO9613-2:1996 Acoustics – Attenuation of sound during propagation outdoors – Part 2: General method of calculation. Where the degree of Project detail required for accurate prediction of impacts has not been available, reasonable assumptions have been made (particularly with regard to blasting), which may result in overly conservative assessment of potential noise impacts. It is noted also that a number of villages will be relocated due to positioning of the Project infrastructure. As expected, given their close proximity to the impact sources, these villages would be the most severely impacted by noise and vibrations, as reported in the Noise Impact Assessment report (Eddie Jewell Acoustics, 2012) in SD3 of Volume 3. However, as they will be relocated, impacts on these villages have not been included in the assessment. 9.2.1 NV1: Blasting causing air overpressure and vibrations, potentially resulting in disturbance of local communities Construction Operation Decommissioning Post-Closure Blasting for construction (earth works) and operations (mining) results in noise, air overpressure (transient air transmitted sound pressure waves moving outwards from an exploding charge) and vibrations that cannot be confined to the site, and may be experienced over large areas. As blasting is an occasional activity it does not affect the ambient noise limits evaluated, but can be disturbing to local communities with short-term noise exceeding U3823_Marampa_ESIS_Final.docx September 2012 Page 197 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 10 dB(A). Although each incident is short term in nature, the repetitiveness of the impact may give rise to complaints if not managed sensitively. The subjective reaction to a single disturbing event will depend on the activities being undertaken by the receptor and the manner in which the programme for blasting events is communicated to identified receptors. For example, a large blasting event at night time may give rise to complaints, where at any other time it would be accepted. The Australian Standard, AS 2187:2-2006, sets limits for ground vibration and air overpressure from blasting activities, separating them into two categories; those causing human discomfort and those with the potential for causing damage to structures. For the purposes of this assessment, criteria relating ground vibration and air overpressure which causes human discomfort have been used, as these levels are generally less than those likely to cause damage to structures. Apart from the villages that are to be relocated, it is also considered unlikely that there are substantive buildings or structures close to the mine site. Impacts on structures in the area resulting from blasting for the Project are therefore considered to be insignificant. These criteria specify a peak particle velocity (PPV) of 5 mm/s for 95% of blasts, and air overpressure not exceeding 115 dBL for 95% of blasts. AS 2187:2- 2006 cautions however that air overpressure and vibrations within these levels may still be noticeable, but are likely to be tolerated. As such, the impacts on local inhabitants are expected to be related specifically to annoyance (and therefore complaints) rather than detrimental health impacts. Disturbance of wildlife and domestic animals resulting from blasting are assessed in Impact EB3. The level of ground vibration is measured by the Peak Particle Velocity (PPV) and is directly related to the size of the blast and the distance from the blast - the closer to the blast the greater the vibration. Human sensitivity to vibration varies significantly between individuals, though a person will generally become aware of blast induced vibration at PPV levels of around 0.15 mm/s. Individuals have been found to be poor at distinguishing between vibrations of differing magnitudes. Air overpressure is reported as decibels (linear) or dBL, as opposed to sound pressure level, which is reported as decibels (dB) a logarithmic unit. At the time of writing, specific details regarding the proposed blasting regime required to accurately calculate air overpressure and ground vibration are not available. As such, an indicative assessment of the maximum permissible mass charge per delay at each of the mine pits was undertaken (see Impact Assessment Report in SD3 of Volume 3 for results), making reasonable assumptions, and refinement of the predictions is recommended once the required detail is available. It should be noted that the nearest noise sensitive receptors selected as part of the assessment for each pit exclude the villages proposed for relocation. Based on the calculated maximum permissible mass charge per day, air overpressure and ground vibration could be determined for the villages surrounding each pit, and assessed against the AS 2187:2-2006 limits. The assessment concluded that the ground vibration and air overpressure at local villages (except those to be relocated) will not exceed the AS 2187:2-2006 criteria when the maximum permissible mass charge per delays, detailed in the Impact Assessment Report (SD3 in Volume 3), are adhered to. Blasting disturbances will occur throughout operation and during daytime only, and at a lower level during construction, and are not reversible. However, the degree of annoyance may decrease over time as people become accustomed to the blasting. Although the effects of blasting will extend to villages outside the direct Project footprint (i.e. those that will not be U3823_Marampa_ESIS_Final.docx September 2012 Page 198 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report relocated), these are unlikely to constitute a negative impact on residents of these villages, as demonstrated by the air overpressure and ground vibration levels predicted (see the Impact Assessment Report in SD3 of Volume 3). Due to the low significance of the impact, no management measures are proposed, but a number of good practice measures are recommended. It is noted however that as Project-specific detail was not available at the time of the assessment, confidence in the prediction is low and more detailed assessment is recommended to confirm the results reported, prior to actual blasting. Impact NV1: Blasting causing air overpressure and vibrations, potentially resulting in disturbance of local communities Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative - Sensitivity Medium - Receptor importance or Medium - Magnitude value description Extent of change / threshold Medium - compliance Magnitude rating MODERATE - Duration Medium term - Timeframe Frequency Medium - description Timeframe rating MEDIUM TERM - Spatial Scale INTERMEDIATE - CONSEQUENCE RATING MEDIUM - PROBABILITY RATING UNLIKELY - SIGNIFICANCE RATING LOW (-ve) - Reversibility / sustainability Irreversible - Confidence Low - Good practice procedures: • Re-assess impacts once detail regarding blasting regime is available. • Monitor initial blasting to ensure compliance with specified air overpressure and vibration criteria. • Schedule blasting outside of hours when people are most disturbed by noise (such as at night). • Inform local communities of blasting timetable in advance and provide adequate notice of when blasts are required outside of the planned schedule. • Maintain records of each blast (including location of blast holes, design, measured overpressure and vibration) U3823_Marampa_ESIS_Final.docx September 2012 Page 199 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 9.2.2 NV2: Operation of mining equipment and vehicles potentially resulting in increase in background noise levels for local communities Construction Operation Decommissioning Post-Closure The increase in ambient noise levels resulting from operation of vehicles and mining equipment could cause disturbance to sensitive receptors (villages in the Project area). As the increase in ambient noise levels during construction and decommissioning is expected to be less than that for operations (due to significantly lower levels of mobile equipment activity), the impact predictions were not conducted for these phases. The most significant sources of noise during operation will be mining equipment, vehicles, and blasting. The pits, primary crushers and waste rock dumps are areas expected to contribute the most to noise impacts. Noise impacts on the inhabitants of local villages have been assessed qualitatively via predictive modelling of the increase in ambient noise levels expected to result from the above- mentioned Project-relates sources, for mining rates of 45 to 100 Mtpa (i.e. up to the maximum proposed rate). As noise generation is directly dependent on mining rate, with lower mining rates resulting in lower noise impacts, only results relating to mining at a rate of 100 Mtpa are included in this impact assessment. Brüel & Kjær Predictor environmental noise prediction software was used for the modelling, taking into account factors that may influence noise attenuation such as geometrical divergence (which includes distance), atmospheric conditions, topography, weather conditions and screening (incorporating pit depth). A conservative approach was adopted in the characterisation of these factors, as well as certain assumptions regarding operation (such as that all pits will be mined, and all machinery will be operated, simultaneously), resulting in what may be considered a worst case scenario with regard to the increase in ambient noise. Noise contour maps (shown in Figure 9.3 and Figure 9.4) were created to show the distribution and magnitude of potential noise impacts over the Project area, relative to local villages and the mine infrastructure. The predictions are reported to be accurate to ±3 dB for distances up to 1000 m from the source. The predicted A-weighted broadband sound pressure levels (LAeq) at local villages during daytime and night time were assessed relative to the IFC noise guideline levels. According to these guidelines, a noise source should not result in a maximum increase in background noise levels of 3 dB, and noise emissions from the proposed mine should be equal to or less than the existing ambient noise level, at the nearest noise sensitive receptor, up to the criteria stated. These criteria, outlined in WHO Guidelines for Community Noise (1999), which have been derived based on research on health impacts resulting from noise emissions, specify a LAeq of up to 55 dB during the day or 45 dB at night in residential, institutional or educational areas (the appropriate category for the local villages). Noise impacts on local communities are usually experienced as an annoyance, especially when they occur during the night, when they may disturb sleep, resulting in stress and other related health impacts. The increase in ambient noise can be expected to be experienced by local communities as follows: • increase of 3 dB(A): a person with average hearing will just be able to detect this; • increase of 5 dB(A): community reaction to the increase in noise may be expected; • increase of 10 dB(A): corresponds to doubling of the subjective loudness of noise and community would consider this ‘disturbing’. U3823_Marampa_ESIS_Final.docx September 2012 Page 200 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 9.3: Noise contour map at day time for 100 Mtpa mining rate, relative to local villages U3823_Marampa_ESIS_Final.docx September 2012 Page 201 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Figure 9.4: Noise contour map at night time for 100 Mtpa mining rate, relative to local villages Impacts on mine workers are not included in this impact assessment. However, the close proximity of workers to noise emission sources could lead to exposure above threshold levels for health and safety for periods which are longer than recommended, potentially resulting in direct health impacts through impairment of hearing. Therefore, mine workers should be U3823_Marampa_ESIS_Final.docx September 2012 Page 202 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report provided with suitable PPE in the form of ear protection (plugs, muffs etc.,) based on the nature of the emission sources (frequency, duration, etc.) to prevent long term degeneration of hearing. The noise impact predictions (as shown in Figure 9.3 and Figure 9.4) indicated that the day and night time maximum noise level criteria (as per the IFC guidelines) will be met at all local villages, except for a few that have already been identified for relocation (generally due to proximity to the proposed pits or infrastructure). Of the villages proposed for relocation, night time noise levels for Ma Sesay, Mafuri, Maso, Matukia, Rosint c/o Mafuri, Royail Kalagba and Konta, and daytime noise levels for Ma Sesay, Mafuri, Maso and Matukia are predicted to exceed the IFC noise guideline levels (by between 0.1 and 21.9 dB(A) – see Impact Assessment Report in SD3 of Volume 3 for details). This impact is not reversible but will cease post-closure. Due to uncertainties and assumptions made regarding certain details of the Project description required for the impact modeling, the confidence of the impact rating is rated as medium. Although no formal management measures are required, it is recommended that good practice measures, as outlined below, are adopted to ensure as minimal impact on the receptors as is practical. Impact NV2: Operation of mining equipment and vehicles potentially resulting in increase in background noise levels for local communities Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative - Sensitivity Low - Receptor importance or Low - Magnitude value description Extent of change / threshold Low - compliance Magnitude rating MINOR - Duration Medium term - Timeframe Frequency - - description Timeframe rating MEDIUM TERM - Spatial Scale INTERMEDIATE - CONSEQUENCE RATING LOW - PROBABILITY RATING POSSIBLE - SIGNIFICANCE RATING LOW (-ve) - Reversibility / sustainability Irreversible - Confidence Medium - Good practice measures: • Maintain vehicles and equipment in accordance with manufacturer’s instructions to minimise noise. • Avoid unnecessary revving of engines and switch off equipment when it is not required. U3823_Marampa_ESIS_Final.docx September 2012 Page 203 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report • Start up vehicles and plant sequentially rather than simultaneously. • Fit vehicles with broadband reversing alarms. • Undertake standardised noise measurements on major items of equipment upon delivery to provide a noise reference against which regular checks can be compared. • When plant equipment is due for replacement, the replacement equipment should have a sound power level equal to or less than the plant that it is replacing. • Plan for operating times of noisy activities to be outside of hours when people are most disturbed by increased noise levels (such as at night). • Promptly investigate and respond to any noise complaints picked up by the Grievance Mechanism. • Routine noise monitoring should be carried out at the surrounding receptors, and records thereof maintained. • Keep haul routes well maintained and avoid steep gradients. • Minimize the drop height for materials. 9.3 Traffic safety The nature of the mining operation at this site, and the means of transportation of the processed ore (rail only in Stage 1, and a combination of rail and slurry pipeline in Stage 2) means that potential impacts from Project related traffic on local road networks will mainly be concentrated in, and will peak during, the construction and decommissioning phases of the mine. These are the periods when construction and infrastructure engineering traffic will have most impact on the local public road network. Transportation of fuel supply to the mine will be via road tankers, but as this will be managed by a third party it has been excluded from the assessment of impacts in this ESIA. As most staff will either be housed on the mine site (at the accommodation camp) or will be sourced locally from Lunsar or surrounding villages, large volumes of traffic commuting daily to and from the site are not expected. Impacts relating to traffic safety during the operational phase will primarily be associated with mobile equipment travelling on mine site roads (such as haul roads), and contractor traffic visiting the site, the day to day movements of site staff and freight and service vehicles on local roads. Although the haul route for the loaded ore transportation trucks from the pits to the beneficiation plant will cross the route of the Makeni highway at two points, this will be affected by the construction of multi-plate arch culverts for the haul roads to pass under the highway as described in Section 4.8.1. As a result, mine site traffic will not come into direct conflict with highway traffic, and will not make use of local roads infrastructure during the mine’s operation 9.3.1 TS1: Increase in Project-related traffic on local and national roads causing increased wear and tear and risk of road accidents Construction Operation Decommissioning Post-Closure Traffic volumes on local and national roads, such as the Makeni Highway (which connects Lunsar to Freetown and therefore will be used by vehicles transporting goods and materials from the port or capital to the mine site) will increase during construction, decommissioning and operation of the mine. This could affect road safety for other road users through increased wear and tear on the roads (as well as increasing vehicle maintenance costs) and risk of road accidents. The impact of traffic associated with a mining site on local road safety U3823_Marampa_ESIS_Final.docx September 2012 Page 204 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report is generally a function of the following three factors: • The nature of the traffic generated by the mine (HGV’s, dump trucks, oversize loads, freight vehicles, cars, light vans, etc.) and the frequency of movements of these; • The nature and density of the existing traffic and other road users on the roads affected by the mine traffic; and • The condition and suitability of the roads to cope with the nature of the mine traffic. In the case of this Project, the majority of the mine-related traffic will be limited to the mine’s daily operation and servicing by various freight and light vehicles and its construction and decommissioning (i.e. construction related traffic) as mentioned above. The operation of the mine in terms of on-site transportation of crushed rock, ore, waste rock, processed ore and soil movements will be on dedicated haul and mine site roads and will not generally affect the local road network. Traffic safety impacts relating to use of haul roads by communities during operation of the Project are discussed separately in Section 9.3.2 (impact TS2). The Makeni Highway is an engineered tarmac highway, and the current level of usage of the road includes usage relating to other mining activities in the area. The additional traffic which the mine will generate will therefore be broadly of a nature which is in-keeping with the type of traffic currently utilising the highway, being mainly light vehicles (cars, vans and light transporter vehicles) with some heavy goods vehicles (HGVs). During the construction and decommissioning phases of the mine, over-size loads could be expected to be travelling to and from the site. However, the relatively good standard of the Makeni Highway’s construction and the relatively low level of existing traffic upon it mean that such occasional loads can be accommodated by the existing traffic-highway system. The appropriate marking of over-size loads and ensuring that they are accompanied by ‘pilot’ vehicles is a management measure which can also be readily implemented to minimise road safety hazards from the movements of such loads on the public highway. The risk of materials or items falling from construction vehicles, light freight and HGV’s and causing a safety hazard is always present during construction of large developments. It can however be readily managed by ensuring vehicles conveying construction and fabrication materials are appropriately sheeted and that loads are securely placed and attached, as is generally standard practice. Freight and goods vehicles delivering essential supplies and maintenance equipment to the site will, similarly, be either of tanker design (on the case of liquids, (fuels, beneficiation plant chemicals, etc.,) or rigid body design (in the case of freight and service vehicles) thereby minimising the risk of objects falling from them and causing a safety hazard. Impacts on road surface condition and maintenance through wear and tear resulting from increased road use by heavy vehicles may include potholes and erosion of the road edge. Both of these can become progressively worse with time and are exacerbated by rainy conditions, which contribute to erosion of the road’s subsurface layers by washing away the fine soil particles responsible for cohesion of the larger particles. Road wear and tear increases maintenance costs (both for vehicle owners and the authority responsible for maintenance of the road) and, if not timeously repaired, increases safety risks for vehicles using the road. As the nature of the traffic to be generated for the mine is generally similar to that already using the highway, the additional impact on safety and road maintenance is considered to be low. Impacts on public roads more local to the site (which are presumably designed to accommodate predominantly lighter vehicles) are expected to be higher, and redesign of these roads to accommodate the additional mine-related traffic may be required. U3823_Marampa_ESIS_Final.docx September 2012 Page 205 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report The impact on roads and traffic will last from the inception of site construction activities through to the end of the decommissioning phase. Although the impact could potentially be experienced over the length of the highway over which mine-generated traffic travels, this would be substantially ‘diluted’ by the mine-generated traffic’s inclusion in the general traffic flow. Therefore the area in which the greater part of the risk occurs is more local to the site, in particular district or local roads used to access the site after exiting the Makeni highway. Careful timing of delivery of oversize loads, for example, and ensuring that delivery vehicles are appropriately sheeted and that loads are correctly distributed and fastened in accordance with standard health and safety procedures, as well as contribution to road maintenance in the area, could reduce the safety risk and therefore the significance of the impact. As numerous uncertainties remain, especially when rating the significance of safety risks, the confidence in the rating is medium. Although impacts on road conditions are reversible, safety impacts on other road users are not. Impact TS1: Increase in Project-related traffic on local and national roads causing increased wear and tear and risk of road accidents Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity Medium Medium Receptor importance or Medium Low Magnitude value description Extent of change / threshold Medium Low compliance Magnitude rating MODERATE MINOR Duration Medium term Medium term Timeframe Frequency Low Low description Timeframe rating MEDIUM TERM MEDIUM TERM Spatial Scale INTERMEDIATE INTERMEDIATE CONSEQUENCE RATING MEDIUM LOW PROBABILITY RATING DEFINITE POSSIBLE SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility / sustainability Irreversible Confidence Medium Management measures • Appropriately sign-post the site entrance and access to the Makeni highway. • Design site roads to a standard suitable for mine and construction traffic, and maintain the roads to this standard. • Assess the condition of local roads and their capacity to accommodate the mine-specific traffic and if necessary upgrade the roads prior to mine construction. • In conjunction with the Government of Sierra Leone, devise and implement a road maintenance programme for roads affected by the Project. Good practice measures: • Design and implement sheeting and correct positioning and securing of loads on vehicles U3823_Marampa_ESIS_Final.docx September 2012 Page 206 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report in line with international health and safety procedures. • Control delivery of oversize loads to site during times of minimal highway traffic as far as possible, and minimise travel outside daylight hours. • Minimise travel by heavy vehicles during heavy rains. 9.3.2 TS2: Use of mine site roads by local communities and their livestock causing increased safety risks due to road accidents Construction Operation Decommissioning Post-Closure A potential source of safety impact to local communities and their livestock is the use of mine site roads (such as haul roads, which will not be fenced) as access routes, either for crossing or travelling along as an easier alternative to the informal access routes currently used (see discussion in Section 7.1.2 – Impact LT2). This creates a risk of injury or fatality resulting from collision with pedestrians or livestock, or objects falling from trucks onto pedestrians. As it is expected that the haul roads and other on-site roads will intersect current access paths used by communities, crossing points are likely to be created, both for use by communities, for example when accessing other villages, and possibly also their livestock. This uncontrolled crossing over working mine site roads will pose an obvious safety risk if safe alternative crossing points are not provided, and crossing at other points is prevented. An additional aspect of the risk is the use of haul roads (or other mine site roads) themselves, as an alternative to the current access tracks, many of which are in bad condition and are only passable on foot. Despite being limited to areas accessible from the mine site roads, this would be an attractive option particularly for transportation of goods to markets or other villages, as it would make mechanical transportation of the load a more viable option. The possibility of objects falling from mine site vehicles and causing a safety hazard for pedestrians is another potential risk, particularly so where ore, rock or mining equipment are transported. Based on the estimation of 300 mining days per year, it is estimated that up to about 85 kt ore would need to be transported per day along haul roads from the pit to the beneficiation plant, requiring approximately 350 movements in a 240 tonne truck, and 120 kt rock waste per day requiring approximately 500 truck movements between the pits and the waste rock dumps. Total truck movements would effectively be doubled to account for the return empty truck journey, resulting in approximately 700 movements per day (or one truck every two minutes) on the haul roads, and 1000 movements per day (or one truck every 1.5 minutes) between the pits and the WRD. These numbers do not however account for other mine traffic on the site roads so the numbers are likely to be higher. Vehicle entrainment of dust would decrease visibility, thereby increasing the safety risk. The impact would peak during operation, but continue until the end of decommissioning, when mine-related traffic would no longer use the site. The implementation of the management measures listed below could decrease the probability of accidents occurring, thereby reducing the significance rating of this impact. As the extent to which local communities will use or cross the mine site roads has not been established, the impact cannot be rated with a high level of confidence. U3823_Marampa_ESIS_Final.docx September 2012 Page 207 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact TS2: Use of mine site roads by local communities causing increased safety risks due to road accidents Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity Medium Medium Receptor importance or Medium Medium Magnitude value description Extent of change / threshold Medium Medium compliance Magnitude rating MODERATE MODERATE Duration Medium term Medium term Timeframe Frequency High High description Timeframe rating MEDIUM TERM MEDIUM TERM Spatial Scale SMALL SMALL CONSEQUENCE RATING MEDIUM LOW PROBABILITY RATING DEFINITE UNLIKELY SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility / sustainability Irreversible Confidence Medium Management measures • In agreement with local communities, establish safe road crossing points at selected localities. • Enforce speed limits and safe diving practice. • Educate local communities on traffic safety. • Implement dust control measures on unpaved roads and manage sources of dust close to roads to maintain visibility and traffic safety. • Consider providing and maintaining access paths alongside roads for key access area. 9.4 Security and Social risks Protection of human rights and ensuring health and safety of both the community and the workers is a responsibility of the Project developers. Potential impacts and risks to human rights, security and community health and safety are discussed below. 9.4.1 SR1: Risk of human rights abuses due to conflict with the communities Construction Operation Decommissioning Post-Closure Conflicts which are dealt with through force (including armed force) either by local police (on request of the Project proponent) or private security guards employed by the Project can lead to violation of human rights, particularly the right to freedom, freedom of expression and health (and safety). There have been recent incidents, on other Sierra Leone mining Projects, of police using force (lock ups and open firing leading to death or injury of members of the public) hence there is a need to manage this risk/potential impact. Potential tension between the community and the Project as well as potential for intra and U3823_Marampa_ESIS_Final.docx September 2012 Page 208 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report inter village conflict due to perceived or real unequal access to Project related benefits (as discussed in Impact SO3, Section 8.3.3) can lead to human rights abuse if not prevented or managed appropriately. The prevention and management measures will be guided by the Voluntary Principles on Security and Human Rights (VPSHR) that provide guidance on the roles and responsibilities of companies (in the extractive sector) and civil society. A culturally appropriate programme for stakeholder consultation with regular dissemination of information and an active mechanism for recording and resolving community grievances in a timely manner will be necessary for managing this impact. The Project community relations team will monitor the human rights situation to assess if the possibility of this impact occurring is decreasing or increasing and plan accordingly (as needed). The impact has the highest probability of manifesting during construction and operations, with reduced probability during decommissioning. The mitigation measures largely focus on eliminating the possibility of human rights violation and on reducing the severity of the impact if anything does go wrong. Any deterioration in the human rights situation is difficult to manage but reversible. A strong policy and programme by MIOL for protection of human rights can effectively prevent this impact hence the higher confidence rating. Impact SR1: Risk of human rights abuses due to conflict with communities Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity High High Receptor importance or High High Magnitude value description Extent of change / threshold Major Minor compliance Magnitude rating MAJOR MODERATE Duration Long term Long term Timeframe Frequency - - description Timeframe rating LONG TERM LONG TERM Scale SMALL SMALL CONSEQUENCE RATING HIGH MEDIUM PROBABILITY RATING POSSIBLE UNLIKELY SIGNIFICANCE RATING HIGH (-ve) LOW (-ve) Reversibility Reversible Confidence High Mitigation measures • Provide training to MIOL security staff and local police on the Voluntary Principles on Security and Human Rights. • Maintain the grievance procedure, and encourage and facilitate stakeholders to use the mechanism to express concerns. U3823_Marampa_ESIS_Final.docx September 2012 Page 209 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 9.4.2 SR2: Increased exposure to communicable diseases due to an influx of workers, potentially resulting in a deterioration in public health Construction Operation Decommissioning Post-Closure As per the Lunsar Peripheral Health Unit (PHU) records since 2005 communicable diseases, particularly Sexually Transmitted Infections (STIs) and HIV/AIDS are on the increase in the Chiefdom. Factors such as the arrival of a predominantly male workforce (Project related as well as speculative job seekers) and increase in disposable incomes can lead to further increase in local prostitution and arrival of commercial sex workers in the Lunsar area. The incidence of HIV/AIDS amongst commercial sex workers is estimated at 10% against the incidence among the general population at 1.6%. Mixing between outsiders and locals can also cause an increase in the incidence of other communicable diseases such as tuberculosis, malaria, respiratory infections and diarrhoea. Management measures, implemented by the Project clinic for the mine employees and by the PHU’s for the community, will focus on prevention and control to minimise the extent and probability and on early diagnosis and treatment to minimise the duration. This impact would manifest mainly during the construction phase, when the influx in population would be at its peak, however it can continue into the operation phase as well with slightly less intensity. The confidence is medium as other factors, unrelated to the Project, may influence the overall impact experienced in the area. Impact SR2: Increased exposure to communicable diseases due to an influx of workers, potentially resulting in a deterioration in public health Residual or optimised impact Impact characteristics Initial impact (taking cognisance of management measures) Type (+ / - /neutral) Negative Negative Sensitivity High High Receptor importance or High High Magnitude value description Extent of change / threshold Moderate Minor compliance Magnitude rating MODERATE MINOR Duration Long term Medium term Timeframe Frequency - - description Timeframe rating LONG TERM MEDIUM TERM Scale SMALL SMALL CONSEQUENCE RATING MEDIUM LOW PROBABILITY RATING DEFINITE POSSIBLE SIGNIFICANCE RATING MEDIUM (-ve) LOW (-ve) Reversibility Partially Reversible Confidence Medium U3823_Marampa_ESIS_Final.docx September 2012 Page 210 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Impact SR2: Increased exposure to communicable diseases due to an influx of workers, potentially resulting in a deterioration in public health Mitigation measures • Develop and implement management policies for HIV/AIDS, tuberculosis and other potential communicable diseases focusing on prevention, control, diagnosis and treatment in coordination with NGOs and local government. • Provide health awareness programmes and counselling services to employees. • Promote use and availability of condoms at the workers camp. • Undertake routine health screening of employees to detect and treat diseases early. 9.5 Other hazards potentially resulting in injury The additional hazards discussed below were identified as those most pertinent to the Project. In this section ‘hazard’ is defined as the potential to cause harm; risk is the probability of harm arising from that hazard. The risk may only materialise under a certain set of circumstances. Therefore although risk is characterised in a similar way to impacts (consequence and probability), generally the probability of such risks occurring is much lower than the impacts discussed in the previous sections due to standard controls implemented to minimise the identified risks. Mines, roads and associated infrastructure are inherently dangerous facilities, with physical, chemical and electrical hazards with potential to harm people or wildlife. The risk of injury or harm and the significance of resulting impacts relate to a number of factors including: • type of hazard; • when, where and how the event materialises; • number of people injured or the extent of ecological damage; • duration of the harmful exposure; • frequency with which the hazard causes injury or harm; and • extent to which injury or harm could have been prevented (for example with suitable management plans in place). The most significant Project hazards are discussed in more detail below. Because of the number of variables affecting the consequence and probability of such events, accurate significance rating of possible impacts should the risk materialise is not possible. Each event must be evaluated on an individual basis, in accordance with the incident reporting system outlined in Section 11.3.2. 9.5.1 OH1: Blasting resulting in fly rock potentially harming people or their possessions Fly rock refers to uncontrolled rock flung into the air as a result of blasting. It may result in death or serious injury on impact with humans or animals within the area around the pits and is one of the most common causes of injury related to blasting. To reduce the risk of injury the Project will conduct blasting in accordance with international safety standards. Open pit blasting will be conducted using standard mining industry practices and procedures for securing personnel and equipment. This includes the development and implementation of standard operating procedures, blasting rules and a safety management plan that: • Delineates the danger zone associated with each blast of at least 400m and clear U3823_Marampa_ESIS_Final.docx September 2012 Page 211 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report workers from this zone before, during and after each blast; and • Provides an audible warning at least three minutes before a blast is fired. 9.5.2 OH2: Community exposure to toxic or hazardous substances Community exposure to toxic or hazardous substances is most likely to occur as a result of two factors. The first is accidental spills of these substances to the environment during handling, storage, disposal or transportation. The second is via landfill disposal of substances in proximity to communities. Spills may occur during construction and operation, or decommissioning (when any hazardous substances stored on site would be removed and either disposed of or used elsewhere). Hazardous substances that will be stored and used on the mine site include fuels (both HFO and diesel), oil, coolant and hydraulic fluid for mining equipment (stored in 200 l drums). Impacts resulting from spills of product or tailings material to water resources are discussed and rated under Impact WR6. The potential impact associated with each release will depend on the source of material released, its inherent hazard potential (toxic, acidic, flammable etc.), the volume released, the extent of release and sensitivity of any human or ecological receptors. Particularly spills close to water courses (or other water resources) could result in significant ecological and health impacts due to the rapid spread of contaminants in water, affecting downstream users. . In terms of exposure to potentially hazardous substances in the landfill associated with the mine, it is important to note that the landfill at the site will be solely for domestic (non-mining) type wastes generated by activities associated with the mining operations. Wastes strictly defined as ‘toxic’ or ‘hazardous’ in accordance with international definitions will be removed from the mine site to an appropriately licensed waste facility. However, the risk of exposure of communities to decaying (and potentially toxic) organic matter in the landfill remains, but can be effectively mitigated by implementation of the management measures listed under Impact EB4 (Section 7.3.4), with particular attention to the following: • Implementation of standard management practices such as ensuring appropriate site security and fencing, to prevent unauthorised access to the waste landfill site. • Thorough and regular compaction and covering of wastes with inert materials (at least weekly). This would also greatly reduce the likelihood of pests being attracted to the landfill, and the associated health hazards. The potential impacts associated with spills of toxic or hazardous materials can be reduced through the implementation of standard management measures, which aim to minimise the risk of spills occurring and the extent of any damage should a spill occur. Recommended general good practice measures include the following: • Design hazardous material containment structures taking into consideration natural hazards and the implications of these on structural integrity of the containment facilities. • Size containment areas to contain 110% of the contents of the largest tank within the facility or provide facilities to direct excess volume to an alternative spill containment facility. • Pave (with an impermeable surface such as concrete) mine site fuel delivery and dispensing pump areas and designed these areas to drain into the adjacent storage tank containment areas. • Prohibit construction of hazardous material facilities (including temporary and permanent refuelling areas) within drainage lines or the 1 on 100 year flood lines of watercourses. • Treat (for example with an oil separator), evaporate or dispose of as a hazardous U3823_Marampa_ESIS_Final.docx September 2012 Page 212 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report material any polluted water collected in hazardous material containment facilities. • Require vehicle maintenance to be undertaken in the designated workshops where appropriate pollution control measures are provided to prevent leaks or spills of fuel or lubricants reaching the environment. • Develop and implement a spill prevention and control system as part of the Emergency Preparedness and Response Plan for the mine site (Section 11.6). 9.5.3 OH3: Fire or explosions due to storage of explosives and use of combustible materials The storage and use of both fuels (and other combustible materials) and explosives poses an inherent fire, and therefore safety, risk to workers on site and surrounding communities. To minimise the risk, standard international good practice will be followed with regard to storage and handling of these materials, and occupational health and safety guidelines with regard to safe working conditions and the use of PPE will be adhered to. As detailed in Section 4.8.7, fire extinguishers will be available at storage areas for flammable substances, and a fire water system will be installed, servicing the beneficiation plant and accommodation areas. 9.5.4 OH4: Failure of the TSF resulting in pollution or harm to individuals The most significant potential safety and environmental hazard resulting from failure of mine workings is structural failure of the TSF (such as foundation failures, containment wall collapse, or failure of the tailings pipeline). This could typically be caused by seismic activity, and may result in contamination of surface water, groundwater or soils in the surrounding areas, with tailings material. However, as described in Section 5.3, the Project site is located in one of the least seismically active zones in Africa, and is therefore considered to be in a low seismic hazard area. The TSF is designed to withstand an operating basis earthquake loading of 0.06g (0.6 m/s²) and a post-closure maximum credible earthquake loading of 0.1g (0.1 m/s²). The design of the TSF is in accordance with the internationally accepted Australian National Committee on Large Dams Incorporated (ANCOLD) Guidelines on Tailings Dam Design, Construction and Operation, published in 1999. It is based on a tailings concentration of 60% (solids by mass), a deposited dry density of1.5 t/m³ and is designed to contain a 1 in 1000 average recurrence interval three-day rainfall event, whilst maintaining a freeboard of at least 0.3 m. Thickening of tailings, as proposed by the design engineers, has the advantage of reduced water content over conventional methods of tailings disposal, as it decreases the likelihood of tailings and process fluid leaks, and the widespread release and downstream spread thereof in the event of leaks. Following closure the TSF will be rehabilitated and excess water will drain, as the tailings material becomes increasingly solid and stable. A pond will remain on the TSF, and beach areas above the pond surface will be capped by covering with soil and rock. Further detail regarding rehabilitation and capping of the TSF will be confirmed after geochemical characterisation of the tailings material has taken place. Further detail on the design of the TSF is available in the Tailings Storage Facility Design Interim Scoping Level Report (August 2011) by Coffey, which is included in Appendix E. Due to the low seismicity of the area and inherent design precautions in the TSF design, the likelihood of its failure is considered to be low. The relatively inert nature of the predicted tailings material implies that, should TSF failure occur, the impacts on human health resulting from exposure to tailings, contaminated surface water, groundwater or soil are not expected to be significant. However this would of course depend on the amount of tailings material released. No additional good practice measures are recommended. U3823_Marampa_ESIS_Final.docx September 2012 Page 213 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 10 CUMULATIVE IMPACTS For the purposes of this assessment, the definition of cumulative impacts provided in the IFC’s Glossary of Terms (IFC, 2006) has been used: ‘the combination of multiple impacts from existing Projects, the proposed Project and/or anticipated future Projects that may result in significant adverse and/or beneficial impacts that would not be expected in case of a stand- alone Project.’ The aim of this preliminary assessment is therefore to identify, and if necessary lay the groundwork for possible issues requiring co-ordinated actions by a number of agencies or groups. The assessment considers the most significant impacts and risks identified for the Project (those rated high in Chapters 7, 8 and 9) and overlays them in time and space with known or possible impacts or risks from other current, planned or reasonably foreseeable activities. In the case of the Project, there has been prior development in the area, mainly linked to mining, and at the time of writing this ESIA SRK there are two other iron ore mining Projects in the country (one by London Mining and the other by AML), with the London Mining (LM) Project being immediately adjacent to MIOL and AML sharing infrastructure with MIOL. The cumulative impact assessment is therefore predominantly based on the likely impacts of the London Mining and MIOL, as well as the AML mining Project and Bumbuna Dam hydroelectric Project on the Rokel River upstream of the MIOL Project. Emphasis is on significant impacts that are additive or synergistic in nature. The cumulative assessment consists of the following steps: • Using knowledge gained from the baseline studies and from stakeholder consultation, the past, present and reasonably foreseeable future activities from sources external to the Project but occurring in the Project’s area of influence are identified (Table 10-1). This includes the possible future expansion of the MIOL Project, including product export infrastructure, which is not otherwise covered by this impact assessment (Section 3.2). • Based on the results of the impact assessment (Chapters 7, 8 and 9), a preliminary judgement is made on whether cumulative impacts on specific environmental or social components are possible or likely – the results are given in Table 10-1. • Where potential cumulative impacts are identified in Table 10-1, significant Project impacts (rated high in Chapters 7, 8 and 9) are evaluated for their potential additive or synergistic interaction with potential future developments in the following sub-sections. The process outlined above yielded a number of types of potentially significant cumulative impacts, as described below. U3823_Marampa_ESIS_Final.docx September 2012 Page 214 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 10-1: Past, present and reasonably foreseeable activities in Project affected area potentially resulting in cumulative impacts Project Past and present Potentially significant cumulative impacts component activities causing Reasonably foreseeable Land Water Ecological Distur- Economic Social (and area significant impacts future activities Air quality (a) (b) affected) transformation resources systems bance growth change • LM mine • Bumbuna dam Mine site and (construction and hydroelectric Project Possible Likely Possible Possible Possible Likely Likely water supply development) • MIOL/LM future expansions • AML railway line • Construction and Concentrate (along which MIOL operation of MIOL export (Stage pipeline will run) product export pipeline Possible Possible None Possible Possible Possible Possible 2) from mine and port facilities at for Stage 2 expansion site Pepel (then • Product dewatering at possibly Tagrin) port • Traffic increases in • Traffic associated Lunsar as a result of with construction growth in local and operation of population (due to National and AML and LM mines development in the Local Road • Traffic associated area) None None Possible None Possible Possible Possible usage with other • MIOL/LM future development in the expansions Lunsar area • Construction of Bumbuna dam hydroelectric Project • Additional relocations Relocation of • Development of and land acquisition local LM mines required (due to MIOL Possible Possible None Possible Possible Possible Likely communities Project expansion and other Projects) (a) Includes: noise, visual, vibrations and traffic (b) Includes: equity issues, access to services, deterioration in health, social ills, food and water security, pressure on infrastructure and services, etc. U3823_Marampa_ESIS_Final.docx September 2012 Page 215 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Based on the evaluation above the most significant cumulative impacts are likely to be those on water resources, economic growth and social change, and are discussed in Sections 10.1 to 10.3 below. The following cumulative impacts could also occur, but MIOL’s contribution is unlikely to significantly change the overall impact to the area: • Land transformation: the cumulative effect of other developments in the area may increase the extent of disturbed areas from those in and around the Project footprint to the general surroundings. This would place added pressure on non-disturbed areas for agricultural land and natural resources; cause more widespread disruption of community access routes and changes in the visual character of the general area and more widespread erosion of topsoil, affecting land capability. • Air quality: MIOL’s proposed current and future developments, along with London Mining’s operations, AML’s railway and the general development of the central part of Sierra Leone will result in increased contributions of gaseous and particulate matter to the local air quality catchment. MIOL’s contribution to this is moderate at most and this regional issue can only be managed with co-ordination from government bodies to ensure ambient air quality is monitored on an ongoing basis and controls put in place to minimise long term health risks to communities in the area. • Ecological systems: Cumulative impacts on ecological systems would result primarily from the other cumulative impacts discussed here. These include land transformation, which would place undisturbed areas under increased pressure; disturbance of wildlife; and impacts on water resources, reducing the amount of wetland habitat available (e.g. through groundwater drawdown), and reducing instream habitats through altered stream flow. • Disturbance: MIOL will slightly contribute to the already increasing noise, visual and vibration disturbance in the Lunsar area. Other forms of disturbance potentially resulting in cumulative effects include lighting (of other mines or developments in the area), and traffic, affecting road safety and condition in the general Project area. 10.1 Water resources Cumulative impacts on water resources are expected to affect both surface and groundwater resources, which are used by local communities for domestic purposes, agriculture and industry and are important for the riverine ecological systems. It is understood the first phase of the nearby London Mining operation involves re-processing of tailings material from previous mining rather than mining of fresh ore, and it is therefore assumed pit dewatering would initially not be required. However, an expansion of the operation to mine fresh ore is proposed, and may require pit dewatering. The MIOL impacts of groundwater drawdown on water supply to local communities is currently only of medium to low significance however given community reliance on groundwater and the proposed future expansions of both MIOL and LM pit dewatering could further increase risks to domestic groundwater supply and agricultural/ecological systems reliant on groundwater fed wetlands in the area. The use or impoundment of surface water from local resources by MIOL, LM and developing area of Lunsar could have significant cumulative impacts on river flow patterns and surface water availability in the area. These local impacts may cumulatively impact the Rokel River which although not currently significantly impacted, may in future be influenced by the proposed expansion of the Bumbuna dam hydroelectric Project, located upstream on the Rokel River. U3823_Marampa_ESIS_Final.docx September 2012 Page 216 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 10.2 Economic growth The significant Project impacts associated with economic growth and development are assessed in Chapter 8 (Impacts ED1 to ED4). Development of other Projects in the area could potentially result in significant positive synergistic effects in the local economy, benefiting local communities and Lunsar town, if not Sierra Leone as a whole. This growth would result from: • direct employment and skills development from the Project and other developments during both construction and operation; • outsourcing opportunities for local suppliers; and • increase in government revenue potentially resulting in investment in social development. Initial Project related economic growth and development would result from MIOL capacity- building programmes as employees are trained and gain experience. Parallel employment and training would occur for the Project’s support services in the area. Other mining and industrial developments within the Marampa area could significantly add to the critical mass and make this growth self-sustaining, fuelling further economic growth, for example: • experienced employees would have the opportunity to increase their earning potential by seeking employment at other developments; • other businesses would develop to provide services to the local population leading to the creation of alternative livelihoods; • increased development and employment would increase the tax base, which could lead to other educational and training opportunities; • increased social services from the local governments; • capacitated communities may be more able to express their wishes or concerns; and • vulnerable groups, such as women and the elderly, may become more empowered if they can be involved in both Project and other economic activities. Cumulative impacts between the Project and other developments have the potential to contribute to significant synergistic effects on the macro-economy of the area. The Project may therefore be a contributor to growth in the area, encouraging other unrelated industry to develop. Successful regional development will mitigate negative impacts associated with the cessation of a single activity (such as when the Project closes). Other developments in the area will then be able to absorb trained workers, potentially use Project infrastructure (such as the power station, accommodation camp and associated facilities, and rail spur line) and make use of the support services, so that the closure of any one development will not necessarily translate into a regional economic downswing but instead provide added local resources to support further sustainable development. 10.3 Social change associated with population increase due to in-migration The significant Project-related impacts associated with population increase due to in-migration are discussed in Chapter 8 (Impact SO1), and include competition for jobs and resources. Additional development in the Lunsar area, such as other mines and secondary development, is likely to trigger further in-migration of job seekers (some has already been observed as result of London Mining’s operations). If not effectively mitigated, this could lead to proliferation of informal settlements and social issues relating to unemployment in the area. U3823_Marampa_ESIS_Final.docx September 2012 Page 217 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report This will also put increased pressure on existing infrastructure and services, food security and water supply, all of which are already under strain at times to meet the needs of the current population. Mitigation measures for this potential cumulative impact, beyond those defined for the Project, will require coordinated management by a number of private and public sector parties and therefore cannot be defined at this time and as such are not included in the EMP (Appendix F). However, it is important these issues are addressed in a timely manner as population increase through in-migration could indirectly increase the magnitude of other Project related impacts on local communities. U3823_Marampa_ESIS_Final.docx September 2012 Page 218 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 11 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM This document describes the framework for the Environmental and Social Management System (ESMS) for the Project. The framework has been developed with consideration of the requirements of Sierra Leone’s legislation and guidelines, the IFC’s Performance Standard 1 and the main principles in the International Standards Organisation (ISO) 14001 Standard (ISO 14001:2004, 2004). Some organisations use different terms for an ESMS, for example the International Standards Organisation (ISO) uses “environmental management system” or “EMS”. For the purposes of this document, the terms are synonymous. The IFC Performance Standards state the objectives of an ESMS are to: • identify and assess social and environmental impacts, both adverse and beneficial; • avoid, or where avoidance is not possible, minimize, mitigate or compensate for adverse impacts on workers, affected communities, and the environment; • ensure that affected communities are engaged on issues that could potentially affect them; and • promote improved social and environmental performance of companies through the effective use of management systems. IFC Performance Standard 1 goes on to explain an ESMS has the features listed below. • it is a dynamic, continuous process initiated by management and involving communication between the Project owner, its workers, and the local communities directly affected by the Project; • it is based on the business management process of “plan-do-check-act” (this is the same basic process used in ISO14001); • it entails the thorough assessment of potential environmental and social impacts and risks from the early stages of Project development; and • it provides order and consistency for mitigating and managing these on an ongoing basis throughout the life of the Project. The basic elements of the ESMS for the Project are outlined in Table 11-1 with more detail on each element, and how it applies, given in the following sub-sections. The elements of the ESMS are discussed under the headings of the “plan-do-check-act” business performance improvement cycle. Stakeholder engagement is an element of the ESMS that applies to all steps of the “plan-do-check-act” cycle as shown in Table 11-1. An important component of the ESMS is the Environmental and Social Management Programme (ESMP). As with the ESMS, the ESMP may be known by different names, but in this instance is considered synonymous with the term “Environmental Management Programme” (EMP) used in certain jurisdictions, including Sierra Leone and which has therefore been used in this report. The EMP presents MIOL’s commitments to manage the impacts identified by the impact assessment process (Section 3.3.3). The EMP falls under the element of the ESMS entitled “objectives, targets and plans for management”. U3823_Marampa_ESIS_Final.docx September 2012 Page 219 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 11-1: Elements of the ESMS Steps of Elements of the ESMS for the Project the “plan- Elements applying do-check- Elements Primary function to all steps of the act” cycle cycle • Produce and communicate a statement of Leadership and corporate commitment to environmental and ans accountability social management (e.g. policy statement) pl • Establish, document, implement, maintain and e improve the Project ESMS ns po Legal and other • Identify and provide access to legal s requirements e Plan requirements and other obligations r of (Section Aspect • Identify aspects (“mechanisms” by which Project 11.1) identification activities impact on the environment) and ent and impact assess associated impacts throughout the t m ec op assessment Project life (the ESIA falls under this element of l oj e the ESMS) r ev P d Objectives, • Define objectives, targets, criteria and actions he , t s targets and for the management of potential impacts (the e i plans EMP falls under this element of the ESMS) d by enc e g • Provide sufficient management sponsorship of t c 6) er e Roles and human and financial resources f 9. m f . t a n e responsibility • Establish roles and responsibilities for c o al . e i j es es implementation i t ct c ro i e ent Contractors, • Consider environmental and social impact 5) P un S m our suppliers and 9. he m s management and performance in the selection t y ( on e n r r vendors om i and management of third party services o v y i e ofc ver en er f h v Competence, • Make personnel aware of their responsibilities i t ectl i eco al o Do training and and enable them to be capable and competent S r i ec ( he p w awareness in meeting their responsibilities t t d ent r (Section ut hi t 11.2) • Maintain internal and external communications men s poand Communication on to enable effective environmental management e gho i se anofe at n ag ou l o ns • Implement operational controls and maintain g e on Operational hr i po t e r esp at s equipment to uphold environmental en, v c e controls and s i r i t , f maintenance performance and compliance and to manage er es c g i r d c u nt of impacts and risks l r n o o t i de s n i on Documentation • Control and maintain documents and records pr on n i a at l he c and record associated with environmental and social akehng c t o t oi l keeping management S n a y p l ai c ugh Assessing, t en o • Monitor environmental and social management n ongn g hr and a correcting and A ai t and performance and take measures to m s improving continually improve performance mer s performance nd E d a edne Check Non- • Promptly report non-conformances and l (Section conformance incidents are promptly reported and take bui epar 11.3) and incident corrective and preventative actions to reduce o pr t s e reporting the likelihood of recurrence e s v EMP and ESMS • Report on compliance with the EMP and ESMS er pon performance to senior management, regulatory S s reporting e r authorities and affected communities y • Require site, regional and senior management nc Governance/ to review the suitability, adequacy and ge management effectiveness of the ESMS and identify er Act review improvement actions to facilitate continuous em (Section improvement n ai 11.4) t • Modify the ESMS in response to changes in the n Management of Project and to changes in the organisation, ai change personnel, operations and processes M The arrows show where there is integral relationship between stakeholder engagement and other elements of the ESMS. U3823_Marampa_ESIS_Final.docx September 2012 Page 220 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 11.1 Planning elements 11.1.1 Leadership and accountability Policy The Project will be undertaken in accordance with MIOL’s corporate policies, which are attached as Appendix H. This will include as a minimum the following policies: Environment Policy, Health and Safety Policy, Human Resources Policy and Community Policy. MIOL will periodically review the scope and effectiveness of its policies (Section 11.4.1). The policies will be documented, maintained, implemented and communicated to MIOL employees, contractors, suppliers and the public. As a subsidiary of Cape Lambert Resources Limited, MIOL is committed to operating in accordance with the policies of its parent company, which operates according to stated principles of Environment, Health and Safety (EHS) and Corporate Social Responsibility (CSR). ESMS MIOL will establish, document, implement, maintain and continually improve an ESMS for the Project. The ESMS will be in place prior to construction. 11.1.2 Legal requirements and other obligations The Project’s ESMS takes account of both legal and other obligations imposed on the Project. The various types of obligations considered are shown conceptually in Figure 11.1. Figure 11.1: Types of obligations relevant to the ESMS U3823_Marampa_ESIS_Final.docx September 2012 Page 221 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report MIOL will identify, document and maintain a register of legal requirements and other obligations applicable to the Project. It will also: • track developing legislation and regulations that may apply to operations and activities to anticipate and prepare for compliance; • inform employees and others working on behalf of the company of existing and emerging obligations that apply to their job responsibilities; and • consider the register in the setting and review of objectives, targets and plans for management of impacts. 11.1.3 Aspect identification and impact assessment throughout the Project life A key element of the ESMS is identification of aspects and assessment impacts. The impact assessment documented in this report is the initial stage of this element of the ESMS. Procedures will be set up, implemented and maintained for the ongoing identification of any new environmental (or social) aspects. These will be evaluated using impact and risk assessments on an ongoing basis through the Project life, probably in the form of regular workshops attended by the environment and community teams, as well as the various engineering and operating teams. The reviews will address: • significant aspects not covered by this ESIA; • any impact arising that was not predicted by the ESIA or did not develop as predicted by the ESIA; • any changes in the Project or new developments arising subsequent to the completion of this ESIA (Section 11.4.1). 11.1.4 Objectives, targets and plans for management throughout the life of the Project This element of the ESMS pertains to the setting of objectives and targets for environmental and social management, and plans for the achievement of these objectives and targets at corporate and Project/ site levels. The EMP20 described below embodies this element of the ESMS at the Project level. The primary purpose of the EMP is to guide environmental and social management throughout the life of the Project. The core of the EMP is a statement of environmental and social management objectives and associated management measures. The EMP will be supported by other documentation, such as the original Project design (described in Section 4) and specific management plans and operating procedures. The preliminary EMP commitments presented in tabular formal in Appendix F are derived from the following sources within the ESIS: • inherent design or management measures described in the Project Description in Chapter 4; • mitigation and enhancement measures identified in Chapters 7, 8 and 9, which are required to manage identified impacts; and • good practice management measures presented in Chapters 7, 8 and 9, which may not significantly alter the impact rating but are considered standard industry practice for the management of such impacts and have been voluntarily adopted by MIOL. 20 For the purposes of this report EMP includes measures related to social management and could equally be known as the environmental and social management plan or ESMP. U3823_Marampa_ESIS_Final.docx September 2012 Page 222 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report During the Project life, the EMP may need to be amended to address a specific requirement, such as those included in the obligations register (Section 11.1.2). Therefore, in subsequent updates of the EMP, a column entitled ‘Source’ may be needed to indicate additional sources of commitments, for example conditions of approval included in permits, or commitments made to stakeholders. Management plans and other forms of supporting documentation will be developed by MIOL or its contractors, where needed, to provide further detail on how key actions identified in the EMP will be executed. The need for supporting management plans or other supporting documents has been determined initially during the ESIA, based on the risk posed by or complexity of the impact/s or area requiring management. Consideration is also given to the regulatory requirements of Sierra Leone. Recognising the EMP could become legally binding, by means of the conditions of approval attached to authorisations (licences/ permits), it is considered desirable that the supporting documentation is separated from the EMP. This allows for flexibility in meeting the objectives and commitments in the EMP; the EMP supporting documents can be dynamic documents, adaptable to changing circumstances, and can be modified (without necessarily requiring regulatory approval of each modification) providing the changes are in compliance with the stated objectives in the EMP. Supporting documents identified as a result of the ESIA or Sierra Leone regulations include the following plans: • Environmental Management Programme and Social Management Programme (Appendix F); • Stakeholder Engagement Plan (Appendix C); and • Resettlement Framework (Appendix D). • Additional plans to be prepared during Stage 1 detailed design for construction include (note these may be individual or combined plans): - construction management plan (addressing land clearance, water/waste management, air quality, noise, vibrations and other environmental impacts associated with construction); - community development plan; - recruitment plan - training and skills development plan; - grievance management plan; - occupational health and safety plan; - security management plan; - closure and rehabilitation plan. • Additional plans to be prepared and/or reviewed during the construction phase ready for operation include (note these may be individual or combined plans): - community health and safety plan; - water management plan; - waste management plan; U3823_Marampa_ESIS_Final.docx September 2012 Page 223 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report - soil management plan; - air quality management plan; - wildlife and habitat management plan - emergency preparedness and response plan; - spill prevention control and countermeasure plan; - hazardous materials management plan; and - closure and rehabilitation plan. The supporting documentation may need to be presented differently, depending on the target audience and Project requirements, for example: • an issues-driven format is often required to facilitate communication with regulatory authorities and stakeholders (for example community development plan); and • an area/activity-driven format is needed for ease of application by the parties responsible for Project execution (for example construction management plan, waste rock dump management plan, spill prevention plans etc.). 11.2 Implementation (Do) elements Effective implementation and functioning of the EMP depends on adequate human and financial resources, clearly defined responsibilities for environmental and social management, appropriate training and good communication. An outline of how these features will be managed for the Project is presented below. 11.2.1 Roles and responsibility MIOL will define, document and communicate the environmental and social management roles and responsibilities of Project personnel, including contractors and others working on behalf of the company, in all phases of Project implementation from detailed design through to closure. Personnel with specific roles and responsibilities will have the authority, and be held accountable for, carrying out these. The basic roles required to implement the EMP, and establish and maintain the ESMS, are shown in Table 11-2. These roles need to be reviewed and incorporated into the organisational structures for the various phases of the Project from detailed design through to closure. A key requirement is for the senior environmental management professional to report directly to the on-site senior manager (the General Manager). 11.2.2 Contractors, suppliers and vendors Environmental and social performance, programmes and risk management will be considered in the selection and management of contractors, suppliers and vendors. Contracts will address potential environmental and social liabilities and responsibilities including the following: • use of competent, trained staff, including subcontractors; • consequences for failing to meet obligations; • monitoring of performance; • required job-specific, site-specific training; • compliance with MIOL policies and site standards and applicable legal requirements; U3823_Marampa_ESIS_Final.docx September 2012 Page 224 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report • responsibility for chemicals and hazardous materials brought on-site and wastes generated on-site, including closure activities where appropriate; and • identification of a lead responsible person for both MIOL and the contractor. Contractors, including their employees and associated subcontractors, will be made aware of the environmental risks, associated controls, procedures and standards relevant to their work on-site (Section 11.2.3), probably through the imposing of contracting clauses. The activities and performance of contractors will be monitored by MIOL against the terms of the contracts. Table 11-2: Key Roles for Environmental and Social Management Roles Relevant Responsibilities Chief executive • Endorse the environmental and social management policy and require it to be officer (CEO) communicated to the public. • Allocate adequate human and financial resources to enable effective functioning and continual improvement of the ESMS. • Establish and maintain a governance system. Top management Policy • Develop, review and update MIOL’s policy/s on environmental and social management. • Incorporate principles of MIOL’s policy/s in business decisions. Compliance • Confirm necessary authorisations (licences/ permits) have been obtained for the Project. • Confirm compliance with legal requirements and other obligations pertaining to environmental and social management. • Commit contractors and suppliers to meeting relevant environmental and social obligations by means of specific conditions in the contracts of appointment. Roles and responsibility • Define, document and communicate environmental and social management roles, responsibilities and authorities. • Provide sufficient appropriately trained human resources and adequate financial resources to enable effective functioning and continual improvement of the ESMS. • Hold personnel responsible for meeting their assigned responsibilities. Communication and reporting • Confirm there is adequate ongoing stakeholder engagement. • Confirm obligations for reporting to regulatory authorities, development financiers and affected communities are met. Management review • Provide leadership in the pursuit of environmental and social management. • Examine and review the ESMS periodically to determine its suitability, adequacy and effectiveness. • Support action to enhance the ESMS and make improvements in environmental and social management performance. U3823_Marampa_ESIS_Final.docx September 2012 Page 225 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Roles Relevant Responsibilities Environmental ESMS management team • Establish the ESMS, with assistance from the senior management, division managers and community relations managers. • Liaise with division managers regarding environmental management roles, responsibilities and authorities throughout operational divisions. • Coordinate monitoring and evaluation activities and confirm corrective actions (an action taken to address a non-conformance) are taken to address incidents and non-conformances (a failure to comply with the Project’s ESMS). • Report progress in implementation and functioning of the ESMS to senior management, development financiers, regulatory authorities and stakeholders. EMP and obligations register • Keep the EMP and obligations register up to date and confirm they address all relevant environmental and social obligations. • Present the EMP in an appropriate format for communication with regulatory authorities and other stakeholders. • Present the EMP in an appropriate format for communication with parties responsible for Project execution. • Compile EMP compliance reports. • “Sign-off” actions in the EMP and non-conformances once they have been completed. Government and • Assist the Environmental Management team with ongoing reporting to stakeholders community relations on EMP and supporting management plans, and progress with implementation of team management measures. • Assist Environmental Manager and division managers with stakeholder communication where awareness and/ or co-operation of stakeholders are required to implement management measures • Manage the grievance mechanism Operations • Confirm the ESMS and EMP are established, communicated, implemented and management team maintained in their respective areas • Provide leadership in the pursuit of environmental and social management • Identify ways to improve environmental and social performance through daily monitoring of their activities and evaluating implementation • Review monitoring results, incidents and corrective actions taken • Evaluate adequacy and effectiveness of awareness and skills training programmes pertinent to environmental and social management • Maintain internal communication of environmental and social matters between the Environmental Manager, Community Relations Manager and other personnel, and promote environmental and social awareness. All personnel and • Comply with MIOL policies, site standards and applicable legal requirements. contractors • Work in accordance with the EMP and supporting documents. • Report problems or deviations from the ESMS or EMP to division managers and/or environmental managers, as instructed. 11.2.3 Training Personnel, including contractors’ personnel, working for or on behalf of the Project will receive training to maintain awareness of relevant environmental and social aspects, impacts and risks associated with the Project and corresponding controls. The training will also maintain awareness of the environmental benefits of improved personal performance and the potential consequences of departure from specified procedures. Visitors to Project sites will receive relevant environmental and social awareness training as part of site induction training. Personnel, including contractors’ personnel, will be made aware of the particular environmental and social management responsibilities that apply specifically to their jobs. Training needs analyses will be undertaken and personnel will be given adequate training to meet these responsibilities. The training programme should comprise the following elements: • identification of training needs for employees specific to their varying responsibilities; U3823_Marampa_ESIS_Final.docx September 2012 Page 226 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report • development of a training plan and schedule to address defined needs; • verification of training programs to confirm consistency with organisational requirements; • training of target employees and documentation of training received; • evaluation of training effectiveness; and • review and modification of training programmes, as required. Personnel with direct responsibility for implementation of the EMP and functioning of the ESMS should receive additional training to: • provide them with the knowledge and skills necessary to perform their work; • maintain their knowledge of relevant environmental and social obligations; and • enable them to implement specific measures required under the EMP in a competent and efficient manner. Training requirements and completed training will be documented. Procedures to evaluate the effectiveness of such training will be implemented. 11.2.4 Communication To effectively implement environmental and social management, the relevant managers will maintain lines of internal communication and provide information regarding the EMP, ESMS and environmental and social management performance, incidents, good practices, lessons learned and concerns to personnel electronically, on notice boards and/or in newsletters. Such communication will be used to inform the personnel of their individual responsibilities with respect to the ESMS and to raise awareness on specific matters. External stakeholder engagement is discussed in Section 11.4. A grievance mechanism will be established (Section 11.4) and will provide a means for Project personnel, including contractors’ personnel, to anonymously raise environmental and social concerns (this grievance mechanism will be separate from the system dealing with employee grievances that need to be handled by the human resources department). 11.2.5 Operational controls Operational controls will be implemented to maintain performance and compliance, and to manage impacts and risks. Operational controls may include: • administrative controls such as performance standards; • standard operating procedures and work instructions; and • engineered controls such as pollution control equipment. Written operational controls are required where their absence could lead to deviation from environmental obligations or objectives and targets. Written operational controls will be part of the EMP supporting documentation (Section 11.1.4). The adequacy, suitability, and effectiveness of operational controls will be reviewed regularly. Documentation on the design basis and operating criteria/limits for equipment having the potential to impact environmental performance will be maintained. Operating equipment, as well as environmental monitoring and measurement devices, will be maintained consistent with manufacturers’ specifications and good management practice to reduce the potential for environmental incidents and adverse environmental impacts. U3823_Marampa_ESIS_Final.docx September 2012 Page 227 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 11.2.6 Documentation and record keeping Elements of the ESMS will be documented and controlled in accordance with a document control system. Records demonstrating compliance with legal requirements and conformance with the ESMS will also be maintained. MIOL will establish, implement and maintain procedures for: • ESMS document control detailing how the creation, review and updating of various types of documents will be managed and who will be responsible; and • record identification, storage, protection, retrieval, retention and disposal. Documentation and record keeping controls will include: • measures to enable relevant documents (including those of external origin deemed necessary for planning and operation of the ESMS) and records to be readily available and identifiable (labelled, dated and properly filed), legible and protected from damage; • periodic review, revision and approval of documents for adequacy by authorised personnel; • making current versions of relevant documents available at locations where operations essential to the effective functioning of the ESMS are performed; • suitably identifying obsolete documents retained for legal and knowledge preservation purposes; and • identification and segregation of confidential and privileged information. 11.3 Monitoring and reporting (Check) elements To confirm effective implementation of the ESMS and conformance with the EMP, monitoring of performance is required. Checks include monitoring, site inspections and formal audits. Linked to this, measures need to be taken to remedy non-conformances and to continually improve environmental performance. These activities fall under the heading “assessing, correcting and improving performance” (11.3.1). Incident reporting (Section 11.3.2) and reporting on the effectiveness of the ESMS and compliance with the EMP (Section 11.3.3) are also classified as “check” elements of the ESMS. 11.3.1 Assessing, correcting and improving performance Monitoring programmes The aim of monitoring programmes is to: • provide measurements of environmental and social impacts of the Project; • ascertain and demonstrate compliance with conditions of approval and other legislation; • provide sufficient evidence to address any claims made against the Project in respect of environmental and social matters; • track performance of the ESMS and progress in the implementation of the EMP; • track and measure key indicators and other performance measures over time to improve the Project’s performance and reduce the likelihood of environmental incidents; and • inform decision processes for determining management actions. The monitoring programmes cover the physical, biological and social components of the operation and are integrally linked with the assessment criteria stated in the EMP. Preliminary monitoring programmes have been prepared and are included in Appendix G. Where appropriate and possible, the sampling parameters and locations used in the ESIA U3823_Marampa_ESIS_Final.docx September 2012 Page 228 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report baseline studies have been retained to provide data continuity. The monitoring programme identifies monitoring parameters, sampling locations, sampling frequency and duration and detection limits (where appropriate). It includes control sites, where relevant. The focus and extent of monitoring is commensurate with the risk of impacts occurring, the sensitivity of the surrounding areas and the affected communities’ perceptions of risks to their health and environment. For some types of monitoring, thresholds or targets are available (and included in the environmental or social management programmes described above). In other cases, the monitoring results will be compared to the baseline data set gathered as part of this ESIA. Lastly, where neither thresholds nor baseline data are available, the initial data collection may form the baseline for future data collection. Data will be documented and interpreted. Temporal and spatial trends in the data will be discerned and compliance with relevant thresholds will be evaluated. Monitoring reports will be produced to meet internal and external reporting requirements (Section 11.3.2). If monitoring results indicate non-conformance with stipulated thresholds or if a significant deteriorating trend is observed, it will be recorded as a non-conformance and handled by the non-conformance and incident procedure (Section 11.3.2). The preliminary monitoring programmes in Appendix G provide a framework of monitoring to evaluate performance and assist in predicting and managing impacts. In conjunction with the development of supporting documentation for the EMP (Section 11.1.4), detailed monitoring plans, with appropriate sampling protocols where relevant, may need to be developed. These more detailed supporting documents would include the criteria against which the monitoring results will be compared and the actions required if the criteria or thresholds are exceeded. The supporting documents may also cover: • sample or data collection methods; • sample handling, storage and preservation; • sample or data documentation; • quality control; • data reliability (calibration of instruments, test equipment, and software and hardware sampling); • data storage and backup, and data protection; • interpretation and reporting of results; and • verification of monitoring information by qualified and experienced external experts. The frequencies and locations of monitoring may need to be adjusted depending on final Project design and ongoing review of results obtained by the monitoring programmes. Therefore the programmes will be reviewed on a regular basis (at least annually) and adjusted, where necessary (Section 11.4.1). Changes to the EMP or obligations register may also result in changes to the monitoring programme. Site inspections Site inspections will be undertaken regularly in relevant areas of the Project. The inspections will focus on compliance with the EMP and conformance with the ESMS. The inspections will play an important role in increasing awareness of EMP and ESMS requirements. Minor non-conformances will be discussed during the inspection and recorded as a finding in the inspection report. Serious non-conformances will be reported as incidents (Section 11.3.2). Inspection results will be disclosed at management meetings. U3823_Marampa_ESIS_Final.docx September 2012 Page 229 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Formal audits Formal audits of both the EMP and the functioning of the ESMS will be undertaken at planned intervals in accordance with the requirements of MIOL and regulatory authorities. Procedures for audits will be established, implemented and maintained. These will cover the audit criteria, scope, frequency and methods, and will address the responsibilities and requirements for planning and conducting audits, reporting results and retaining associated records. Audits will include both internal and external audits, as well as regulatory audits required by SLEPA. Internal audits will be undertaken frequently and may include review of contractors, evaluation of implementation of a specific supporting document or evaluation of one area of site against the relevant EMP conditions. External audits occur less frequently (for example every one or two years) and are likely to focus on the EMP, though more detailed audits could be commissioned if considered necessary. Negative findings arising from an audit will be dealt with in accordance with the non- conformance and incident procedure (11.3.2). Results from audits and evaluations of compliance with legal requirements will be reported to site and senior management and subject to management reviews (Section 11.4.1). 11.3.2 Non-conformances and incident reporting Non-conformances include the following: • exceedances of relevant thresholds as identified during routine monitoring; • non-conformances with the requirements of the EMP or supporting documentation identified during an internal inspection; • non-conformances identified during an audit or by regulatory authorities, including legal non-conformances; • events, such as spills, resulting in environmental harm; • events that did or could result in risks to community health and safety; and • significant complaints or grievances received from any source. A process will be established for the identification, investigation and tracking of non- conformances, including: • prioritising and classifying non-conformances based on the type and severity of the non- conformance; • recording of non-conformances and the results of corrective and/or preventive actions, including the actions necessary to mitigate or remedy any associated impacts; • defining results expected from the corrective and/or preventative actions; • confirming the corrective and/or preventive actions taken to eliminate the causes of the non-conformance are appropriate to the magnitude of problem and commensurate with the impacts encountered; • reviewing the effectiveness of the corrective and/or preventive actions taken; and • implementing and recording required changes in the EMP or monitoring programme resulting from corrective and preventive action. Serious non-conformances will be classified as incidents. Incidents will be promptly reported to appropriate management. MIOL will prepare a guideline on: • the types of incidents reportable to internal management at the site, Project and corporate levels, as well as to regulatory authorities and other external stakeholders; and U3823_Marampa_ESIS_Final.docx September 2012 Page 230 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report • standards to be observed when reporting incidents. The investigation of incidents and evaluation of effectiveness of existing controls and response actions will be undertaken at a level commensurate with the severity of the incident. 11.3.3 EMP and ESMS Reporting Progress on compliance with the EMP will be reported to: • Project site and MIOL senior management; • regulatory authorities, as required; and • affected communities and other stakeholders who have an interest in the Project (Section 11.5). In addition, the formal audit reports on compliance with the EMP and the functioning of the ESMS will be made available to site and corporate management. 11.4 Act elements 11.4.1 Governance/ Management review Project site management and MIOL senior management will review the EMP and ESMS on a periodic basis to determine its suitability, adequacy and effectiveness. Each management review will initiate a new plan-do-check-act cycle with enhancement of the ESMS and continuous improvements in environmental and social management performance. The management review will cover: • progress and closure of actions from previous management reviews; • monitoring programmes findings/ the extent to which objectives and targets have been met; • findings of audits (Section 11.3.1); • incidents and the status of corrective and/or preventative actions (Section 11.3.2); • impact and risks assessments (Sections 11.1.3 and 11.4.2); • changing circumstances, including changes to operations, Sierra Leone legislation or guidelines, ownership, socio-political circumstances (Section 11.1.2); • legal compliance and compliance with other obligations (Section 11.1.2); • stakeholder concerns, requests or complaints (Section 11.5); • adequacy of policies, EMP, monitoring plans, support documents and overall functioning of the ESMS to meet operational and corporate requirements; and • recommendations for improvement. 11.4.2 Management of change Changes to the Project can be expected throughout the life of the Project. These can range from changes to operations and infrastructure, new developments (such as an expansion), changes to personnel and the Company, changes in legislation and changes to the environment of the Project (such as a new settlement established near Project infrastructure). These changes could result in changes to the significance of environmental and social impacts and risks, or identification of new aspects or impacts (Section 11.1.3). This may necessitate updates to existing authorisations/ permits, changes to the EMP (which may have to be approved by regulatory authorities), changes to supporting documentation including monitoring programmes and general changes to the ESMS framework. U3823_Marampa_ESIS_Final.docx September 2012 Page 231 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report A procedure for the management of change will be established and maintained by MIOL. This will: • observe the corporate owners’ requirements for the management of change; • identify proposed changes that could alter environmental or social impacts and risks and/ or require new authorisations/ permits or changes to existing authorisations/ permits; and • define the impact and risk assessments appropriate to different types of changes, which need to be undertaken by competent personnel. Changes will not be made without the required authorisations/ permits in place. The measures identified as necessary to mitigate impacts and risks will be implemented. The various elements of the ESMS will be modified as required in response to the change, A procedure specifically for changes to the policy/s, EMP, monitoring programmes and supporting documentation will be established. This will detail: • how the changes are to be recorded; • who has responsibility for overseeing changes and checking they do not conflict with any planning conditions or other obligations; • the process of review and sign off in response to changes; and • how changes to the EMP should be communicated internally and externally. 11.5 Stakeholder engagement Stakeholder engagement provides stakeholders with opportunities to express their views on Project risks, impacts and impact mitigation measures and involves appropriate consideration of the views and responses by Project management (IFC 2012). Table 11-1 shows stakeholder engagement applies to each of the steps of ESMS “plan-do-check-act” cycle and is an integral part of several ESMS elements. The relationship between stakeholder engagement and these elements is explained further in Table 11-3. MIOL will establish a programme of stakeholder engagement for the Project that builds on the consultation undertaken for the ESIA. This will continue throughout the life of the Project. When the Project enters the construction phase, and throughout the remaining life of the Project, stakeholder engagement will include: • reporting on the implementation of the EMP and relevant supporting management plans; • opportunities for stakeholders to respond to the information received; and • constructive dialogue on environmental and social issues and performance. The stakeholder engagement process will be documented, including: • maintenance of a stakeholder database with stakeholder details; • records of information disclosed to stakeholders; • records of stakeholder engagements; and • records of inputs from stakeholders and responses to these. U3823_Marampa_ESIS_Final.docx September 2012 Page 232 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 11-3: Relationship between stakeholder engagement and the ESMS elements Steps of ESMS elements that stakeholder engagement is integral to the “plan- do-check- ESMS elements Role of stakeholder engagement act” cycle During the ESIA, the focus of stakeholder engagement has been the involvement of stakeholders in Project-planning and Project-approval decision- ESIA making processes. It facilitated identification of stakeholder’s concerns so they could be addressed in the Project design and/or EMP. It forms the basis for stakeholder engagement throughout the life of the Project. Plan Stakeholders will be involved in the review and approval of the preliminary EMP. Throughout the life of the Project, there should be ongoing reporting to EMP stakeholders on progress in the implementation of the EMP and supporting management plans that are of interest to them. The EMP and supporting management plans may need to be revised in response to stakeholders’ concerns. Communication with stakeholders will be required to implement some management actions. The communication will be required to raise awareness and/or co-operation of potentially affected communities and other stakeholders. Do Communication MIOL will determine effective communication methods for making affected communities aware of actions they may need to take to avoid exposure to operation-related hazards and how they can maximise on opportunities resulting from the operation. Participatory monitoring is desirable. This entails involvement of stakeholders, particularly affected communities, in monitoring and verifying information to Assessing, check that impact mitigation measures are appropriate. Grievances will be handled as incidents and managed through the incident correcting and improving procedure to enable the grievance to be received, documented, addressed and Check performance results fed back to the complainants. This procedure will protect the confidentiality of the persons raising the complaint, where necessary. The feedback will be easily accessible and understandable to members of the affected community and/or staff. Stakeholders affected by the Project will be informed of progress in the Reporting implementation of the management plans and of the effectiveness of management measures. 11.6 Emergency preparedness and response The Project will implement and maintain an Emergency Preparedness Response and Recovery Plan (EPR&R). The plan will be in place prior to construction. The purpose of the EPR&R is to provide a framework for a comprehensive system to: • establish a process to identify potential emergency situations prior to their occurrence; • take steps to prevent or minimize the impact of potential emergencies; • train personnel to appropriately identify, report and respond to emergencies; • provide and maintain emergency response resources and equipment to mitigate potential emergencies; • define detailed procedural steps to respond and manage various types of potential emergencies; • provide information to and consult with the surrounding community regarding environmental risks and response measures; • co-ordinate with external emergency response organizations; • test communications, emergency procedures and equipment on a periodic basis; • contain, where practicable, any emergencies and their effects within Project site boundaries; U3823_Marampa_ESIS_Final.docx September 2012 Page 233 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report • safely return to normal operations following an emergency; • identify the cause(s) of an emergency event and the corrective and preventative measure to avoid a reoccurrence; and • review and update plans and procedures based on lessons learned from tests and responses to actual emergencies. The EP&R will be prepared in accordance with: • IFC Performance Standards (PS) PS3 Resource Efficiency and Pollution Prevention and PS4 Community Health, Safety and Security, which require that a plan is in place to effectively respond to emergencies associated with Project hazards and that local communities are involved in the planning process (IFC, 2012); • WBG General EHS Guidelines, Volume 3 Community Health and Safety, Section 3.7 Emergency Preparedness and Response and the equivalent sections of the Sectoral EHS Guidelines relevant to the Project (WBG, 2007/8); • United Nations Environment Programme (UNEP) guidelines for Awareness and Preparedness for Emergencies at Local Level (APELL), including the guidelines for mining (UNEP, 2001), port areas (UNEP and the International Maritime Organisation, 1996) and dangerous goods transport (UNEP, 2000); and • the ICMM and UNEP guideline on good practice in emergency preparedness and response (2005). For the purposes of the EPR&R, the term “emergency” will refer to an unplanned event when a Project operation loses control, or could lose control, of a situation that may result in risks to human health, property or the environment. The EPR&R will not cover safe work practices for frequent upsets or events, which will be covered by occupational health and safety plans. The EPR&R will contain the following elements: • administration (relevant policy, purpose, distribution, definitions, scope, criteria for triggering the EP&R, date and frequency of updates); • organisation of emergency areas (for example command centres and medical stations); • roles and responsibilities; • communication systems (worker notification and communication, community notification, media contacts and media relations strategy); • emergency resources (finance and emergency funds, fire services and medical services, mutual aid agreements provide a clear basis for response by mutual aid providers, contact list); • emergency equipment (such as location of isolation valves, helicopters and equipment for fire fighting, toxicity testing, personal protection and pollution prevention equipment); • training and drills; • updating (to account for changes in equipment, personnel, and facilities); • checklists (role and action list and equipment checklist); • business continuity and contingency (including measures to allow business continuity following an emergency, back-ups of critical information in a secure location to expedite the return to normal operations following an emergency and alternative supplies of resources such as water); and • clean up (options and procedures for clean-up following accidents); • emergency scenarios and risks (identified scenarios, people and environments at risk, U3823_Marampa_ESIS_Final.docx September 2012 Page 234 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report maps of risk areas, locations of hazardous substances and properties of hazardous substances); • emergency response procedures for each emergency scenario (with specific information on specific procedure triggers, response actions, equipment, relevant notification procedures, relevant communication procedures, alarm systems, relevant evacuation procedures, relevant media procedures, medical procedures, assessment, monitoring and recording of the progress of the accident, procedures for operational shut down if necessary, relevant procedures for clean-up, recording of actions taken to respond and de-activation of the procedure); and • review (to identify missing or weak elements, consistency with any regional and national disasters plans and compliance with relevant legislation and codes). The emergency scenarios covered by the EPR&R will be determined by means of risk assessments. Procedures will be developed for at least the following events: • off-site chemical, oil or fuel spills; • on-site chemical, oil or fuel spills; • slope failure at the tailings storage facilities, waste rock facilities or mine workings; • concentrate pipeline failure; • emergencies arising from natural hazards such as earthquakes, sandstorms, extreme heat/cold, flash floods, monsoons, moving sand dunes, and extreme precipitation; • security incidents such as lost contact/ missing person, sabotage or a threat to kill/injure employees; • vehicle or equipment accidents; • medical emergencies; • fire; and • blasting and explosives accidents. The EPR&R will distinguish between two types of emergencies as follows: • Type 1 – emergencies contained within Project site boundaries requiring use of MIOL’s emergency resources, but not requiring external resources; • Type 2 – emergencies not contained within the Project site boundaries and/ or requiring involvement of external resources. Type 2 emergencies require application of relevant APELL guidelines. The primary goals of APELL are: • to raise awareness of local communities living close to industrial activities on how to react if an accident happens; and • to establish adequate coordination and communication in situations where the public might be affected by accidents and emergencies arising from natural hazards (such as floods). APELL is a multi-stakeholder dialogue working through a stepwise process comprising the 10 steps listed in the textbox below. U3823_Marampa_ESIS_Final.docx September 2012 Page 235 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report The APELL process • Step 1 – identify emergency response participants and establish their roles, resources and concerns; • Step 2 – evaluate risks and hazards that may result in emergency situations in the community and define options for risk reduction; • Step 3 – have participants review their own emergency plan, including communication for adequacy relative to a coordinated response; • Step 4 – identify the required response tasks not covered by existing plans; • Step 5 – match to resources available from the identified participants; • Step 6 – make changes necessary to improve existing emergency plans, integrate them into an overall community plan and gain agreement; • Step 7 – commit the integrated community plan to writing and obtain endorsement for it and relevant approvals; • Step 8 – communicate final version of integrated plan to participating groups and ensure that all emergency responders are trained; • Step 9 – establish procedures for periodic testing, review and updating of the plan; and • Step 10 – communicate the integrated plan to the general community. U3823_Marampa_ESIS_Final.docx September 2012 Page 236 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 12 CONCLUSIONS AND OVERALL ASSESSMENT This report documents the ESIA process undertaken on behalf of MIOL for the Marampa Iron Ore Project in the Marampa area of Sierra Leone. The ESIA has been prepared in accordance with the Environment Protection Agency Act No. 11 of 2008 (EPA Act 2008). The assessment of environmental and social impacts has been conducted in consideration of input received through a comprehensive stakeholder consultation process. The Project is being developed by MIOL, and involves four open pits for mining of iron ore (in two Stages of development), the associated mining waste storage areas, haul roads, beneficiation plant and accommodation areas. Infrastructure for export of product, over and above that which will be transported via rail to Pepel port is excluded from this ESIA. Export of product through Tagrin Point will require additional infrastructure, which will be handled under an amendment to this ESIA, once the details thereof are known. A Project of this scale has the potential to cause multiple impacts, both negative and positive. This report was prepared to inform decision-makers regarding the ‘triple bottom line’ (economic, environment and social) of the Project, by providing an objective and comprehensive analysis of the potential impacts and benefits. It has examined the Project design information and drawn on both available (secondary) and specifically collected (primary) baseline data (including local knowledge), as well as the discussions with stakeholders, to identify and evaluate environmental and socio-economic impacts of the proposed Project. This analysis has created a framework for the formulation of appropriate management measures. This ESIA report incorporates the following components: • an overview of the legal, regulatory and policy framework within which the Project has been developed and will operate (Chapter 2); • a description of the ESIA process undertaken, including the associated stakeholder consultation processes (Chapter 3 and Appendix C); • a description of the Project’s activities and the associated environmental control measures that are inherent in the design, along with an overview of the alternatives considered by the Project team (Chapter 4); • a description of the environmental and social setting of the Project (Chapters 5 and 6); • an analysis of the potential environmental and social impacts and risks arising as a result of the Project along with the management measures necessary to prevent, minimise or optimise the impacts, as necessary (Chapters 7, 8 and 9, and Appendix F); an analysis of the potential cumulative impacts resulting from the Project (Chapter 10) • a proposed environmental and social management system (ESMS) framework to enable the identified management measures to be successfully implemented and compliance evaluated (Chapter 11, and Appendix F). The scope and timing of the various baseline studies undertaken to provide data for the impact assessment were developed and adapted to address the shifting focus of the Project design with regard to spatial extent and production capacity. Due to the relatively early stage of Project development, the Project description is based on the findings of the technical scoping study, rather than more detailed pre-feasibility or feasibility studies. This required certain assumptions to be made, particularly for the studies involving predictive impact modelling. These assumptions (as well as any limitations) are clearly stated in the discussions regarding the impact ratings concerned, and may have resulted in overly conservative impact U3823_Marampa_ESIS_Final.docx September 2012 Page 237 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report ratings for these impacts. The lack of specific detail regarding certain aspects of the Project description (such as use of explosives) is therefore not considered to compromise the integrity of the ESIA, provided any changes to the Project description (such as the inclusion of facilities for product export during Stage 2) are assessed via an amendment to this ESIA. Although the ESIA is currently intended to meet in-country requirements only, it has been compiled with international standards in mind. Thus, wherever possible, data which may be required for an internationally compliant ESIA have been included (for example, additional seasonally dependent studies such as natural resource use and aquatic biodiversity). Additionally, wet season rounds of natural resource use and surface water hydrology studies are planned for Q3 of 2012. The final phase of the ESIA process is regulatory review. As part of this process, this document will be made available to interested stakeholders in accordance with the Stakeholder Engagement Plan (Appendix C). Feedback received during this process will be provided to the regulatory authorities. The ESMS presented in Chapter 11 is an adaptable tool, able to respond to changes and refinements in the Project description, as well as the social development plan. The robustness of the supporting management programmes, along with implementation, assurance and continual improvement functions, are fundamental to enabling the successful implementation of management measures by MIOL, its contractors and sub-contractors. By its nature, impact assessment can disaggregate the effects of a Project and, although it is necessary to examine the significance of individual impacts, an overly intensive focus on such impacts can detract from a more holistic assessment. As a result, the potential cumulative impacts of the Project in its developmental environmental context have been examined in Chapter 10. In association with Chapter 10, this concluding section aims to provide this more holistic view – a qualitative re-aggregation and synthesis of impacts, both negative and positive, which recognises the Project will result in some negative impacts, but that there will be significant social and economic benefits too. A summary of the potential impacts is given in the Table 12-1 below, including the consequence and probability, as well as the overall significance and confidence rating. The significance is colour coded, with red indicating negative impacts and green positive. Where consequential mitigation or enhancement measures are proposed, the residual impact ratings are also given. For those impacts of potentially higher significance, mitigation measures are defined and committed to in order to lower their significance to acceptable levels; this is shown in the residual impact column. With the implementation of the mitigation measures listed in the individual impact rating tables (and summarised in the EMP in Appendix F), the significance of all negative impacts assessed is predicted to decrease to medium or low. As committed to in the Project’s ESMS, these impacts will be reviewed periodically to determine if they are still relevant and if so whether the impact significance has changed. Most of the Project’s biophysical impacts are predicted to be of medium to low significance due to a combination of inherent design and natural mitigation. The most significant biophysical impacts are expected to relate to land transformation (affecting use of the land and access by local communities) and changes to surface water flow. Socioeconomic impacts of the Project are predicted to be wide ranging, and potentially significant, both positive and negative. U3823_Marampa_ESIS_Final.docx September 2012 Page 238 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report The Project’s combined economic benefits to local communities as well as Sierra Leone as a whole, including increased employment, economic growth, infrastructure development, and direct and indirect fiscal receipts, will be significant (particularly with the recommended enhancement measures). The economic growth expected to result from the Project may have the potential to negatively affect some communities, particularly more vulnerable groups, but, in the majority of cases, will benefit the host communities. Land acquisition and relocation of a number of villages (approximately 10) due to positioning of the Project infrastructure and impacts such as noise and dust emissions, will result in some negative impacts on local communities, particularly in terms of their livelihoods and access to natural resources, and, potentially, social order. Negative impacts on community health, safety and security, are predicted to be low to medium for communities other than those that will be relocated. However, the implementation of a resettlement action plan, agreed to by the affected stakeholders, has the potential to result in equal or potentially better situations for the affected people. The overall conclusion of this ESIA is that the negative potential impacts assessed can be reduced to acceptable levels with effective mitigation and management measures, which MIOL is strongly committed to implementing. In addition, the positive economic development impacts of the Project can be expected to be significant, not only at the local and regional level, but also at the national level. For the local communities, this will be manifested in areas such as employment and resultant wealth generation; training and skills development; potential for enhanced government investment towards social development in the Project areas as a result of tax and royalties derived from the mining operation; and the stimulation of local economic growth in general as a result of Project generated opportunities for local suppliers and contractors. Finally, MIOL is committed to supporting community development, continuing to undertake stakeholder consultation and information disclosure, and monitoring the effectiveness of its environmental and social management programmes throughout the Project life cycle to international standards of implementation. U3823_Marampa_ESIS_Final.docx September 2012 Page 239 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Table 12-1: Preliminary summary of environmental, socio-economic and health and safety impact ratings Significance rating Impact groups Identified impacts Initial impact Residual/ enhanced Confidence impact Biophysical Impacts Impact LT1: Change in land use as a result of mine and related infrastructure limiting use by local communities Refer to Impact RL1 Impact LT2: Disruption of community access routes by mine infrastructure, resulting in social disruption Refer to Impact RL2 Land Impact LT3: Mine infrastructure and activities resulting in visual intrusion and loss of ‘sense of place’ for local MEDIUM LOW Medium transformation communities Impact LT4: Loss of topsoil through erosion, decreasing land capability MEDIUM LOW High Impact LT5: Fugitive dust resulting in changes in soil chemistry and agricultural land capability MEDIUM LOW Medium Impact WR1: Pit dewatering potentially resulting in reduced groundwater availability to ecological systems and MEDIUM LOW Low local communities Impact WR2: Surface water abstraction affecting downstream users LOW No Residual Impact High Impact WR3: Project infrastructure causing altered flow conditions, affecting downstream users HIGH MEDIUM Medium Water Impact WR4: Surface water diversions potentially causing changes to flood risk to adjacent agricultural areas LOW No Residual Impact Medium resources and communities Impact WR5: Seepage from mining wastes potentially resulting in deteriorated water quality affecting LOW No Residual Impact Medium communities and ecological systems Impact WR6: Discharge or runoff to surface water potentially resulting in deteriorated water quality affecting MEDIUM LOW High communities and ecological systems Impact EB1: Site clearance and positioning of Project infrastructure potentially resulting in habitat loss and MEDIUM LOW Medium fragmentation, and direct loss of fauna and flora Ecology and Impact EB2: Soil disturbance facilitating the establishment and spread of invasive species, affecting indigenous MEDIUM LOW High biodiversity ecosystems Impact EB3: Project activities potentially resulting in sensory or other disturbance to wildlife LOW No Residual Impact High Impact EB4: Mine infrastructure and activities attracting nuisance species, resulting in impacts on indigenous LOW LOW Medium ecosystems U3823_Marampa_ESIS_Final.docx September 2012 Page 240 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Significance rating Impact groups Identified impacts Initial impact Residual/ enhanced Confidence impact Socio-economic Impacts Impact ED1: Employment generation by the Project resulting in increased standard of living for the local MEDIUM HIGH High community Economic Impact ED2: Employee training leading to skills development in the local community MEDIUM HIGH Medium development Impact ED3: Increase in government income (from taxes and royalty on mining) potentially leading to social LOW MEDIUM Low development in the Project area Impact ED4: Opportunities for local suppliers and contractors leading to economic growth LOW MEDIUM Medium Resettlement Impact RL1: Impoverishment through loss of shelter, land and communal natural resources HIGH MEDIUM High and loss of land Impact RL2: Changes to community as a result of the Project potentially affecting livelihoods, access to HIGH LOW Medium and social and communal social services and infrastructure and community cohesion natural Impact RL4: Added pressure on limited host community resources, potentially resulting in food insecurity and Impact not rated as it is dependent on the characteristics of resources malnutrition the host community, which has not yet been decided. Impact SO1: Influx of job seekers causing increased pressure on government services and infrastructure, MEDIUM LOW Medium potentially resulting in reduced standard of living Social order Impact SO2: Increase in social ills/problems MEDIUM LOW Medium Impact SO3: Real or perceived unequal distribution of Project benefits leading to social tension HIGH MEDIUM High Cultural Impact AC1: Disturbance to sacred bushes and cemeteries leading to loss of community’s access cultural HIGH LOW High heritage resources Decom- missioning and Impact DC1: Closure of mine leading to economic decline HIGH MEDIUM Medium closure Community health, safety and Security Impacts Air quality Impact AQ1: Dust emissions causing nuisance and health impacts on local communities MEDIUM LOW Medium Impact NV1: Blasting causing air overpressure and vibrations, resulting in disturbance of local communities LOW No Residual Impact Low Noise and Impact NV2: Operation of mining equipment and vehicles resulting in increase in background noise levels for vibrations local communities LOW No Residual Impact Medium Impact TS1: Increase in Project-related traffic on local and national roads causing increased wear and tear and MEDIUM LOW Medium Traffic safety risk of road accidents Impact TS2: Use of mine site roads by local communities causing increased safety risks due to road accidents MEDIUM LOW Medium U3823_Marampa_ESIS_Final.docx September 2012 Page 241 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report Significance rating Impact groups Identified impacts Initial impact Residual/ enhanced Confidence impact Impact SR1: Risk of human rights abuses due to conflict with communities HIGH LOW High Social risks Impact SR2: Increased exposure to communicable diseases due to an influx of workers, resulting in a MEDIUM LOW Medium deterioration in public health Other hazards potentially resulting in injury Impact OH1: Blasting resulting in fly rock potentially harming people or their belongings Because of the number of variables affecting the Impact OH2: Community exposure to toxic or hazardous substances consequence and probability of such events, accurate Hazards Impact OH3: Fire or explosions due to storage of explosives and use of combustible materials significance rating of possible impacts should the risk materialise is not possible. Each event must be evaluated on Impact OH4: Failure of the TSF resulting in pollution or harm to individuals an individual basis U3823_Marampa_ESIS_Final.docx September 2012 Page 242 of 298 SRK Consulting Marampa Iron Ore Project ESIS – Main Report 13 REFERENCES th Brady, N.N. and Weil, R.R. 2002. The Nature and Properties of Soil (13 edition), Prentice Hall, New Jersey Taylor, JC, Harding, WR and Archibald, CGM 2007b. An illustrated guide to some commondiatom species from South Africa. Water Research Commission Report TT282/07. Water Research Commission. Pretoria. Van Dam, H., Mertens A., and Sinkeldam, J. 1994. A coded checklist and ecological indicator values of freshwater diatoms from The Netherlands. Aquatic Ecology 28(1): 117-133. Payne, A. I, Wakeford, R. C. and Ndomahina, T. E. 2010. Fish distribution and zonation along a tropical African river, the Rokel/Seli River, Sierra Leone, West Africa. Smithiana Bulletin 12: 25–36. Bousso, T. and Lalèyè, P. 2006c. Marcusenius meronai. In: IUCN 2010. IUCN Red List of Threatened Species. Version 2010.4. . Downloaded on 03 May 2011. Bousso, T. and Lalèyè, P. 2006e. Tilapia joka. In: IUCN 2010. IUCN Red List of Threatened Species. Version 2010.4. . Downloaded on 01 May 2011 Brown, D. S 1994. Freshwater snails of Africa and their medical importance. Taylor & Francis. Revised second edition. London. x + 609 pp. Kristensen, T.K. and Stensgaard, A-S. 2006. Sierraia leonensis. In: IUCN 2010. IUCN Red List of Threatened Species. Version 2010.4. . Downloaded on 27 October 2010. Lalèyè, P. 2006. Scriptaphyosemion roloffi. In: IUCN 2010. IUCN Red List of Threatened Species. Version 2010.4. . Downloaded on 01 May 2011. Canadian Council of Ministers of the Environment (CCME), 2007. Available online at http://www.ccme.ca Statistics Sierra Leone, 2008. Available online at: www.statistics.sl EM-DAT, 2012. International Disaster Bureau. Available online at www.emdat.be PreventionWeb, 2012, Disaster reduction community website. Available online at www.preventionweb.net Okoni-Williams, A.D, Shokellu Thompson, H., Wood, P., Koroma, A.P. and Robertson, P. 2001. Sierra Leone. In: Fishpool, L.D.C. and Evans, M.I. (eds) Important Bird Areas in Africa and Associated Islands: Priority Sites for Conservation. Birdlife Conservation Series 11. BirdLife International. Nippon Koei UK. 2005. Bumbuna Hydroelectric Project Environmental Impact Assessment. January 2005. Nippon Koei UK International Consulting Engineers. Bateman, 2012. Revised Scoping Study Report M6037-2700-001, April 2012 NSADP, 2009. National Sustainable Agriculture Development Plan (2010 – 2030). Sierra Leone’s comprehensive African Agriculture Development Programme. 45pp rd Mason, B; 1966. Principles of Geochemistry. 3 Edition. John Wiley and Sons Inc. 329pp IFC (International Finance Corporation) (2007). Environmental Health and Safety Guidelines U3823_Marampa_ESIS_Final.docx September 2012 Page 243 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Main Report for Mining, World Bank Group. Available at: http://www.ifc.org International Union for the Conservation of Nature (IUCN) 2001. IUCN Red List Categories and Criteria: Version 3.1. U3823_Marampa_ESIS_Final.docx September 2012 Page 244 of 244 SRK Consulting Marampa Iron Ore Project ESIS – Glossary, Abbreviations, Units Glossary TERM EXPLANATION Aquifer An underground layer of water-bearing permeable rock, or unconsolidated materials (gravel, sand, silt, or clay) from which groundwater can be usefully extracted using a water well. Background or The level or concentration of the substance or compound being measured, baseline conditions prior to additional activity. Baseline data Data gathered during the Social and Environmental Assessment used to describe the relevant existing conditions of the project, such as physical, biological, socio-economic, and labour conditions, including any changes before the project commences. Bioaccumulation Means to accumulate in a biological system and is commonly taken to measure the uptake over time of a substance, called a bioaccumulant, that can accumulate in a biological system Biodiversity An integrating concept that includes the ecosystems within which the people of the world live, as well as the multitude of species that are used by humankind for food, fibre, medicines, clothing and shelter. Biodiversity is the variety of life in all its forms, including genetic, species and ecosystem diversity. Catchment The total area from which a river or waterway collects surface water runoff. Consultation Consultation involves two-way communication between the client and the affected communities. The consultation process should be undertaken in a manner that is inclusive and culturally appropriate and that provides the affected communities with opportunities to express their views on projects risks, impacts and mitigations measures, and allows the client to consider and respond to them. The consultation process will ensure free, prior and informed consultation. Cultural heritage A unique and non-renewable resource that possesses cultural, scientific, spiritual or religious value and includes moveable or immoveable objects, sites structures, groups of structures, natural features, or landscapes that have archaeological (prehistoric), paleontological, historical, cultural, artistic, and religious values, as well as unique natural environmental features that embody cultural values, such as sacred groves. Cumulative impacts Impacts associated with the proposed project in combination with the impacts of other past, existing and proposed developments in the area. Deposit An anomalous occurrence of a specific mineral or minerals within the earth’s crust Downstream The direction toward which groundwater is moving under natural conditions: from higher to lower piezometric heads Effluent Wastewater (treated or untreated) that flows out of a treatment plant, sewer, or industrial outfall; generally refers to wastes discharged into surface waters. Endangered species Species that are under threat of extinction. Environmental Are the consequences of project activities or aspects on environmental impacts resources or receptors of particular value or sensitivity. Fault A planar rock fracture which show evidence of relative movement Feasibility study A definitive engineering study addressing the economic viability of bringing a deposit to the production stage; taking into consideration all associated costs, revenues and risks Geomorphology The scientific study of landforms and the processes that shape them. Greenhouse gases The six greenhouse gases that form the Kyoto Protocol to the United Nations (GHGs) Framework Convention on Climate Change i.e. Carbon Dioxide (CO ), 2 Methane (CH ), Nitrous oxide (N 0), Hydro fluorocarbons (HFCs), 4 2 U3823_Marampa_ESIS_Final.docx September 2012 Page i of iv SRK Consulting Marampa Iron Ore Project ESIS – Glossary, Abbreviations, Units TERM EXPLANATION Perfluorocarbons (PFCs), Sulphur hexafluoride (SF6). Some greenhouse gases occur naturally in the atmosphere, while others result from human activities. Groundwater The part of the subsurface water that is the zone of saturation, including underground streams Groundwater table The level below the earth's surface at which the ground becomes saturated with water. The water table is set where hydrostatic pressure equals atmospheric pressure Hazardous waste Substances classified as hazardous wastes possess at least one of four characteristics- ignitability, corrosivity, reactivity, or toxicity - or appear on special lists. Information disclosure The process of providing information to the affected communities and other (also Public stakeholders that is timely, accessible, understandable, and in the Disclosure) appropriate language(s). For projects with potential adverse impacts, information on the purpose, nature and scale of the project, the duration of proposed project activities, and any potential risks to and potential impacts on such communities should be included. Infrastructure The supporting installations and services that supply the needs of the project. Land capability The ability of the land to support a particular land use. Classification is based on an assessment of the land's biophysical characteristics, the extent of which these will limit particular land uses, the current management technology available and soil erosion hazard. Leachate The liquid that can appear from beneath waste rock or ore/tailings deposits. Leachate can sometimes contain dissolved minerals, metals or chemicals leached out of ore, rock or soils. Local community Community within a project’s area of influence. Mitigation measures The measures attempting to prevent hazards from developing into disasters altogether, or to reduce the effects of disasters when they occur Open pit Mine excavation produced by quarrying or other surface earthmoving equipment. Ore Accumulation of minerals containing a substance which can be economically recovered. Ore body The column of rock contained the mineral resource Permeability Degree to which fluids can move through rock or soil. Pollution Refers to both hazardous and non-hazardous pollutants in the solid, liquid, or gaseous forms, and is intended to include other forms such as nuisance odours, noise, vibration, radiation, electromagnetic energy, and the creation of potential visual impacts including light. Pre-feasibility Study The initial stage of the feasibility study in which the accuracy of the factors involved such as costs and revenues is ± 25%. Receptors Comprise people or human-made systems, such as local residents, communities and social infrastructure. Resources Components of the biophysical, socio-cultural and economic environment that can be used for some purpose. Run-off That part of precipitation, snow melt, or irrigation water that drains or flows off the land into streams or other surface waters Seepage The escape of liquids downward through the soil Significance of impact The significance of the unmanaged and managed impacts taking into consideration the probability of the impact occurring, the extent over which the impact will be experienced, and the intensity/severity of the impact. Stakeholder A person or group that has an investment, share, or interest in something, as a business or industry. U3823_Marampa_ESIS_Final.docx September 2012 Page ii of iv SRK Consulting Marampa Iron Ore Project ESIS – Glossary, Abbreviations, Units TERM EXPLANATION Stakeholder Engagement is an on-going process involving disclosure of information, engagement consultation with affected communities, and the establishment of a grievance mechanism. Tailings Material rejected from treatment plant after the recoverable valuable minerals have been extracted. Waste rock Rock excavated from pit, no longer required and placed in a waste pile Working conditions Conditions in the workplace and treatment of workers. Conditions in the workplace include the physical environmental, health and safety precautions and access to sanitary facilities. Treatment of workers includes disciplinary practices, reasons and process for termination of workers and respect for the worker's personal dignity. Abbreviations AML African Minerals Limited ANFO Ammonium nitrate-fuel oil ANZECC Australian and New Zealand Environmental Conservation Council ARPS African Railways and Port Services Ltd ARDML Acid Rock Drainage Mineral Leaching Bateman Bateman Engineering Pty Ltd – authors of the Mining Scoping Study BID Background Information Document Cape Lambert Cape Lambert Resources Limited CBO Community Based Organisation DELCO Sierra Leone Development Company Ltd DoE Department of Environment EHS Environmental, Health and Safety EMP Environmental Management Programme EPA Environmental Protection Agency (also known as SLEPA) EPCM Engineering, Procurement and Construction Management EPR&R Emergency Preparedness, Response and Recovery Plan ESIA Environmental and Social Impact Assessment ESMS Environmental and Social Management System ESS Environmental Scoping Study FEL Frontend Loader GDP Gross Domestic Product GIIP Good International Industry Practice GoS Government of Sierra Leone HDPE High Density Polyethylene HEC-RAS Hydrologic Engineering Centre’s River Analysis System HFO Heavy Fuel Oil IFC International Finance Commission IFC PS International Finance Corporation Performance Standards on Social and Environmental Sustainability London Mining London Mining plc MCC Motor Control Centre MIOL Marampa Iron Ore Limited MLCPE Ministry of Lands, Country Planning and the Environment MMR Ministry of Mineral Resources U3823_Marampa_ESIS_Final.docx September 2012 Page iii of iv SRK Consulting Marampa Iron Ore Project ESIS – Glossary, Abbreviations, Units NACEF National Environmental and Forestry Commission NAF Non Acid Forming NAG Net Acid Generation NGO Non-government Organisation PAP Project Affected People QA/QC Quality Assurance / Quality Control ROM Run of Mine RWG Resettlement Working Group SD Supporting Document SEP Stakeholder Engagement Plan SLEPA Sierra Leone Environmental Protection Agency (also known as EPA) SRK SRK Consulting (UK) Ltd ToR Terms of Reference TSF Tailings Storage Facility UNEP United Nations Environment Programme WHIMS Wet High Intensity Magnetic Separation WHO World Health Organisation WRD Waste Rock Dump Units Mt Million metric tonnes Masl Metres above sea level Mtpa Million metric tonnes per anum Mbgl Metres below ground level Ha Hectares bcm Bank cubic metre kt Kilo tonne µm Micrometres kV Kilovolts MW Megawatt °C Degrees Celcius U3823_Marampa_ESIS_Final.docx September 2012 Page iv of iv SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix A APPENDIX A A SUMMARY OF APPLICABLE LEGISLATION AND INTERNATIONAL GUIDELINES U3823_Marampa_ESIS_Final.docx September 2012 Page A1 of A1 1 Appendix A Appendix A: Relevant Legislation and International Standards 1 INTRODUCTION 1 2 NATIONAL LAW 2 2.1 Introduction and overview 2 2.2 Legislative and regulatory framework for environmental management 3 2.2.1 National Environmental Policy 3 2.2.2 Government agencies responsible for the environment 4 2.2.3 The Environment Protection Agency Act (No. 11 of 2008) 5 2.2.4 EIA procedure specified in the EPA Act 2008 5 2.2.5 Guidelines on EIA procedures 6 2.3 Environmental management provisions in mining legislation 9 2.3.1 The Mines and Minerals Act 2009 Error! Bookmark not defined. 2.4 Legislation pertaining to disturbance of forests 13 2.4.1 Forestry Act, 1988 13 2.4.2 The Forestry Regulations, 1989 14 2.5 Water law 15 2.5.1 Current legislation 15 2.5.2 National Water and Sanitation Policy 15 2.5.3 Water permits needing to be obtained 17 2.6 Legislation pertaining to land tenure 17 2.7 The Factories Act – 1974 18 3 INTERNATIONAL LAW, STANDARDS AND CODES OF CONDUCT 19 3.1 International law 19 3.1.1 Declarations and customary law 21 3.1.2 Multilateral treaties 22 3.1.3 Regional treaties influencing international practice 26 3.2 Conditioning of project finance: Equator Principles and the IFC Performance Standards and World Bank EHS Guidelines 26 3.2.1 Introduction to the Equator Principles 26 3.2.2 Introduction to the IFC Performance Standards 27 3.3 Self regulation in the mining sector 32 3.3.1 United Nations Global Compact and the Global Reporting Initiative 32 3.3.2 International Council on Mining and Metals Sustainable Development Framework 32 3.3.3 Voluntary Principles on Security and Human Rights 33 3.3.4 The Extractive Industry Transparency Initiative 34 3.3.5 Mining and Metals Sector Good Practice website 34 4 REFERENCES 35 1 INTRODUCTION This appendix outlines legislation, standards and codes of practice influencing the approach to the ESIA for the Marampa Project and will continue to influence management practices throughout the life of the project. The focus is on legal instruments and guidelines applicable to biological, physical and social dimensions of the environment and sustainable development. Relevant legislation in Sierra Leone is outlined in Section 2. The influences and obligations arising from international law, standards and codes of practice are considered in Section 3. U3823 August 2012 2 Appendix A 2 NATIONAL LAW This section identifies legislation relevant to the environment (Section 2.1) and then focuses on the regulatory framework for environmental management in Sierra Leone, including relevant environmental impact assessment (EIA) legislation and guidelines (Section 2.2) and environmental provisions in mining legislation (Section 2.3). It also provides brief background on the status of legislation pertaining to use of forest resources, water resources, and land resources (Sections 2.4, 2.5 and2.6, respectively). 2.1 Introduction and overview Since Sierra Leone’s emergence from the civil war in 2002, much effort is being directed into the reform of law to improve governance and promote security, peace and development. All legislation pertinent to resources such as minerals, water and land is under review. The revisions are generally being made to promote good governance and address the lack of institutional capacity and monitoring mechanisms. The revisions are also geared to encourage foreign and local investment and development that will be socially and economically beneficial for the country. Furthermore, the revisions are being undertaken to meet the requirements of the many international treaties that Sierra Leone has signed in the last decade. A summary of current legislation pertinent to the environment and to sustainable development needing to be taken into account in the planning and implementation of the Marampa Project is listed in Table 2-1. Table 2-1: Sierra Leone legislation pertinent to the environment and sustainable development of the Marampa Project Primary Policy Legislation subject Environment National • The Environment Protection Agency Act, 2008 (No. 11 of and Environmental Policy 2008) sustainable (1994) development Mineral Core Mineral Policy of • National Reconstruction and Development Act, 1999 resources and the Government of (No. 5 of 1999) mining Sierra Leone (2008) • Mines and Minerals Act,1994 Water National Water and • The Water (Control and Supply) Act, 1963 Sanitation Policy • Sierra Leone Water Company Act, 2001 (No. 6 of 2001) (August 2008) Biodiversity National Biodiversity • Wildlife Conservation Act, 1972 (No. 27 of 1972) and biological Strategy and Action resources Plan (developed in Forestry accordance with the • Forestry Regulations, 1989 (P.N. No. 17 of 1990) requirements of the • Forestry Act, 1988 convention on U3823 August 2012 3 Appendix A Primary Policy Legislation subject Fishing and • Sierra Leone Fisheries (Management and Development) marine (Amendment) Act, 2007 (No. 10 of 2007) resources • Fisheries Regulations, 1995 • Fisheries (Management and Development) Decree, 1994 • Fisheries (Amendment) Regulations, 1994 (P. N. No. 4 of 1994) • Fisheries Management and Development (Amendment) Act, 1992 (No. 7 of 1992) • Fisheries Regulations, 1990 (Public Notice No. 15 of 1990) • Fisheries Management and Development (Amendment) Act, 1990 (Act No. 9 of 1990) • Fisheries Management and Development Act, 1988 (Act No. 4) • Fisheries (Operation of Foreign Motor Fishing Vessels) Regulations, 1985 (P.N. No. 1 of 1986) Land National Lands Policy • Devolution of Estates Act, 2007 (No. 21 of 2007) (2005) • Land Commission Act (not promulgated yet) • Commercial Lands Act (not promulgated yet) Radiation • Protection from Radiation Act, 2001 (No. 14 of 2001) Occupational • The Factories Act, 1974 (1974) environment Local • Local Government Act, 2004 (2004): An Act which government provides for decentralisation and devolution of functions, powers and services to local councils. 2.2 Legislative and regulatory framework for environmental management 2.2.1 National Environmental Policy A National Environmental Policy was developed for Sierra Leone in 1994. The goals, objectives and strategies of the policy are outlined in Table 2-2. Table 2-2: Outline of the National Environmental Policy Aspect Commitments Goal • To achieve sustainable development in Sierra Leone through sound environmental management. • To secure for all Sierra Leoneans a quality of environment adequate for their health and well being; • To conserve and use the environmental and natural resources for the benefit of present a future generations; • To restore, maintain and enhance the ecosystems and ecological processes Objectives essential for the functioning of the biosphere; to preserve biological diversity and the principle of optimum sustainable yield in the use of living natural resources and ecosystems; and • To raise public awareness and promote understanding of the essential linkages between environment development and to encourage individual and community participation in environmental improvement efforts. • To establish and/or strengthen environmental protection standards, monitor changes in, and publish relevant data on, environmental quality and resource use; • To promote prior EIA of proposed activities which may significantly affect the environment or use of a natural resource and to provide relevant information, in a timely manner, to persons likely to be significantly affected by a planned activity and Strategies to grant them equal access and due process in administrative and judicial proceedings; and • To promote environmental management through the creation of administrative and infrastructural support with appropriate financial backing; • To cooperate in good faith with other countries and agencies to achieve optimal use of transboundary natural resources and effective prevention or abatement of transboundary environmental protection. U3823 August 2012 4 Appendix A 2.2.2 Government agencies responsible for the environment The Environment Protection Agency Act (No. 11 of 2008), promulgated in September 2008, provides for the establishment of an Environment Protection Agency (EPA). The EPA will take over responsibility for environmental matters from other institutions that have held these responsibilities in the last decade. These institutions are: • the Department of Environment (DOE), within the Ministry of Lands, Country Planning and the Environment (MLCPE); • the National Environment Protection Board; and • the National Environmental and Forestry Commission (NACEF), which was established in 2005 by the President (President Ahmad Tejan Kabbah), and which was later referred to as the Environment Commission (according to the National Water and Sanitation Policy, published by the Ministry of Energy and Power, August 2008). The responsibilities of the DOE and National Environmental Protection Board were defined in the Environment Protection Act (No. 2 of 2000), which was repealed with the promulgation of the EPA Act 2008. It is understood NACEF/ the Environment Commission was a precursor to the EPA. The administrative staff and structures of the DOE were reported to function within the NACEF/ Environment Commission framework in 2008 (University of Sierra Leone, 2008). In terms of the new EPA Act 2008 (Sections 3 to 5 and 13), the governing body of the EPA is a Board of Directors, which comprises a chairman and senior representatives of several ministries with an interest in environmental matters, three people knowledgeable in commence, finance and law, and the Executive Director of the EPA. The Board has control and supervision of the EPA and is responsible for ensuring efficient implementation of the functions of the EPA. The EPA is not subject to the direction or control of any person or authority other than the EPA Board. 1 The Act names the ministries to be represented on the EPA Board as follows: Ministry of the Environment; Ministry of Local Government; Ministry of Mineral Resources; Ministry of Marine Resources; Ministry of Agriculture and Forestry; Ministry of Tourism; Ministry of Trade and Industry; Ministry of Transport; Ministry of Health; and Petroleum Unit. The EPA is required to advise “the Minister” on the formulation of policies on all aspects of the environment, co-ordinate the activities of bodies concerned with the environment and serve as a channel of communication between such bodies and the Minister. The Act defines “the Minister” as “the Minister charged with responsibility for the environment”. It also states “the Ministry shall be construed accordingly”. Additional functions of the EPA are to: • ensure compliance EIA procedures; • issue environmental permits, pollution abatement notices, directives, procedures and warnings; • prescribe environmental standards and guidelines; 1 The titles of the named Ministries are not the same as the official names of the equivalent ministries. For example, at present there is no “Ministry of Environment” and no “Ministry of Agriculture and Forestry”. In addition, there is no reference to a water authority. U3823 August 2012 5 Appendix A • co-ordinate the activities of such bodies as it considers appropriate for the purposes of controlling waste handling and disposal; • collaborate and coordinate with such foreign and international bodies; • coordinate with Government Ministries, local councils and other agencies on matters relating to environmental protection and management; • promote studies, research for protection of the environment; • develop a comprehensive database on the environment; and • promote public awareness of the environment and its importance. 2.2.3 The Environment Protection Agency Act (No. 11 of 2008) The EPA Act 2008 forms the legal basis for environmental management and protection in Sierra Leone. The Act states the term “environment” applies to the biophysical and social 2 components of the environment . As outlined in the above section, the EPA Act provides for the establishment of an EPA, which has a wide range of environmental management functions including coordination of the activities of government agencies and other agencies on matters relating to environmental protection and management. The Act also requires that licences are obtained for projects with potential to have significant impacts. No project of the type listed in the First Schedule of the Act may be undertaken without an environmental impact assessment (EIA) licence. The Act charts the procedure to obtain an EIA licence briefly, with emphasis on the responsibilities of the EPA and the EPA Board, as outlined in Section 2.2.4. Transfer of EIA licences is not automatic according to Section 35 of the Act. If there is a change in ownership of the project, both the previous owner and the new must notify the EPA of the change. The EPA will transfer the licence to the new owner subject to endorsement of the licence conditions by the new owner. The EPA is required to monitor projects for which licences have been issued, in terms of Section 37 of the Act, in order to determine their effect on the environment and ascertain compliance with the Act. The Board can make regulations, in terms of Section 62 of the Act, to facilitate implementation of the Act. These regulations can cover subjects such as financial security to be maintained in respect of specified activities and standards, guidelines or methods for preventing or minimising pollution. A significant portion of the Act (Sections 40 to 52) deals with the control of ozone-depleting substances. 2.2.4 EIA procedure specified in the EPA Act 2008 SRK understands the main steps in the procedure are as follows: • An application must be made to the EPA for a licence, accompanied with a description of the proposed project; • The EPA will decide (within 14 days) whether an EIA is required; • If required, the applicant should then prepare an EIA; 2 The EPA Act 2008 explains that the term “environment” includes “land, air, water and all plants, animals and human beings living therein and the inter-relationship which exists among these.” U3823 August 2012 6 Appendix A • On receipt of the EIA report, the EPA will circulate it to professional bodies or associations, Government Ministries and non-governmental organisations (NGOs) for review; • The EPA will also open the EIA report for public inspection and comment and will notify the public of this in two issues of the Gazette (consecutive issues) and two issues of a newspaper (with an interval of at least seven days between the publications); • The EPA will submit the comments on the EIA, together with the EIA report, to the Board; • If the Board approves the EIA, it will instruct the Executive Director of the EPA to issue an EIA licence; • The EPA will issue a licence to undertake the activity/ project. The licence will have a period of validity and contain conditions for the protection of the environment. The EIA licence procedure presented in the EPA Act 2008 is the same as that presented in the now repealed Environment Protection Act 2000, except the agencies responsible for implementation of the EIA provisions have changed. 2.2.5 Guidelines on EIA procedures Guidelines on EIA procedures were published by the Ministry of Lands, Country Planning and the Environment (MLCPE) in July 1999. The same guidelines were re-issued by the MLCPE in July 2002. The guidelines were originally intended to facilitate implementation of the EIA provisions in the old Environment Protection Act 2000 and are considered by the MCLPE to be valid for the EIA provisions in the new EPA Act, 2008. The guidelines are summarised in Table 2-3, with emphasis on the relative responsibilities of the developer and the EPA. 3 The guidelines assign considerable responsibility to the EPA for the EIA process including responsibility for formulation of the EIA terms of reference (TOR) and for key public consultation activities. Usually (in most countries) responsibility for such tasks are assigned to the developer. References to public consultation during the EIA process are sparse in the EIA guidelines. The various references are listed below: • The EIA process is consultative at all stages as it requires welcomed input from all segments of society (Section 2 of the ESIA Procedures); • In line with the transparent and consultative principles of the EIA process, the developer is required, after the EPA has decided the project requires an EIA, to inform the public about and make representations to the EPA on the project. The EPA determines the most appropriate means of public notification in each case (Section 3.1 of the ESIA Procedures). • At the time of submission of the Draft environmental impact statement (EIS) for review, the developer should make the Draft EIS available for public review and make the necessary advertisements and arrangements for this (Section 3.4 of the ESIA Procedures). 3 The guideline actually refers to the DOE (and the Environment Protection Department/ Director of this department) rather than the EPA. U3823 August 2012 7 Appendix A • The EPA must prepare a Review Report that collates comments on the Draft EIS, (Section 3.4 of the ESIA Procedures). • The EPA must keep a register of the EIS, all related comments and decisions for public reference and scrutiny (Section 3.7 of the ESIA Procedures). • The public have a role in environmental auditing – members of the public are encouraged to step forward to inform the EPA of environmental offences and the EPA must investigate these and take action (Section 3.8.3 of the ESIA Procedures). • The Technical/Working Group is composed of representatives from the private sector, non-governmental organisations (NGOs), community groups, as well as a wide range of government entities. The Technical/ Working group ensures different views are heard and collaboration is encouraged (Section 2 of the ESIA Procedures). Table 2-3: Sierra Leone EIA Procedures (MCLPE, 1999 and 2002) EIA steps and Developer and EIA team EPA4 purpose Task Deliverable Task Deliverable Screening Complete a standardised Completed Based on the information in the The Executive To determine project brief using the screening screening form, a systematic Director of the whether the Screening Form (Annex 2, form review is undertaken by the EPA informs project will EIA Procedures) and submit EPA to determine whether an the developer have significant to the EPA (note that the EIA is required. of the decision impacts and if MMR5 must be involved). taken. a full EIA The EPA takes a decision on Unspecified process is required level of public required notification. Tasks under Developer is required to Unspecified the heading of inform the public about and “screening” in make representations to the the EIA EPA on the project Procedures, A preliminary study or series Unspecified but could be of investigations may be classified as undertaken to identify issues “EIA scoping” that need to be addressed in tasks. the full EIA. EIA Scoping A scoping meeting is convened Approved To determine to identify issues of importance TOR for the the scope of to decision makers. Members EIA the EIA of affected community may be invited to the meeting. The developer and its consultant shall be invited to meeting. The Terms of Reference (TOR) for the EIA are prepared by a Working Group constituted by the EPA – comprising government administrators and the developer. EIA Conduct studies of issues in Draft EIS6 Initial check of the Draft EIS by accordance with the the Executive Director of the approved TOR. Produce an EPA to ensure it is ready for draft environmental impact review. statement (EIS) 4 The guideline actually refers to the DOE (and the Environment Protection Department/ Director of this department) rather than the EPA 5 The MMR is the “Lead Sectoral Ministry (LSM)” in terms of the EIA Procedures (MLCPE, 1999 and 2002). When the developer initiates discussions with the MMR, the MMR must inform the developer of the prescribed EIA procedures. The MMR is obliged to forward the developer’s completed Screening Form to the EPA. 6 According to the EIA Procedure (MLCPE, 1999 and 2002), the EIS is referred to a Draft EIS initially because it represents findings and views of the developer. When the EIS has been approved, it is referred to as a Final EIS U3823 August 2012 8 Appendix A EIA steps and Developer and EIA team EPA4 purpose Task Deliverable Task Deliverable Review of the Up to 15 Review of the Draft EIS by the Reviewers EIS copies of EPA and Working Group7. may request the Draft Review process may not additional EIS exceed 90 days. information Developer makes the Draft The EPA opens the Draft EIS Review EIS available for public for public inspection and Report review and advertises this to comment 8and gives notice in containing the public two consecutive issues of the comments on Gazette and two issues of a the EIS newspaper (with an interval of at least seven days between the publications). The Working Group and members of the public consulted should forward written comments to the EPA. EPA compiles a Review Report for the Working Group/ Board9. This report collates the comments of all recipients of the Draft EIS and also comments from members of the public. Public hearing The EPA and/or the The EPA will co-ordinate the Record of the developer may decide to public hearing and the Board public hearing convene a public hearing if will appoint a mediator. there is sufficient opposition to the project. Environmental EPA issues environmental Environmental approval approval when satisfied that approval, with the proposed mitigating or without measures will effectively conditions reduce the environmental risk. Incorporate the Final EIS (3 Environmental Approval into copies to the EIS the EPA) Notify the general public of Keep a register of the EIS, all the final decision through related comments and public notice such as decisions for public reference newspapers and scrutiny. Environmental Submit monitoring reports to Carry out periodic audits of auditing the EPA in accordance with each project to ensure that all commitments in the agreements that were made monitoring and evaluation and conditions of approval are section of the EIS. being implemented. If the project is out of compliance with environmental regulations, implement remedial measures. Submit environmental management records to the EPA. 7 The new EPA Act 2008 refers to professional bodies, Government Ministries and NGOs rather than a “Working Group”. 8 The guidelines on EIA procedure suggest that the developer makes the EIA available for public review and the Act states that EPA is responsible for this. 9 The new Act 2008 requires that comments go to the EPA Board. U3823 August 2012 9 Appendix A 2.3 Environmental management provisions in mining legislation The Ministry of Mineral Resources (MMR) controls mining and mining-related matters by means of the Mines and Minerals Act 2009. Provisions in this Act that are pertinent to environmental and social management in general and to the ESIA for the Marampa Project are identified Table 2-4. The Act repeals the Mines and Minerals Act 1994. A key feature of the new Act is that it directly addresses environmental protection, community development and health and safety and it makes performance in all of these areas a condition for obtaining and keeping a mineral rights licence Table 2-4: Provisions in the Mines and Minerals Act 2009 pertinent to environmental and social impact assessment and management Subjects Key provisions Relevant sections General Types of The Act distinguishes the following mineral rights: Article 22 mineral rights • a reconnaissance licence; • an exploration licence; • an artisanal mining licence; • a small-scale mining licence; and • a large-scale mining licence. Surrender, The Act specifies the processes and conditions under which a mineral right can be Articles 50 suspension suspended and/or cancelled. The Minister may suspend or cancel a mineral right if to 55 and the mineral right holder: cancellation of • grossly violates health and safety regulations or causes environmental harm; mineral rights • employs child labour; • fails to submit required reports; • violates any provision of the Act; • fails to substantially comply with the terms of the community development agreement. Relationship between mineral rights and surface rights (Part V, Articles 32 to 38) Written The Act restricts the mineral right holder to exercise their rights on the following Article 32 consents without a consent from the responsible authority: required from • land dedicated for public purposes (such as cemeteries, parks and roads); authorities • land reserved for a railway, highway or waterway; • land within 200 m metres of any township. Written To exercise mineral rights, the holder of a mineral right must obtain written consent Article 32 consents from from the landowners/ occupiers for: landowners/ • land dedicated as a place of burial or which is a place of religious or cultural occupiers significance; • land on or within 200 metres of any inhabited, occupied or temporarily unoccupied dwelling; • land within 50 metres of land which has been cleared or ploughed for agriculture including the growing of crops; • land within 100 metres of any cattle dip, tank, dam, or other body of water. The Minister may judge consent is being unreasonably withheld and allow the holder of a mineral right to exercise those rights. Rights to The Act makes provisions for rights to graze stock and cultivate land as long as Article 33 graze stock this activity does not interfere with the use of the area for mining operations. and cultivate No holder of a mineral right shall create unprotected pits, hazardous waste dumps Article 33 land or other hazards that may endanger the stock, crops or other activity of the land owner or occupier. Surface lease The Act requires mining companies to enter into surface lease arrangements with Article 34 agreements the Government or landowners. If agreement cannot be reached between the parties, the Minister may determine the agreement upon the advice of the Minerals Advisory Board. Compensation The Act provides for payment of fair and reasonable compensation for Articles 35 disturbances foreseen by operations and damage done to the surface of the land. to 37 If the holder of a mineral right fails to pay compensation when demanded, or if the owner/occupier of the land is dissatisfied with any compensation offered, such compensation may be determined by the Minister on the advice of the Minerals U3823 August 2012 10 Appendix A Subjects Key provisions Relevant sections Advisory Board. Resettlement The Act introduces an explicit sub-section on the right to resettlement for affected Article 38 parties by clarifying the rights and responsibilities of communities and mining companies. Large-scale mining licences (Part XII, Articles 105 to 119) An application An application for a large-scale mining licence must include the following Article 106 for a large- environmental and social information: scale mining • proposals for the progressive reclamation and rehabilitation of land disturbed by must include mining; environmental • effects of the mining operations on the environment and on the local population and social and the proposals for mitigation, compensation and resettlement measures; information • a list of interested and affected parties including land owners and occupiers of the area; • details of consultation with interested and affected parties; • a report on the goods and services required for the mining operations which can be obtained within Sierra Leone; • proposals for the employment and training of citizens of Sierra Leone; • proposals for insurance cover including health and life insurance cover for employees; and • an environmental impact assessment licence for the project and an environmental management programme (EMP). Terms and The following will be appended to the large-scale mining licence as binding Article 110 conditions of obligations on the licence holder: the licence • the programme of mining operations approved by the Director; • a certified copy of the agreement between the applicant and the owners of the land over which the large-scale mining licence is granted; • particulars of the programme for the employment and training of citizens of Sierra Leone; • a certified copy of the approved EMP; and • particulars of the applicant’s proposals with respect to the procurement of goods and services obtainable within Sierra Leone. Obligations The holder of the mining licence is also obliged to substantially comply with the Article 115 community development agreement. Amendments Subject to Minister approval, the holder of a large-scale mining licence may make Article 113 to licences amendments to: • the programme of mining operations; • the environment management programme; and • the programme of employment and training of Sierra Leone citizens. Rights to Subject to the provisions of this Act and any other law holders of a large-scale Article 114 other mining licence shall have the exclusive right to carry on operations and establish resources infrastructure, including mine residue disposal facilities, in the licence area and may utilize the water and timber as necessary for mining operations. Protection of the Environment (Part XV, Sections 131 to 137) Environmental All small and large-scale mining licence holders must acquire environmental impact Article 131 impact assessment licences, in accordance with the Environmental Protection Act 2000 (it assessment is necessary to undertake an environmental impact assessment and produce an licence EMP to obtain this licence). Environmental The environmental impact assessment must be based on environmental baseline Article 133 impact work and include the following: assessment • detailed description of the environment supported by relevant measurements; • detailed description of the project including all phases of development, operations, reclamation and closure, and including o detailed resource requirements and emissions; o identification of the likely major environmental impacts; o review of residual and immitigable environmental impacts; o broad and detailed objectives regarding each environmental impact and means for achieving them; o predicted effect of each environmental mitigation activity; o budget and timetables for implementation; o identification of likely major social impacts and mitigation measures; o methodologies to be used for monitoring potential negative impacts and the source of funding for monitoring; o identification of people/ agencies responsible for implementation of U3823 August 2012 11 Appendix A Subjects Key provisions Relevant sections environmental management and monitoring; and o an EMP Public An applicant for a mining licence that is required to submit an environmental impact Article 133 consultation assessment must consult the public to introduce the project and verify possible impacts. The environmental impact assessment, EMP and annual status reports are Articles considered to public documents and will be made available for public review 133 and 134 Updating of The EMP must be updated and submitted for approval whenever there is a change Article 133 the EMP in mining operations Annual An annual report on progress in the implementation of the EMP is required. Article 134 progress/ The Director of Mines may suspend the licence if it is decided that the status report programme is not succeeding. Rehabilitation Conditions relating to rehabilitation may be included in a mineral right granted Article 136 under the Act. Financial All small-scale and large-scale licence holders must provide financial assurance for Article 136 assurance the performance against any obligations originating from an environmental impact assessment and management plan. To strengthen the Government’s ability to manage environmental issues associated with mining, the Act empowers the Minister to make specific rehabilitation activities a condition of a mineral right. If the company does not comply and the Government has to undertake work to remedy, the amount expended will be considered a debt to the Government and recoverable in court. Eligible forms of financial assurance include one or a combination of the following: • surety bond; • trust fund with pay-in period; • insurance policy; • cash deposit; and • annuities. Community development (Part XVI, Articles 138 to 141) Obligation to The holder of a small-scale or large-scale mining licence must assist in the Article 138 promote development of mining communities affected by its operations to promote community sustainable development, enhance the general welfare and the quality of life of the development inhabitants, and shall recognize and respect the rights, customs, traditions and religion of local communities. Community A community development agreement must be prepared where: Article 139 development • underground mines moving more than 100,000 tonnes/ year and open pit agreement mines moving more than 250,000 tonnes/ year. • mines employing/ contracting more than 100 workers on a typical day. The primary host community is the single community of persons mutually agreed by the holder of the small-scale or large-scale mining licence and the local council. If there is no community of persons residing within 30 km of any boundary defining the mining licence area, the primary host community shall be the local council. While a community development agreement is formed between the mining company and community, the Minister is required to approve the plan. The minimum expenditure for the implementation of the agreement by the holder of the mineral right of 0.1% of gross annual revenue for the implementation of the agreement. U3823 August 2012 12 Appendix A Subjects Key provisions Relevant sections Contents of The community development agreement must identify the primary host community Article 140 the agreement and include: • objectives of the agreement; • obligations of the licence-holder to the community; • obligations of the primary host community; • means for review of the agreement; • consultative and monitoring frameworks and means by which the community can participate in planning, implementation, management and monitoring of activities carried out under the agreement; and • a statement defining the process through which disputes will be resolved (including the involvement of the local authority and the Minister). Types of Types of projects that should be considered in the agreement are: Article 140 projects to be • educational scholarship, apprenticeship, technical training and employment considered in opportunities for the community; the agreement • financial and other forms of contributions towards infrastructural development and maintenance involving education, health, roads, water, power and other community services; • assistance towards the creation and development of small and micro sized enterprises; • agricultural product marketing; and • methods and procedures of environment and socio-economic management and local governance enhancement. The agreements may not address: Article 140 • imposition of additional taxes/ fees/ rent for the benefit of the primary host community; • provision of vehicles to the community unless it is for a specialised purpose (such as an ambulance or bus); or • provision of money, goods or facilities for the sole benefit of an individual or single family unit. Approval of All agreements entered into by large-scale mining licence holders and communities Article 141 the agreement must be approved by the Minister and the Act empowers the Minister to make determinations where parties cannot come to agreement. Health and safety (Part XVII, Articles 142 to 147) Duties of • Provide and promote conditions for safe operation and a healthy working Article 142 mineral rights environment. holders • Initiate measures necessary to secure, maintain and enhance health and safety. • Ensure the mine is operated and maintained in such a way that workers can perform their work without endangering the health and safety of themselves or others. • Ensure that persons who are not employees but who may be directly affected by activities at the mine are not exposed to any health and safety hazards. • Ensure that all persons working at the mine have the necessary skills and resources to undertake their work safely. • Take all reasonable steps to continuously prevent injury or loss of life when the mine is not being worked. • Establish a policy for the compensation of injured workers. Duties of • Comply with all measures and procedures established by the mineral right Article 143 workers holder to ensure health and safety at the mine. • Take reasonable care to protect their own health and safety and that of other persons. • Take proper care of all health and safety facilities and equipment. • Report promptly any situation which he believes could present a risk to health and safety. • Any worker shall have the right to leave the mine if he believes that circumstances pose a serious danger to their own health and safety. Health and The Act obligates the Minister to make regulations for securing, as far as possible, Article 147 safety the health and safety of employees involved in any operation associated with a regulations mineral right. U3823 August 2012 13 Appendix A Subjects Key provisions Relevant sections Financial (Part XVIII, Articles 148 to 162) Transparency The Minister must: Article 159 in the • develop a framework for transparency in the reporting and disclosure of extractive revenue due to or paid to Government; industry: • request, from any person engaged in the extractive industry, an accurate record disclosure of of the cost of production and volume of sale of minerals extracted; revenues and • request, from any person engaged in the extractive industry, an accurate payments account of money paid by and received from such person at any period; • ensure that all payments due to the Government from a person engaged in the extractive industry, including taxes, royalties, dividends, bonuses, penalties, and levies, are made; and • disseminate information concerning the revenue of the Government from the extractive industry at least annually. Miscellaneous (Part XIX, Articles 163 to 175) Preferential Companies must preferentially procure goods made in Sierra Leone and services Article 163 procurement from agencies in Sierra Leone and owned by Sierra Leoneans or companies of Sierra registered in Sierra Leone or Public Corporations. Leonean goods and services Preferential Companies must give employment preference to Sierra Leonean citizens; holders Article 164 employment of small and large scale mining licences must undertake a scheme of training to of Sierra ensure the advancement of Sierra Leoneans in skilled, technical, supervisory, Leoneans administrative and managerial positions. Reporting on Small- and large-scale mining licence holders are also required to submit annual Article 164 employment reports on employment and training, failure to do so shall be considered material and training breach of licence. Core Mineral Policy of the Government of Sierra Leone 2008 The Core Mineral Policy (CMP) of the Government of Sierra Leone has been designed to create an investor-friendly business environment in order to attract much needed foreign and local investments into the minerals sector. It is designed to enhance the social and economic benefits for the country and the communities affected by mining activities. The sector is expected to make important contributions towards industrial, social, economic and infrastructure development. It is also expected to provide new employment opportunities, generate foreign exchange earnings and contribute significantly to government revenue. The CMP aims to ensure tht the development of the minerals sector is achieved in ways that will protect the environment and that are socially responsible and economically viable. National Reconstruction and Development Act, 1999 (No. 5 of 1999) This Act establishes a Commission to secure and monitor the legitimate exploitation of Sierra Leone's' gold and diamonds, and other resources that are determined to be of strategic importance for national security and welfare as well as to cater for post-war rehabilitation and reconstruction. It states the commission will supervise and develop the exploration and exploitation of precious metals and diamonds and other natural resources of Sierra Leone. 2.4 Legislation pertaining to disturbance of forests 2.4.1 Forestry Act, 1988 This Act focuses on forests, but includes provisions for the declaration of protected areas for soil, water, flora or fauna conservation and protected trees anywhere in Sierra Leone. Most of provisions of the Act apply only to classified forests, which may be either national or community forest. A classified forest may have protection or production as its primary U3823 August 2012 14 Appendix A purpose, but in both cases it is to be managed for the maximum combination of benefits compatible with the primary purpose. The clauses of relevance to the environmental and social assessment and management are listed below. • There is a general prohibition against logging and other activities in classified forests, except as authorized under the Act. • The Chief Conservator of Forest, with the directives of the minister, is responsible for the management of the forest resources of the country. The Chief Conservator is required to compile a national inventory of forest resources and a national forest management plan. • A national forest is required to be on state-owned or -leased land. Community forests on chiefdom lands are created by agreement between chiefdom authorities and the Chief Conservator (Part V, Section 18). The agreement must delineate the area and describe the the forest resources and potential of the area. • Management of community forests may be provided by the Forestry Division, by the chiefdom or local authority, or by non-governmental organizations. Utilization may be permitted to community members or others, and may be subject to fees and other conditions • Detailed inventories of classified forests may be required by regulation. • Detailed management plans are encouraged for all classified forests, although they are only required in the case of a concession for a national forest. • Utilization of national forests may be authorized by licence or concession, which is subject to the payment of prescribed fees and to management, reforestation and working plans prepared or approved by the Chief Conservator. • No classified forest may be cut, burned, uprooted, damaged or destroyed, except with a written permission from the Chief Conservator of the forest (Part VI, Section 21 Subsection 2). Failure to observe this is an offence punishable with a fine. • Any one permitted to fell timber is liable to paying a reforestation fee (Section 17), which is to be paid to the Chief Conservator and will be paid into a reforestation fund established under the Act. Mining companies can have this fee refunded where it undertakes reforestation in the rehabilitation of disturbed land. 2.4.2 The Forestry Regulations, 1989 No classified/ protected forest can be used or disturbed without written permission from the Chief Conservator of the forest. A licence may be issued by an inspector of the Forestry Division authorising the holder of the mining lease, to clear land in a classified forest for the purpose of mining (Section 15, Subsection 1). A holder of a licence for deforestation of, or vegetation removal from the environment, must observe conditions in Section 15, Subsection 3, which include the following conditions: • removal of vegetation, can be done for mining operations only within an area licenced for this purpose; • specified land area, shall be cleared within a stated time, but trees requested not to be felled, removed or damaged, are to be left standing; • trees to be felled shall be identified, except where total felling is authorised; • a forest severance fee and a minor forest produce fee, shall be paid in respect of all forest produce that is merchantable, which may be removed by clearance of vegetation; U3823 August 2012 15 Appendix A • at the completion of mining, the area shall be replanted with approved crops or trees by the mining company, or provision made for this to be done by payment of the estimated reforestation cost; and • required method of cultivation and silviculture, specified by the Chief Conservator, must be employed. No land between the high and low water marks, nor those above the high water mark on both sides of the bank of any waterway, covering a distance of one hundred feet (approximately 33 m), shall be cleared of any vegetation except permitted by a clearance licence (Part XI, Section 38). Sacred bushes are protected by the stipulated regulations of Section 40, whereby clearance of vegetation from land designated as sacred bush, is prohibited except by clearance authority from the Chief Conservator. 2.5 Water law 2.5.1 Current legislation With the exception of legislation pertaining to water supply and sanitation, there is no water management legislation in Sierra Leone. Existing legislation pertaining to water supply and sanitation includes: • The Guma Valley Water Act (1961), which deals with water supply services to the city of Freetown. • The Water (Control and Supply) Act (1963), which deals with water supply services in urban centres except for Freetown as well as rural areas in the country. The responsible authority is the Water Supply Division (WSD) of the Ministry of Energy and Power. • The Sierra Leone Water Company Act (2001) which establishes the Sierra Leone Water Company (SALWACO) to provide water supply services in the district towns of Bo, Kenema, Koidu, Makeni, Kabala and the International Airport at Lungi (thus some of the responsibilities of WSD are transferred to SALWACO). It has reportedly been recognised that the existing legislation is inadequate and high priority has been given to the development of a National Water and Sanitation Policy. 2.5.2 National Water and Sanitation Policy The latest version of the policy was published by the Ministry of Energy and Power in August 2008. The policy covers the following subjects: • water resources management • urban water supply and sewerage • rural water supply • hygiene and sanitation; and • legal, regulatory and institutional framework. Water resources management Specific policy objectives relevant to water resources management include: • to vest in the State all water in the country and provide every citizen equal right to access and use the nation’s natural water resources; U3823 August 2012 16 Appendix A • to ensure effectiveness and efficiency of water resources utilization; • to promote management of water conservation and quality standards of water resources; • to develop a water management system that protects the environment, ecological system and biodiversity; • to develop appropriate and sustainable procedures for water resources assessment; • to develop sustainable integrated plans for water resources development; • to develop a database and information for development of water projects; • to carry out research and technological development; • to undertake training and human resources development; • to develop disaster prevention and management plans; • to promote regional and international cooperation on utilization of trans-boundary water resources; • to increase utilisation of groundwater resources; and • to develop sustainable financing of water resources management activities. The NWSP states future water management approaches will focus on how water is best used beneficially and efficiently. Accordingly, water should be prioritised as follows: • Adequate quantity and acceptable quality water for basic human needs will receive first priority. • Water for the environment to protect the ecosystems that underpin the country’s water resources, now and in the future will attain second priority and will be reserved. • Other uses such as agriculture, industrial production, hydropower production, mining, livestock keeping, fish production and processing, fish farming etc will be subject to social and economic criteria which will be reviewed from time to time. • Utilisation of trans-boundary water resources will be based on the principle of equity, right and rationality in accordance with agreements among the riparian states, and by respecting the principles of international obligations on trans-boundary water resources. The Ministry of Lands, in collaboration with the National Water Resources Board (NWRB), will carry out resource mapping to support better allocation and use, and the need to protect sources and resources. And the following issues are addressed: • Water use permits will only be issued for a determined beneficial water use. Procedures, criteria and guidelines for issuing the permits will be prepared and made operational by the NWRB. • Trading of water rights, application of economic incentives and pricing for water use shall be gradually built into the management system as a means for managing demand requirements. • The “polluter pays” principle shall apply in conjunction with other legal and administrative actions. Environmental standards for in-stream flows, industrial effluents and other waste discharges for meeting environmental objectives will be developed and enforced. Future regulatory bodies/ institutions With respect to the legal, regulatory and institutional framework, key objectives are listed below. U3823 August 2012 17 Appendix A • Enact new unified water legislation (Water Law) which creates a level playing field for all those involved in the sector, public and private, present and future. • Create a transparent and independent regulatory regime including the establishment of an independent regulatory authority with appropriately qualified personnel for regulating the water supply and waste disposal activities. • Ensure the roles and responsibilities of stakeholders involved in the water and sanitation sector are clearly defined and allow for coordination and collaboration between stakeholders for the benefit of the national economy and the population of Sierra Leone. A NWRB will be established and become the overall responsible institution for the water resources management continuum from upstream freshwater sources to freshwater- seawater interface. It will be responsible for implementing the water resources management strategies. Core functions will include: water resources exploration, water resources assessment both in quantity and quality, monitoring and evaluation, water allocation, pollution control, and other cross-sector activities such as catchments management, planning and development. The Ministry of Marine Resources, in collaboration with the NWRB, will continue to be responsible for planning, developing, managing and conservation of all living and non-living aquatic resources including fisheries and fish culture and regulates activities for both in-land water and marine fishing. Local Councils will be responsible for implementing water resources plans, protection and conservation of natural resources at district level, establishment of bye-laws on the management of water resources, and conflict resolution in accordance with established laws and regulations. District Water and Sanitation (WATSAN) Committees will be statutorily established, comprising water and sanitation sector stakeholders to carry out the above- mentioned tasks Participation of communities in decision-making, planning, management and implementation of water resources management and development will be enhanced through statutory establishing village/community water and sanitation committees. 2.5.3 Water permits needing to be obtained Currently, there are no water permits to be obtained for the Project because there is no legislation controlling: • abstraction of water from water resources; • water use for industrial purposes; • effluent discharges or other discharges to watercourses; • impounding of water; and • diversion of watercourses. 2.6 Legislation pertaining to land tenure Rural land in Sierra Leone is held by landowning families (extended families or lineages) with chieftaincy structure playing a significant administrative and custodian role. Extended families are attached to particular areas within chiefdom. While there are section chiefs at different administrative levels, the paramount chief is particularly important in land matters. At present, the sale of land is virtually impossible and leasing of land is tricky. Property U3823 August 2012 18 Appendix A boundaries have not been surveyed, written deeds do not exist and both chiefs and recognised representatives of land owning families have to be involved decisions on leasing of land. Furthermore, both national legislation and customary law apply, and the relevant national legislation is under revision and the relevant customary law is unwritten. A detailed review of this predicament is presented in a paper by the Food and Agriculture Organization (FAO) of the United Nations (2006). According to the FAO (2006), the formal legal environment regarding land in Sierra Leone is currently undergoing significant change and the primary pieces of legislation regarding land are: • The Land Policy. The new National Lands Policy (2005) articulates sufficiently the urgent need for a more coherent approach to land administration since the war. Statement of the policy appears to support the inalienability of land with regard to the landowning families and the role of descendants in claiming rights to land. In addition policy does acknowledge that land is sold in urban areas in the provinces. • The Land Commission Act. The overall purpose of this Act is to establish a Lands Commission with offices at the federal, provincial and district levels in order to grant rights to lands, impose restrictions, implement policies on land and rural development, advise government local councils and traditional authorities on the policy framework for the development of particular areas, recognize and establish the content of land tenure rights as well as transform ownership rights of such lands; advice and assist in the execution of a registration programme and perform other functions as necessary. • The Commercial Lands Act. The law project to formulate legislation on the commercial use of land was the first major activity of the Law Reform Commission. The purpose of the project was to find approaches to modernizing the laws dealing with commercial use of land, particularly in the provinces where customary law predominates, with the purpose to attract foreign and local investment to set up large scale commercial activities involving land. Neither the Land Commission Act nor the Commercial Lands Act have been promulgated yet. The recent Devolution of Estates Act, 2007 (No. 21 of 2007) deals with land ownership and inheritance. This Act makes provision with respect to intestate succession and succession by will of estates including land and land-related rights. The Act sets out rules relative to inheritance and related distribution of estates in the case a person dies without having made a will. The Act also defines offences against persons entitled to inheritance or related to the deceased person. 2.7 The Factories Act – 1974 This Act deals with the safety, security and welfare of factory employees. It requires every factory to be kept in a clean state and free from effluent arising from any drain, sanitary convenience or nuisance. This part of the Act also states that for overall safety of all employees, the factory must not be overcrowded, must be effectively ventilated, and provided with suitable lighting systems. Every care must be taken by the factory holder, to secure the health, safety and welfare of all employees. The Act also covers reporting of all injuries, accidents, diseases and death and the powers of inspectors. U3823 August 2012 19 Appendix A 3 INTERNATIONAL LAW, STANDARDS AND CODES OF CONDUCT An overview of the main international initiatives having influenced approaches to ESIA in the last two decades are outlined in Figure 3-1. They include the 1992 Rio Declaration; 2000 United Nations Millennium Declaration; the 2000 United Nations Global Compact; and the 2002 Millennium Development Goals. For the mining industry, further impetus has been added by the findings of research projects from 2000 to 2005 – including the Global Mining Initiative; the Mining, Minerals and Sustainable Development Project, and the World Bank Extractive Industries Review. The International Finance Corporation’s (IFC) Performance Standards, which were published in April 2006, reflect these developments. The International Council on Mining and Metals’ (ICMM) Sustainable Development Framework also reflects and reinforces these developments. International law, standards and codes of conduct concerning environmental management and sustainable development that are of relevance to the Marampa Project are discussed in this section under the following headings: • international law (Section 3.2); • conditioning of project finance – Equator Principles and IFC Performance Standards (Section 3.3); and • self-regulation in the mining sector (Section 3.4). 3.1 International law International law pertinent to the environment and sustainable development comprises: • customary international law, which is applicable to all states and it results from general and consistent practice followed by states out of a sense of legal obligation, so much so that it becomes custom; • treaties (the term “treaty” encompasses “agreements, covenants, conventions, pacts, protocols, and statutes”), which are generally intended to be implemented through enactment and enforcement of laws at national levels; and • judicial decisions of international courts and tribunals. International practices pertaining to environmental management and sustainable development are strongly influenced by declarations and treaties as outlined below. Declarations are generally not immediately legally binding but can acquire the force of international customary law if they continue to express an international consensus which states adhere to over time. U3823 August 2012 20 Appendix A Figure 3-1: International initiatives influencing the scope of and approaches to ESIA U3823 August 2012 21 Appendix A 3.1.1 Declarations and customary law Declarations influencing international practice in the fields of environmental management and sustainable development are listed below in order of their relative importance to these fields: • The 1992 Declaration on Environment and Development (referred to as the “Rio Declaration); • The 1972 Declaration on the Human Environment (referred to as the “Stockholm Declaration”); • The 1948 Universal Declaration of Human Rights; • The 2000 United Nations Millennium Declaration; • The 2007 Declaration on the Rights of Indigenous Peoples; and • The 1998 Declaration on Fundamental Principles and Rights at Work. The Rio Declaration is of major importance because it reinforced the notion of sustainable development. Many of the principles in the Rio Declaration are acquiring the force of international customary law according to UNEP (2005). In the last decade, the set of concerns addressed under the heading “sustainable development” has been extended to include: • human rights – up-holding and supporting universal human rights; • labour standards – up-holding labour standards, particularly those that pertain to human rights. • working against corruption of all forms, including extortion and bribery. Key initiatives influencing this are the 2000 United Nations Millennium Declaration and 2002 Millennium Development Goals. The Millennium Declaration Goals recognise explicitly the interdependence between sustainable development, growth and poverty reduction. They comprise eight international development goals that 189 United Nations member states have agreed to achieve by the year 2015. They were developed out of the United Nations Millennium Declaration and synthesise, in a single package, many of the most important commitments made separately at the international conferences and summits of the 1990s. They also acknowledge that development rests on the foundations of democratic governance, the rule of law, respect for human rights and peace and security. All principles contained in the Universal Declaration of Human Rights are considered to be international customary law and do not require signature or ratification by the state to be recognised as a legal standard (UNEP, 2005). The Declaration on the Rights of Indigenous Peoples, which was adopted by the United Nations General Assembly in September 2007 (United Nations website, March 2009), has high profile in the realm of sustainable development. The Declaration sets out the rights of indigenous peoples, prohibits discrimination against indigenous peoples and promotes their full and effective participation in all matters that concern them. The 1998 Declaration on Fundamental Principles and Rights at Work requires both states and businesses to observe International Labour Organisation (ILO) Conventions that are of fundamental importance from a human rights perspective. These conventions pertain to: • Freedom of association, collective bargaining, and industrial relations; U3823 August 2012 22 Appendix A • Forced labour; • Elimination of child labour and protection of children and young persons; and • Equality of opportunity and treatment/ elimination of discrimination in respect of employment and occupation. 3.1.2 Multilateral treaties Multilateral treaties pertinent to the environment and sustainable development include numerous environmental treaties, some human rights treaties and some workplace treaties. The treaties are officially recorded as follows: • Environment and human rights treaties are recorded in the United Nations Treaty Series (March 2009) under the headings “Environment (Chapter 27)” and “Human Rights (Chapter 4)”. • Workplace treaties are better known as ILO conventions because they are promulgated by ILO, an agency of the United Nations. They are recorded on the ILO’s ILOLEX website (ILOLEX, March 2009). Environmental treaties Most international environmental treaties that are considered to be important by the United Nations Environmental Programme (UNEP, 2005) are in force in Sierra Leone. These treaties are listed in Table 3-1. The Government of Sierra Leone has secured funding from the Global Environment Facility (GEF) to facilitate the fulfilment of the treaty mandates and to develop strategic action plans that link country action to the broader global environmental management and sustainable development. The United Nations Development Programme is providing provides supervisory and management support with this (Sierra Leone Information System, 2009). Table 3-1: International environmental treaties endorsed by Sierra Leone Topic Convention In force in Title Date Sierra Leone Climate United Nations Framework Convention on Climate 1992 1995 change and Change the ozone Kyoto Protocol to the United Nations Framework 1997 2007 layer Convention on Climate Change Convention for the Protection of the Ozone Layer 1985 2001 Montreal Protocol on Substances that Deplete the Ozone 1987 2001 Layer Amendment to the Montreal Protocol on Substances that 1990 2001 Deplete the Ozone Layer Amendment to the Montreal Protocol on Substances that 1992 2001 Deplete the Ozone Layer Amendment to the Montreal Protocol on Substances that 1997 2001 Deplete the Ozone Layer Amendment to the Montreal Protocol on Substances that 1999 2002 Deplete the Ozone Layer Hazardous Basel Convention on the Control of Transboundary 1989 chemicals, Movements of Hazardous Wastes and their Disposal waste and Bamako Convention on the Ban of the Import into Africa 1991 Signed in pollution and the Control of Transboundary Movement and 2003, not in Management of Hazardous Wastes within Africa force Stockholm Convention on Persistent Organic Pollutants 2001 2004 U3823 August 2012 23 Appendix A Topic Convention In force in Title Date Sierra Leone Rotterdam Convention on the Prior Informed Consent 1998 Procedure for Certain Hazardous Chemicals and Pesticides in International Trade Desertification International Convention to Combat Desertification in 1994 1997 those Countries Experiencing Serious Drought and/or Desertification, particularly in Africa Biodiversity African Convention on the Conservation of Nature and 2003 Signed in and the Natural Resources (Revised Version) 2003, not in protection of force plants and African Convention on the Conservation of Nature and 1968 Signed in animals Natural Resources 1968, not in force Convention on Biological Diversity 1992 1995 Cartagena Protocol on Biosafety to the Convention on 2000 Biological Diversity Convention on the Conservation of Migratory Species of 1979 Wild Animals Memorandum of Understanding concerning Conservation 1999 2002 Measures for Marine Turtles of the Atlantic Coast of Africa Memorandum of Understanding concerning Conservation 2005 Signed in Measures for the West African Populations of the African 2005, not in Elephant force Convention on International Trade in Endangered Species 1973 1995 of Wild Fauna and Flora Amendment to the Convention on International Trade in 1979 1995 Endangered Species of Wild Fauna and Flora (Art.XI) Convention on Wetlands of International Importance 1971 2000 especially as Waterfowl Habitat Protocol to amend the Convention on Wetlands of 1982 2000 International Importance especially as Waterfowl Habitat Amendments to Articles 6 and 7 of the Convention on 1987 2000 Wetlands of International Importance especially as Waterfowl Habitat Cultural Convention concerning the Protection of the World 1972 1994 heritage Cultural and Natural Heritage Human rights treaties Of the 25 United Nations treaties on human rights that are listed in the United Nations Treaty Series (March 2009), 14 have been signed by Sierra Leone (Table 3-3). Table 3-2: United Nations treaties on human rights and endorsement of these by Sierra Leone United Nations Treaties Date In Endorsement by (List from from the United Nations Treaty Series force Sierra Leone (http://untreaty.un.org/ ) Ratification, Accession (a), Signature (s) 1. Convention on the Prevention and Punishment of the 1948 1951 Crime of Genocide 2. International Convention on the Elimination of All Forms of 1966 1969 1967 Racial Discrimination 2.a. Amendment to article 8 of the International Convention 1992 Not yet on the Elimination of All Forms of Racial Discrimination 3. International Covenant on Economic, Social and Cultural 1966 1976 1996(a) Rights U3823 August 2012 24 Appendix A United Nations Treaties Date In Endorsement by (List from from the United Nations Treaty Series force Sierra Leone ) Ratification, (http://untreaty.un.org/ Accession (a), Signature (s) 4. International Covenant on Civil and Political Rights 1966 1976 1996(a) 5. Optional Protocol to the International Covenant on Civil 1966 1976 1996(a) and Political Right 6. Convention on the non-applicability of statutory limitations 1968 1970 to war crimes and crimes against humanity 7. International Convention on the Suppression and 1973 1976 Punishment of the Crime of Apartheid 8. Convention on the Elimination of All Forms of 1979 1981 1998 Discrimination against Women 8.a. Amendment to article 20, paragraph 1 of the Convention 1995 Not yet on the Elimination of All Forms of Discrimination against Women 8.b. Optional Protocol to the Convention on the Elimination of 1999 Not yet 2000 (s) All Forms of Discrimination against Women 9. Convention against Torture and Other Cruel, Inhuman or 1984 1987 2001 Degrading Treatment or Punishment 9.a. Amendments to articles 17 (7) and 18 (5) of the 1992 1987 Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment 9.b. Optional Protocol to the Convention against Torture and 2002 Not yet 2003 (s) Other Cruel, Inhuman or Degrading Treatment or Punishment 10. International Convention against Apartheid in Sports 1985 1988 1986 (s) 11. Convention on the Rights of the Child 1989 1990 1990 11.a. Amendment to article 43 (2) of the Convention on the 1995 2002 2001 (a) Rights of the Child 11.b. Optional Protocol to the Convention on the Rights of 2000 2002 2002 the Child on the involvement of children in armed conflict 11.c. Optional Protocol to the Convention on the Rights of 2000 2002 2001 the Child on the sale of children, child prostitution and child pornography 12. Second Optional Protocol to the International Covenant 1989 1991 2001 on Civil and Political Rights, aiming at the abolition of the death penalty 13. International Convention on the Protection of the Rights 1990 of All Migrant Workers and Members of their Families 14. Agreement establishing the Fund for the Development of 1992 1993 the Indigenous Peoples of Latin America and the Caribbean 15. Convention on the Rights of Persons with Disabilities 2006 Not yet 2007 (s) 15.a. Optional Protocol to the Convention on the Rights of 2006 Not yet 2007 (s) Persons with Disabilities 16. International Convention for the Protection of All Persons 2006 Not yet 2007 (s) from Enforced Disappearance Workplace treaties/ ILO Conventions ILO Conventions are treaties and they are subject to ratification by member states. According to the ILO ILOLEX website (ILOLEX, March 2009), Sierra Leone has ratified 17 ILO conventions (ILO, August 2008). The ILO Conventions of relevance to the ESIA for the Marampa Project are listed in Table 3-1 . Sierra Leone ratified many of the ILO Conventions that are considered to be important U3823 August 2012 25 Appendix A in terms of the 1998 Declaration on Fundamental Principles and Rights at Work (Section 3.2.1) in the 1960s. It has not yet ratified those pertaining to forced labour. Table 3-3: ILO Conventions of relevance to the ESIA for the Marampa Project ILO Conventions Importance Ratified by Sierra Leone Grouping Conventions Human Mining11 10 rights Freedom of Freedom of Association and Protection of X X 1961 association, the Right to Organise Convention, 1948 collective (No. 87) bargaining, and Right to Organise and Collective Bargaining X X 1961 industrial Convention, 1949 (No. 98) relations Forced labour Forced Labour Convention, 1930 (No. 29) X X 1961 Abolition of Forced Labour Convention, 1961 1957 (No. 105) Elimination of Minimum Age Convention, 1973 (No. 138) X X child labour and Worst Forms of Child Labour Convention, X X protection of 1999 (No. 182) children Equality of Equal Remuneration Convention, 1951 (No X X 1968 opportunity and 100) treatment Discrimination (Employment and X X 1966 Occupation) Convention, 1958 (No 111) Occupational Occupational Safety and Health X safety and Convention, 1981 (No. 155) health Protection Working Environment (Air against Pollution, Noise and specific Vibration) Convention, 1977 risks (No. 148) Chemicals Convention, 1990 (No. 170) Prevention of Major Industrial Accidents Convention, 1993 (No. 174) Protection Safety and Health in in specific Construction Convention, branches 1988 (No. 167) of activity Safety and Health in Mines X Convention, 1995 (No. 176) Indigenous and Indigenous and Tribal X tribal peoples Peoples Convention, 1989 (No. 169) The ILO Indigenous and Tribal Peoples Convention, 1989 (No 169), is considered important from the environmental and social perspectives (UNEP, 2005). It requires the adoption of special measures to protect and preserve the environment of indigenous and tribal people. It contains numerous references to lands, resources and the environment of indigenous people. 10 ILO Conventions recognised as being of fundamental importance from a human rights perspective in terms of the 1998 Declaration on Fundamental Principles and Rights at Work (Section 3.2.1). 11 Conventions considered to be important by the International Council on Mining and Metals (ICMM, March 2009). U3823 August 2012 26 Appendix A 3.1.3 Regional treaties influencing international practice Some conventions of the United Nations Economic Commission for Europe (UNECE) are considered to have global significance, even though their field of application is regional. These are listed in Table 3-5. Table 3-4: UNECE conventions that are considered to have global importance UNECE Conventions Global importance Convention on Long-range Transboundary Air Addresses long-range transboundary air Pollution (CLTRAP, 1989) pollution. Convention on Environmental Impact Assessment in Set an international precedent on a Trans-boundary Context (Espoo, 1991) transboundary EIA and public involvement. Convention on the Protection and Use of Laid down the principles of transboundary Transboundary Watercourses and International cooperation within river basins for the first Lakes (Water Convention, 1992) time under international law. Convention on Access to Information, Public Considered to be of global importance as an Participation in Decision Making and Access to elaboration of Principle 10 of the Rio Justice in International Environmental Matters Declaration. (Aarhus, 1998) 3.2 Conditioning of project finance: Equator Principles and the IFC Performance Standards and World Bank EHS Guidelines Development financiers play a major role in the development and enforcement of international sustainable development standards through the conditioning their loans. This conditionality comes in two forms: (1) the use of ESIA to screen projects in advance of loan approval and (2) actual loan conditions imposed on projects. 3.2.1 Introduction to the Equator Principles The Equator Principles require that financial institutions to condition their loans. They were published in June 2003, by several private banks and the International Finance Corporation (IFC), and were updated in July 2006. By February 2009, 65 financial institutions had adopted the Equator Principles (Equator Principles website, March 2009). The founding banks chose to model the Equator Principles on the environmental and social standards of the World Bank Group. When the Equator Principles were first published, the IFC invested in rigorous updating of the standards. The products of this exercise are the IFC Performance Standards on Social and Environmental Sustainability (IFC Performance Standards), which were published in April 2006 and are recognised as being the best and most comprehensive standards available to international finance institutions working with the private sector. The revised Equator Principles were published largely in response to the publication of the IFC Performance Standards. The 2006 Equator Principles require observance of the new International Finance Corporation (IFC) Performance Standards and the World Bank Group Environmental, Health and Safety (EHS) Guidelines (Equator Principles, March 2009). A summary of the Equator Principles is presented in Table 3-6. Table 3-5: Overview of the Equator Principles Title Outline Principle 1: Determine the screening category the project belongs to. Review and Most mines fall in Category A (Projects with potential significant adverse social or U3823 August 2012 27 Appendix A Title Outline Categorisation environmental impacts that are diverse, irreversible or unprecedented) Principle 2: An ESIA must be completed for each project assessed as being either Category A Social and or Category B. Environmental Assessment Principle 3: The ESIA must establish the project's overall compliance with, or justified deviation Applicable from, applicable IFC Performance Standards and World Bank Group Social and Environmental, Health and Safety (EHS) Guidelines. The ESIA must address Environmental compliance with relevant host country laws, regulations and permits that pertain to Standards social and environmental matters. Principle 4: An Action Plan that addresses the relevant findings, and draws on the conclusions Action Plan of the ESIA must be prepared. This must describe and prioritise the actions needed and to implement mitigation measures, corrective actions and monitoring measures Management necessary to manage the impacts and risks identified in the ESIA. Establish an System Environmental and Social Management System (ESMS) that addresses the management of identified impacts. Principle 5: There must be consultation with project affected communities in a structured and Consultation culturally appropriate manner. The process, results of the consultation and any and actions agreed resulting from the consultation must be documented. Disclosure Principle 6: Establish a grievance mechanism to ensure that consultation, disclosure and Grievance community engagement continues throughout construction and operation of the Mechanism project. Inform the affected communities about the mechanism. Principle 7: For all Category A projects and, as appropriate, for Category B projects, an Independent independent social or environmental expert should review the assessment, action Review plan and consultation process documentation to assess Equator Principles compliance. Principle 8: The borrower will covenant in financing Covenants documentation: a) to comply with all relevant host country social and environmental laws and permits; b) to comply with the action plan; c) to provide periodic reports (not less than annually) by in-house staff or third party experts that document compliance; d) to decommission the facilities, where applicable and appropriate, in accordance with an agreed decommissioning plan. If the borrower fails to comply, development financiers reserve the right to exercise remedies, as they consider appropriate. Principle 9: Monitoring information to be shared with development financiers must be verified Independent by an independent expert or qualified and experienced external experts retained by Monitoring the borrower. and Reporting Principle 10: Each EPFI adopting the Equator Principles commits to report publicly at least Equator annually about its Equator Principles implementation processes and experience, Principle taking into account Financial appropriate confidentiality considerations. Institutions (EPFI) Reporting 3.2.2 Introduction to the IFC Performance Standards The IFC Performance Standards are matched with corresponding Guidance Notes that provide guidance on the requirements contained in the standards and on good sustainability practices to help clients improve project performance. These Guidance Notes are updated on a regular basis. The most recent versions were published in July 2007 with a new set expected early in 2011. U3823 August 2012 28 Appendix A The IFC Performance Standards (April 2006) are entitled: • 1: Social and Environmental Assessment and Management System; • 2: Labour and Working Conditions; • 3: Pollution Prevention and Abatement; • 4: Community Health, Safety and Security; • 5: Land Acquisition and Involuntary Resettlement; • 6: Biodiversity Conservation and Sustainable Natural Resource Management; • 7: Indigenous Peoples; and • 8: Cultural Heritage. IFC Performance Standard 1 establishes the importance of: • integrated assessment to identify the social and environmental impacts, risks, and opportunities of projects; • effective community engagement through disclosure of project-related information and consultation with local communities on matters that directly affect them ; and • the client’s management of social and environmental performance throughout the life of the project. IFC Performance Standards 2 through 8 establish requirements to avoid, reduce, mitigate or compensate for impacts on people and the environment, and to improve conditions where appropriate. Where social or environmental impacts are anticipated, the client is required to manage them through its Social and Environmental Management System consistent with Performance Standard 1 (IFC website, March 2009). Figure 3-2. illustrates an ESIA procedure in terms of IFC Performance Standard 1. More background on this procedure is provided in Table 3-7. The IFC recommends that assessment should begin as early as possible, as collection of baseline data required for definition of impacts may require months or even years and potential impacts can be identified and avoided or mitigated in the earliest stages of planning. U3823 August 2012 29 Appendix A 12 Figure 3-2: ESIA procedure in terms of the IFC Performance Standard 1 12 The IFC Performance Standards use the term “social and environmental assessment (SEA)” instead of ESIA –ESIA has been used here for the purposes of consistency with the rest of the document. U3823 August 2012 30 Appendix A 13 14 Table 3-6: ESIA procedure in terms of the IFC Performance Standard 1 Steps Description of activities Screening Screening is a quick, high-level analysis to determine whether a full ESIA is necessary. Scoping produces a plan for the assessment. It determines  which impacts are likely to be significant and should become the main focus of the assessments;  data availability and gaps; Scoping  the appropriate spatial and temporal scopes for the assessment; and suitable survey and research methodologies. Stakeholders – including government officials and local communities – are consulted to help identify key impacts and input to the assessment plan. Baseline studies provide a reference point against which any future changes associated with a project can be assessed and offer information for subsequent monitoring of performance. It may be necessary to commission lengthy field-based studies to fully capture Baseline studies seasonal trends. The first step in conducting a baseline study is creating a map of the potentially affected area. Additional survey work and consultation with local experts is usually required to get a full picture of an area. It is important to remember that baseline information is often not sufficient to determine impacts; the information forms the basis of subsequent impact assessment activities. Impact prediction and evaluation is the heart of the ESIA. Impact prediction requires professional judgment, and will require input from relevant experts. Once the potential impacts are more fully understood, it is necessary to judge Impact prediction the significance of each impact, to determine whether it is acceptable, requires and evaluation mitigation or is unacceptable. Determining the significance of impacts is a complex and subjective process. Consultation with local stakeholders is vital at this stage, and particular attention should be given to vulnerable or disadvantaged communities. Mitigation aims to eliminate or reduce negative impacts. Mitigation options should generally be considered in the following order of preference: 1. Avoidance of impacts altogether Mitigation 2. Reduction of impacts where unavoidable 3. Restoration of disturbed areas to their original state 4. Relocation of affected communities 5. Compensation for any residual, unavoidable damage When all mitigation measures have been identified, a comparison of alternatives will allow identification of the least damaging option. Consideration of alternatives This is an iterative process of comparing potential impacts and mitigation options of a series of alternative designs, locations, technologies and operations to identify the optimal configuration that meets or exceeds the requirements of national legislation and any funding agencies. 13 The IFC Performance Standards use the term “social and environmental assessment (SEA)” instead of ESIA –ESIA has been used here for the purposes of consistency with the rest of the document. 14 Source: IFC, March 2006. A Guide to Biodiversity for the Private Sector: The Social and Environmental Impact Assessment Process. (http://www.ifc.org/ifcext/sustainability.nsf/AttachmentsByTitle/BiodivGuide_ESIA/$FILE/ESIA.pdf) U3823 August 2012 31 Appendix A Steps Description of activities Also called an Action Plan, an ESMP defines resources, roles and responsibilities required to manage impacts and implement mitigation measures. The ESMP forms a link between the ESIA and the Environmental and Social 16 Management System (ESMS ). The central elements of a ESMP should Environmental and include a prioritized description of the activities planned to mitigate impacts, a Social Management time line and identification of resources to ensure the ESMP can be delivered, 15 Plan (ESMP) and a communication plan that indicates how progress in the implementation of the ESMP will be disclosed. The ESMP should also define monitoring requirements to determine whether mitigation is successful. Monitoring is important for providing evidence of compliance with ESMP and the effective implementation of management measures. The ESIS/ ESIR is the physical report on the ESIA process and findings. The ESIA should provide a clear, jargon-free review of potential impacts and how Environmental and they have been and will be mitigated. Social Impact Statement (ESIS)/ The report often forms the basis of public consultation activities and is the Environmental and document that is presented to regulatory authorities and others, including IFC, Social Impact as the basis for decision making. Report (ESIR) Public disclosure helps affected communities understand risks, impacts and opportunities related to potential projects. Introduction to the World Bank Group EHS Guidelines The World Bank Group Environmental, Health, and Safety Guidelines (known as the 'EHS Guidelines') were published in 2007 and 2008. The EHS Guidelines are intended to be living documents, and will be updated on a regular basis. The EHS Guidelines are technical reference documents with general and industry-specific examples of Good International Industry Practice (GIIP), as defined in IFC's Performance Standard 3 on Pollution Prevention and Abatement. The World Bank Group EHS Guidelines that may apply to the Marampa Project are listed in Table 3-8. Table 3-7: EHS Guidelines that may be relevant to the Marampa Project Sector Standard or guideline name General EHS General Guidelines Mining and processing EHS Guidelines for Mining EHS Guidelines for Electric Power Transmission and Power plant & distribution Distribution Draft EHS Guideline for Thermal Power Plants Non-mining waste EHS Guidelines for Waste Management Facilities Water supply and sewage EHS Guidelines for Water and Sanitation Facilities 15 The IFC uses the term “social and environmental management plan (ESMP)”. 16 The IFC uses the term “social and environmental management system (SEMS)”. U3823 August 2012 32 Appendix A 3.3 Self regulation in the mining sector In addition to international and national law, there are rules and regulations created by businesses themselves for self-regulation in the business community and for voluntary regulation by individual companies. These exist in the form of business charters, codes of conduct/ ethics/ practice and good-practice guidelines. Those of particular importance to environmental management and sustainable development in the mining sector are identified in this section. The IFC Performance Standards and EHS Guidelines do encourage observance of the codes and guidelines. 3.3.1 United Nations Global Compact and the Global Reporting Initiative The United Nations Global Compact is a corporate governance initiative, launched in July 2000, that aims to mainstream ten principles in business activities around the world and to catalyse actions in support of broader United Nations goals, such as the Millennium Development Goals. The Global Compact's ten principles are derived from: • The 1948 Universal Declaration of Human Rights; • The 1998 Declaration on Fundamental Principles and Rights at Work; • The 1992 Rio Declaration; and • The 2003 United Nations Convention against Corruption (the tenth principle was added to the Global Compact in 2004 in response to this convention). The United Nations Global Compact has been given impetus by the Global Reporting Initiative (GRI). The GRI has established a sustainability reporting framework that sets out the principles and indicators that organizations can use to measure and report their economic, environmental, and social performance. The GRI reporting framework is strongly influenced by the UN Global Compact and is widely used by corporations. GRI reporting by the mining sector is discussed further in Section 3.4.2. On the subject of human rights, the United Nations Global Compact requires that businesses support and respect the protection of internationally proclaimed human rights and make sure that they are not complicit in human rights abuses. 3.3.2 International Council on Mining and Metals Sustainable Development Framework The International Council on Mining and Metals (ICCM) was formed in 2001 to represent the world’s leading companies in the mining and metals industry and to advance their commitment to sustainable development. The ICCM has a Sustainable Development Framework that comprises three elements: a set of ten principles (including a set of supporting position statements); public reporting; and independent assurance (ICCM website, March 2009). The ICMM Sustainable Development Framework has been influenced by: • the 1992 Rio Declaration (Section 3.2.1); • the United Nations Global Compact (Section 3.2.1); • the Global Reporting Initiative (Section 3.2.1); • Voluntary Principles on Security and Human Rights (Section 3.4.3); • the Global Mining Initiative, which was undertaken by nine large mining companies in order to prepare the sector for the World Summit on Sustainable Development (WSSD) in 2002; U3823 August 2012 33 Appendix A • the Mining, Minerals and Sustainable Development (MMSD) project and the MMSD’s Breaking New Ground report, which was published in 2002; and • the World Bank’s Extractive Industries Review (EIR), which was undertaken in 2004 and ended with focus on sustainable development and poverty alleviation. The ten ICCM principles are as follows: 1. Implement and maintain ethical business practices and sound systems of corporate governance; 2. Integrate sustainable development considerations within the corporate decision- making process; 3. Uphold fundamental human rights and respect cultures, customs and values in dealings with employees and others who are affected by our activities; 4. Implement risk management strategies based on valid data and sound science; 5. Seek continual improvement of our health and safety performance; 6. Seek continual improvement of our environmental performance; 7. Contribute to conservation of biodiversity and integrated approaches to land use planning; 8. Facilitate and encourage responsible product design, use, re-use, recycling and disposal of our products; 9. Contribute to the social, economic and institutional development of the communities in which we operate; and 10. Implement effective and transparent engagement, communication and independently verified reporting arrangements with our stakeholders. The principles listed above were first published in May 2003 and have since been complemented with a number of position statements that give greater clarity to the commitments implicit in the principles. ICMM corporate members have to implement the principles and measure their performance against the principles. They also have to undertake public reporting in accordance with the Global Reporting Initiative’s Sustainability Reporting Guidelines and Mining and Metals Sector Supplement (ICCM website, March 2009)17. The ICMM Assurance Procedure, which was approved in May 2008, must be implemented by all ICMM members in relation to their sustainability reports for the financial year ending December 2009 or March 2010 (ICCM website, March 2009). 3.3.3 Voluntary Principles on Security and Human Rights The Voluntary Principles on Security and Human Rights address the negative impacts that company security could have on the human rights of local communities (Voluntary Principles website, March 2009). The principles were launched in the year 2000 and were developed through dialogue between multinational companies in the extractive and energy sectors, 17 The Global Reporting Initiative (GRI) is a sustainability reporting framework that sets out the principles and indicators that organizations can use to measure and report their economic, environmental, and social performance. The GRI reporting framework is strongly influenced by the UN Global Compact and is widely used by corporations. U3823 August 2012 34 Appendix A human rights non-governmental organisations (NGOs) and the United States and British governments. The principles guide companies in maintaining the safety and security of their operations within an operating framework that ensures respect for human rights and fundamental freedoms. A significant number of large multinational companies have now adopted or adhere to the principles (Voluntary Principles website, March 2009). 3.3.4 The Extractive Industry Transparency Initiative The Extractive Industries Transparency Initiative (EITI) aims to increase transparency over payments by companies to governments and government-linked entities, as well as transparency over revenues by those host country governments (EITI website, Voluntary Principles website, March 2009). The United Kingdom’s Department for International Development (DFID) plays an important role in the promotion and coordination on the initiative. To date, no countries have completed EITI validation, although preparations are well advanced in several EITI candidate countries (EITI website, March 2009). EITI supporting companies are those that have endorsed the EITI Principles and Criteria and contribute to implementation in EITI implementing countries. About 40 of the world’s largest oil, gas and mining companies support and actively participate in the EITI process. 3.3.5 Mining and Metals Sector Good Practice website A website called “Good Practice: Sustainable Development in the Mining and Metals Sector” (Good Practice website) has recently been developed by the ICCM, together with the United Nations Conference of Trade and Development (UNCTAD), UNEP and the UK Department for International Development (DFID). This website is intended to provide access to a library of good practice guidelines, standards, case studies, legislation and other relevant material that are leading examples of their kind globally (Good Practice website, March 2009). The target audience for the website is people who are directly and indirectly involved in the design, operation and regulation of mining and metals facilities. The site is intended to support the implementation and effective achievement of the ICMM Sustainable Development Principles. It will also encompass a host of additional issues lying outside the scope of these principles (Good Practice website, March 2009). The Tailings Good Practice website was launched October 2005 by the ICCM and the International Commission on Large Dams (ICOLD). It has been is linked to the broader Good Practice site. It was developed to provide a resource on all aspects of tailings in the context of good practice in the mining and metals sector (Good Practice website, March 2009). The following guidelines are of interest to the Marampa Project: • Good Practice Guidance on HIV/AIDS, TB and Malaria; • Planning for Integrated Mine Closure: Toolkit; • Metals Environmental Risk Assessment Guidance; • Good Practice Guidance for Mining and Biodiversity; • Good Practice in Emergency Preparedness and Response; and • Community Development Toolkit. U3823 August 2012 35 Appendix A 4 REFERENCES ECOLEX, March 2009. ECOLEX is an information service on environmental law, operated jointly by United Nations Environmental Programme (UNEP), the Food and Agriculture organisation of the United Nations (FAO) and the International Union for Conservation of Nature (IUCN). Web address: www.ecolex.org/ . Equator Principles, March 2009. Website on the Equator Principles": A financial industry benchmark for determining, assessing and managing social & environmental risk in project financing, which is maintained by the Equator Principles Financial Institutions. Web address: http://www.equator-principles.com/. Extractive Industries Transparency Initiative (EITI), March 2009. EITI Website maintained by United Kingdom’s Department for International Development (DFID). Web address: http://www.eitransparency.org/node. Food and Agriculture Organization (FAO) of the United Nations. 2006. Land tenure, food security and investment in postwar Sierra Leone. Good Practice website, March 2009. Good Practice: Sustainable Development in the Mining and Metals Sector website. Developed by the International Council on Mining and Metals (ICMM), together with the United Nations Conference of Trade and Development (UNCTAD), the United Nations Environment Programme (UNEP), and the UK Department for International Development (DfID). Web address: http://www.goodpracticemining.org/index.php. IFC, March 2009. Websites on the IFC Performance Standards on Social and Environmental Sustainability and the World Bank Group Environmental, Health and Safety Standards. Web addresses: http://www.ifc.org/ifcext/sustainability.nsf/Content/PerformanceStandards and ; http://www.ifc.org/ifcext/sustainability.nsf/Content/EnvironmentalGuidelines. ILOLEX, March 2009. ILOLEX is a database containing ILO Conventions and Recommendations and numerous related documents. Web address: http://www.ilo.org/ilolex/english/docs/. International Council on Mining and Metals (ICCM), March 2009. ICCM website. Web address: http://www.icmm.com/. International Finance Corporation (IFC), March 2006. A Guide to Biodiversity for the Private Sector: The Social and Environmental Impact Assessment Process. Web address: http://www.ifc.org/ifcext/sustainability.nsf/AttachmentsByTitle/BiodivGuide_ESIA/$FILE/ESIA. pdf International Labour Organisation (ILO). August 2008. ILO website. Web addresses: http://www.ilo.org/ilolex/; http://www.ilo.org/dyn/declaris/DECLARATIONWEB.INDEXPAGE; http://www.ilo.org/global/About_the_ILO/Mission_and_objectives/lang--en/index.htm; http://www.ilo.org/global/About_the_ILO/Mainpillars/Therightsatwork/lang--en/index.htm; and http://www.ilo.org/dyn/declaris/DECLARATIONWEB.ABOUTDECLARATIONHOME?var_lan guage=EN. U3823 August 2012 36 Appendix A Ministry of Energy and Power (MEP). 2008. The Republic of Sierra Leone National Water and Sanitation Policy, August 2008). Ministry of Lands, Country Planning and the Environment (MLCPE). 1999 and 2002. The Republic of Sierra Leone EIA Procedures. Freetown. Ministry of Mineral Resources (MMR). 2005. Details of Policy Measures Relating to Small- Scale and Artisanal Mining and Marketing of Precious Minerals. Sierra Leone Information System (SLIS). 2009. Sierra Leone Encylopedia 2008. The Sierra Leone Encyclopedia is a core project of the SLIS positioned under Development Assistance Coordination Office (DACO). The Encyclopedia 2008 of Sierra Leone is a joint United Nations and Government of Sierra Leone effort. Web address: http://www.daco- sl.org/encyclopedia/ United Nations Environmental Programme (UNEP), 2005. Training Manual on International Environmental Law. Edited by L Kurukulasuriya of UNEP and N A Robinson of Pace University School of Law on behalf of the International Union for Conservation of Nature (IUCN) Academy of Environmental Law. http://www.unep.org/law/PDF/law_training_Manual.pdf. United Nations Global Compact, March 2009. Website of the United Nations Global Compact. Web address: http://www.unglobalcompact.org/. United Nations Treaty Series, March 2009. Web addresses: http://untreaty.un.org/ and http://treaties.un.org/Pages/ParticipationStatus.aspx. United Nations, March 2009. Website of the United Nations Permanent Forum on Indigenous Issues. Web address: http://www.un.org/esa/socdev/unpfii/. University of Sierra Leone. 2008. Mineral Sector Technical Assistance Project (MTAP) Environmental and Social Impact Assessment (ESIA) Study. Undertaken on behalf of the Government of the Republic of Sierra Leone/ Ministry of Mineral Resources (MMR) and the World Bank, by ET Ndomahina (Consultant) of the Institute of Marine Biology and Oceanography, Fourah Bay College. Voluntary Principles, March 2009. Website on the Voluntary Principles on Security and Human Rights, which is maintained by the International Business Leaders Forum and Business for Social Responsibility. Web address: http://www.voluntaryprinciples.org/ U3823 August 2012 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix B APPENDIX B B SLEPA APPLICATION FORM AND SUPPORTING CORRESPONDENCE U3823_Marampa_ESIS_Final.docx September 2012 Page B1 of B1 17 August 2010 Ref: MP.20.10.01.02 – 02 Mr Momodu A. Bah - Acting Deputy Director, Sierra Leone Environmental Protection Agency 3rd Floor, Youyi Building, Brookfields Freetown, Sierra Leone Dear Mr Bah, Ref: Marampa Iron Ore Project Submission of Environmental Impact Assessment Application and Screening Forms Marampa Iron Ore (SL) Limited (Company) submits with this letter the Environmental Impact Assessment (EIA) application and screening forms for the Marampa Iron Ore Project (Project), for categorisation of the Project according to Sierra Leone EIA Regulations. It should be noted that the Project is at a very early stage and many studies are still required before the Company can determine whether development of the Project will be technically and economically feasible. The Company acknowledges the importance of obtaining environmental and social baseline information, however, and therefore wishes to initiate these studies at an early stage. Due to the early stage of the Project, only limited information regarding certain aspects of the topics covered in the screening form is available at this time. However, the Company trusts that sufficient information has been provided for the Sierra Leone Environment Protection Agency (SLEPA) to categorise the Project. In accordance with the Environmental Protection Agency Act, 2008, the Company understands that should a full EIA be required for the Project then the Government’s EIA Working Group would have the responsibility of defining the Terms of Reference (ToR) for the Environmental and Social Impact Study. If this was the case, then the Company offers to submit a draft ToR, based on the requirements for similar projects, for consideration, review and use by the Working Group. We look forward to your response to the screening form and categorisation of the Project. Should you have any queries, or require further information, then please do not hesitate to contact the undersigned. Yours sincerely, Marampa Iron Ore (SL) Limited Chris Gbyl Country Manager Encl. : Environmental Impact Assessment Application Form : Environmental Impact Assessment Screening Form J 49 Spur Road, Lumley, Freetown Marampa Iron Ore Project – EIA Application Form August 2010 APPLICATION FORM FOR AN ENVIRONMENTAL IMPACT ASSESSMENT (EIA) LICENCE 1. Name of Institution / Company: Marampa Iron Ore (SL) Limited 2. Type of Business Mining Exploration 3. Business Registration No. CF/175/2007 4. Contact Address 49J Spur Rd Lumley, Freetown 5. Nationality Sierra Leonne 6. Proposed Development Marampa Iron Ore Project 7. Proposed Location In vicinity of Lunsar Townsite, Port Loko District, Sierra Leone. 8. Cost of Proposal USD 500 Million 9. Estimated Duration for Development Activities 3 years 10. State the Impact of Activities on the Following: Tick the Appropriate Columns POSITIVE NEGATIVE a) Substantial Impact on √ Ecosystem of the locality b) Social √ c) Aesthetic √ d) Scientific √ e) Historical √ f) State Other: √ The Project provides a positive social impact not only on the immediate locality but also surrounding areas due to the hiring of employees, and the use of suppliers and contractors from other areas within Sierra Leone. File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA Corresp\SLEPA EIA Application Form_v1.docx SRK Consulting Marampa Iron Ore Project – EIA Screening Form August 2010 ENVIRONMENTAL IMPACT ASSESSMENT SCREENING FORM SECTION 1: INFORMATION ON THE CONTACT PERSON Name: Chris Gbyl Institutional Affiliation: Marampa Iron Ore (SL) Limited Business Title / Position: Country Manager Telephone: + 232 (0) 33 294188 Email: Chris.Gbyl@miolb.com SECTION 2: DESCRIPTION OF THE INDUSTRY/FACTORY/COMPANY/PROJECT AND OR PROPOSED PROJECT Due to the early stage of Project development, the information provided by Marampa Iron Ore (SL) Ltd in this form is preliminary and is subject to change throughout Project development. Name: Marampa Iron Ore Project (the Project) Date operations started: Construction of the Project is subject to technical and economic studies and is not expected to commence before 2012. Location of establishment The Project is located 90 km northeast of Freetown near the town of and/or Project: Lunsar in the Port Loko District (Figure 1) Location of proposed See above project: Land area: The total land area to be disturbed by the Project has not yet been determined due to the early stage of Project development. The current 2 exploration licence area EXPL09/06 covers 305 km however the Project will not cover this entire area. At present, Marampa Iron Ore (SL) Ltd (the Company) has identified three areas that may be affected by the Project (Figure 2). Area 1 has been identified as a potential infrastructure location and Areas 2 and 3 have been identified as potential mining areas. These three areas represent the environmental and social “area of interest” at this stage of the Project and cover a 2 total of 30.4 km . Attach a map or maps covering the proposed site and surrounding 5 km radius Figure 1 shows the general location of the Project and Figure 2 shows the three environmental and social areas of interest. CURRENT LAND USE Describe how the land is being used at present The area of interest is a mosaic of cleared areas or secondary growth, interspersed with floodplain subsistence cultivation along river courses, isolated settlements and small areas of palm plantations. The crops grown within the floodplains include cassava, ground nut, rice and potato, and are largely for subsistence use. Small villages and minor roads and tracks occur within the area of interest but there are no other major commercial or industrial operations within the boundaries of the area of interest. Describe any possible alternative site(s) The location of the mining operations is determined by underlying geology therefore no alternative sites are possible. The infrastructure location is determined by its proximity to the existing railway line. File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA Corresp\SLEPA Screening Form_v4.docx SRK Consulting Marampa Iron Ore Project – EIA Screening Form August 2010 Describe other types of industries or facilities (including health centers and schools), which are located within 100 metres of the site, or are proposed to be located near the facility. Indicate the proximity of the industrial, factory or project site and or proposed site to residential areas, national parks or areas of ecological, historical or cultural importance. There are no industries or facilities located within 100 m of the area of interest. The area of interest is located near the town of Lunsar which has a population of 23,387 according to the 2008 census. Lunsar has approximately 10 primary schools, 8 secondary schools and two hospitals. There is no sanitation system in the town and water is either obtained from groundwater wells or surface water sources such as the Rokel River. 2 The area of interest is located adjacent to a 10 km mining licence area (ML02/05) held by London Mining (Figure 2). The London Mining lease is located within 100 m of the boundary of the area of interest however the Company will not carry out activities within the London Mining lease. The area of interest includes small villages, mostly within the Masimera and Marampa chiefdoms. The houses in the villages are largely made out of mud with palm leaf or corrugated iron roofs. Most villages have a hand-pump well for water supply but do not have a formal drainage system. Some villages contain small schools which service the children of the local communities. It is currently understood that there are no sites of ecological or cultural importance located within 100 m of the area of interest, with the exception of society bush, however this assumption will be confirmed during the Environmental Impact Assessment (EIA). There are no protected areas located within EXPL09/06, although there is a forest reserve 20 km to the east of the exploration licence area. Indicate whether adequate infrastructure exists at the location and/or proposed location and whether old or new buildings, roads, electricity and water lines or drainage systems exist at the location and/or proposed site. New Project-specific infrastructure will be built at the site; including a processing plant, on-site power generator and distribution network, water storage and supply infrastructure, storm water systems, waste management facilities, site haulage roads, auxiliary buildings and an accommodation camp. SECTION 3: EMPLOYEES AND LABOURERS Number of people employed: At this stage in the planning of the Project, there is no exact indication of the number of people to be employed throughout the life of the Project. Numbers will vary between the different Project phases; operation employment requirements are potentially to be more than 500. Employees and labourers During Construction During Operation Full Time 300+ 500+ Part Time Unknown at present Unknown at present Indicate whether you have or plan to construct housing / sanitation facilities for temporary or permanent workers An on-site accommodation camp will be provided for non local staff during work periods and a temporary construction camp may also be required during the construction phase of the Project. The camps will include appropriate sewerage treatment and waste management systems though details of these are not yet available. File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA Corresp\SLEPA Screening Form_v4.docx SRK Consulting Marampa Iron Ore Project – EIA Screening Form August 2010 SECTION 4: DESCRIPTION OF INDUSTRIAL PROCESS Briefly describe the type and nature of industrial processes at the installation and / or proposed installation. The Project will include open pit mining of specular hematite (iron ore) and on-site beneficiation including crushing, grinding, and concentrate cleaning via wet high-intensity magnetic separation. State the type and quantity of energy used (including the origin of the energy i.e. public utility, on site generator, wood, solar, wind etc.) Type (s) Quantity Period (per day/week etc.) On-site generator Unknown at present but the generator will be Power requirements will be (large) designed to provide all Project power continual but Project will requirements aim to be self-sufficient Estimate the quantity of water used Use(s) of water Quantity Period Source Cooling None NA NA Steam generation None NA NA 3 Production process ~10,000 m per day Continuous Unknown (possibly Rokel Other (e.g. potable River and reclaim from water, dust Unknown Continuous tailings facility and suppression, vehicle dewatered pits) washing) List the type and quantity of raw material(s) used per year in the production process (including soil, sand, cement, aggregates, wood, animals etc). Identify the source(s) of raw material(s) Type (s) Quantity Source Large quantities of raw materials will be required for the construction and operation of the Project although at this stage of the Project, details regarding the quantities and source of the raw materials have not been determined. Materials will be sourced from local suppliers where feasible. List all of the chemical(s) used in the production process or expected to be used for any aspect of the production process (a separate list may be attached with more detailed information). Type (s) Description Quantity At this stage of the project, specific chemicals and quantities required have not been identified however as the beneficiation process is mainly physical, so use of toxic chemicals are unlikely. Possible chemicals that may be required include explosives, lubricants, dust control agents and water treatment chemicals File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA Corresp\SLEPA Screening Form_v4.docx SRK Consulting Marampa Iron Ore Project – EIA Screening Form August 2010 SECTION 5: PRODUCTS Briefly state the nature of the product(s) or output of the facility and or proposed facility, and the expected quantities on a quarterly or annual basis. Indicate the use and or intended use of the product(s). Name Description of uses Output Iron concentrate Steel production (by third parties outside 5 Mtpa concentrate (~65% Fe) Sierra Leone) SECTION 6: BY PRODUCTS, WASTE MANAGEMENT AND DISPOSAL Specify the nature of each waste or by-product and the quantity generated or to be generated. Type (s) Description Quantity in 1g per weeks Solid (bulk) Waste rock from mining process 20 Mtpa Tailings from concentrator 10 Mtpa Solid particulate Dust and blasting fumes Unknown at present Liquid Unknown at present (dependent on Unknown at present processing activities) Gaseous Haulage vehicle emissions Unknown at present Generator emissions State the method of disposal or management (e.g. dump site, burning, bury etc) Details of waste management strategies have not yet been developed, however all hazardous and non-hazardous wastes will be collected, transported, processed, recycled or disposed of in a manner that meets national requirements and good international industry practice. Type of waste Method of disposal/management Waste rock Waste stockpiles located adjacent to pits Tailings Within a facility consisting of rock wall embankments Non hazardous Recycled, incinerated or landfill Options for disposal and management of hazardous waste have not yet Hazardous been determined but measures will meet national requirements and good international industry practice Indicate the sources of noise pollution, the type / quality of noise (i.e. machinery / repetitive pounding etc) Sources of noise Type of noise Mining Drilling, blasting, heavy vehicles Processing Crushing and grinding On-site generators Engine noise File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA Corresp\SLEPA Screening Form_v4.docx SRK Consulting Marampa Iron Ore Project – EIA Screening Form August 2010 SECTION 7: ENVIRONMENTAL IMPACTS Please indicate environmental impact (s) that may occur as a result of the factory / industrial process and or the process of proposed project. The potential impacts of the Marampa Project have been identified at a preliminary level in the following table. The impacts were identified through consideration of limited information on the Project, its environmental and social setting and taking account previous experience gained on similar projects. The impact assessment will evaluate if these potential impacts are likely to occur and if so, to what extent. This list of impacts may change during the period of Project development and the ESIA will evaluate new impacts identified. Nature of Brief description of the anticipated impacts impact Modification of land by mining activities and infrastructure limiting use by local communities Land Disturbance of transport routes by Project infrastructure affecting local communities transformation Mining activities and infrastructure causing visual intrusion leading to loss of sense of and place for local communities landscape Disturbance to sites considered to be of archaeological, historic or cultural importance by local communities Surface erosion by wind and water leading to degradation and/or loss of soil resulting Soil in reduced land capability Uncontrolled or accidental discharges leading to deterioration of soil quality Release of fugitive dust and particulate emissions leading to increase in background particulate concentrations creating nuisance or health risks to local communities Release of gaseous emissions (SO , NO and Volatile Organic Compounds) leading Air Quality 2 x to increases in background gaseous concentrations causing potential health effects to local communities Release of greenhouse gas emissions contributing to increasing global greenhouse gas concentrations Diversion of surface water drainage channels resulting in changes to water availability for downstream users and ecosystems Abstraction of water for the mine resulting in reduced availability of water to other water users Dewatering of the mine workings leading to reduced availability of water to other water users Surface Water Discharges from the Project during storm events leading to contamination of local waterways resulting in water quality impacts downstream of the mine site Deteriorated water quality in mine water holding facilities posing risks to people and wildlife Mobilisation of soils due to erosion process leading to sedimentation of local waterways potentially affecting site drainage, aquatic fauna and downstream water users Seepage from mine and mineral-processing residue disposal facilities or tailings storage facility or waste rock dump failure (e.g. due to liner leakage) leading to contamination of groundwater aquifer impacting downgradient water users Groundwater Mine consumption and dewatering leading to reduction in available groundwater to downgradient users Potential pit lake formation following closure of mine and possible impact of pit lake water on the downstream groundwater quality Noise and Project activities resulting in unacceptable increases in background noise levels for vibrations local communities Blasting leading to vibration disturbance to local communities File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA Corresp\SLEPA Screening Form_v4.docx SRK Consulting Marampa Iron Ore Project – EIA Screening Form August 2010 Nature of Brief description of the anticipated impacts impact Land disturbance leading to loss of habitat and individuals. Ecology Habitat disturbance and animal displacement due to mining activities and vehicles resulting in changes to biodiversity. Displacement of natural fauna due to disturbance from mining activities and vehicles Direct and indirect employment, training and business opportunities and training, leading to improved economy Social investment leading to improved infrastructure and quality of life Influx of job seekers and mine related activities increasing pressure on local resources and services and demographic changes leading to changes in community Socio- health economic Sudden decrease in demand for workers and services, after completion of construction phase, leading to increase in unemployment and slowing down of local economy Retrenchment at end of construction phase and mine closure leading to loss of employment, income and slowing down of economy Loss of land leading to loss of income and livelihood opportunities, relocation of households or villages leading to long term poverty Hazardous Exposure to fly rock, slope failure of the tailings dam or waste rock dumps, explosion incidents or fire, petrochemical spills, vehicle accidents. SECTION 8: PROPOSED MITIGATION MEASURES Indicate the measures(s) employed to mitigate against damage likely to be caused by the factory / industrial process and / or proposed project to humans and /or the environment. At this stage of the Project, only a preliminary identification of potential environmental and social impacts has been undertaken. As baseline studies and impact assessments have not been carried out, the potential risks/impacts cannot be quantified, therefore mitigation measures have not been proposed at this stage, however these types of impacts are typical for mining projects and considered manageable. Following the findings of the impact assessment, specific mitigation and management measures will be included as part of an Environmental and Social Management System (ESMS) in the final EIA report and will be in accordance with IFC Performance Standards and World Bank Environmental, Health and Safety Guidelines for Mining. State any and all experience you have with implementing the above mentioned mitigation measure(s). If you do not have prior experience, what skill (s) do you possess to implement these mitigation measures? The Company’s management has considerable experience in managing and operating mining operations similar to that proposed for the Project. The EIA will be conducted by environmental consulting firm SRK Consulting (SRK). SRK has considerable experience in conducting EIA processes globally across all regions of the world. A list of recent environmental and social projects conducted by SRK Consulting (UK) is attached which involved the development and implementation of mitigation and management measures for large mining operations. What staff training is provided or will be provided to ensure compliance with health and environmental safety standards? Training on health, safety and environmental issues will be provided by the Company to ensure that all activities associated with the Project are undertaken in accordance with national requirements and good international industry practice. Health, safety and environmental training will be compulsory for all employees, prior to commencing any work. File Ref: P:\U3823 Marampa Iron Ore (Env)\Project\Final Report\Volume 2 ESIS Inc Tech Appendices\Appendix B - SLEPA Corresp\SLEPA Screening Form_v4.docx Selected Environmental and Social Projects Project Client Timing Country Description Name Environmental and Social scanning study. Approval for Scoping phase of ESIA process, Kiaka Volta Resources 2010 – Burkina as well as installation of meteorological Ongoing Faso station and monitoring system with a preliminary scoping of water resources and surface water hydrology. 2009 - Environmental and social input compliant to Thar Coal Engro Power ongoing Pakistan host country and international standards into the feasibilty study for a open cast coal mine. Environmental and Social Impact Bozshakol Kazakhmys 2008- Kazakhstan Assessment for a copper project conforming ESIA ongoing to EP/PS, host country requirements and owner standards. Input to pre-feasibility. Tethyan Copper Environmental and Social Impact Reko Diq Company 2007- Assessment for a copper/gold project ESIA (Barrick/Antofogast Ongoing Pakistan conforming to EP/PS, host country JV) requirements and owner standards. Input to pre-feasibility and feasibility studies. Environmental and Social Impact CJSC Fedorovo 2007- Assessment for a nickel/PGM project Fedorovo (Barrick) ongoing Russia conforming to EP/PS, host country requirements and Barrick Standards. Input to pre-feasibility and feasibility studies. Nimba Development of plan of study for Mountains SMFG (Rio environmental and social impact assessment Concept Tinto/Newmont JV) 2007 Guinea for an iron ore project to conform with EP/PS Study and BHP Billiton/Newmont Standards as input to project development Concept Study. Corantijn NV BHP Billiton River Maatschappij 2007 - Suriname Environmental and social impact assessment Dredging Suriname 2008 process of river dredging project. Project ESIA (BHP Billiton) Suriname NV BHP Billiton Environmental and Social Impact River Maatschappij 2006-2008 Suriname Assessment conforming to EP/PS and BHP Dredging Suriname Billiton Standards. ESIA (BHP Billiton) Ghurayyah Tertiary (Middle East) Environmental and social impact assessment Scoping Ltd 2006-2007 Saudi Arabia and input into pre-feasibility study. Study Environmental and social impact assessment Malmbjerg International 2005-2007 Greenland and input into Feasibility Study for a ESIA Molybdenum plc molybdenum project to meet Greenlandic requirements. Voskhod Environmental and Social Impact ESIA Oriel Resources Plc 2006-2007 Kazakhstan Assessment to comply with EP/PS undertaken in parallel with feasibility study. Bulghah Bulghah ESIA Environmental and social impact ESIA (Ma'Aden) 2005-2007 Saudi Arabia assessment. (Ma'Aden) NV BHP Billiton Environmental and Social Impact Bakhuis Maatschappij 2006- Assessment conforming to EP/PS and BHP Transport Suriname Ongoing Suriname Billiton Standards for the transport and ESIA (BHP Billiton) processing aspects of Bakhuis bauxite project. Adastra/Congo Equator Principles standard environmental Kolwezi EIA Mineral 2004-2005 DRC and social Impact assessment for a tailing Developments reprocessing project. Limited (CMD) SECTION 9: TESTIMONY I confirm that the information provided herein is accurate to the best of my knowledge. I will also endeavour to provide additional information and facilitate a site visit if required. For Official Use Only Reviewed by: Date: Classified A B C Reasons for the classification: Endorsed by: Date: Approved by Director: Date: SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix C APPENDIX C C STAKEHOLDER ENGAGEMENT PLAN U3823_Marampa_ESIS_Final.docx September 2012 Page C1 of C1 MARAMPA IRON ORE PROJECT: STAKEHOLDER ENGAGEMENT PLAN FOR THE ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT Prepared For MARAMPA IRON ORE (S.L.) 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Date: August, 2012 Project Number: UK3823 SRK Project Director Fiona Cessford Corporate Consultant (Environmental) and Project Manager: Client Legal Entity: Marampa Iron Ore Ltd Client Address: Victoria Place 31 Victoria Street Hamilton Bermuda HM10 U3823_Marampa_SEP_Final.docx August, 2012 SRK Consulting (UK) Limited 5th Floor Churchill House 17 Churchill Way City and County of Cardiff CF10 2HH, Wales United Kingdom E-mail: enquiries@srk.co.uk URL: www.srk.co.uk Tel: + 44 (0) 2920 348 150 Fax: + 44 (0) 2920 348 199 MARAMPA IRON ORE PROJECT: STAKEHOLDER ENGAGEMENT PLAN FOR THE ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT – EXECUTIVE SUMMARY SRK Consulting (UK) Limited (SRK) has been appointed by Marampa Iron Ore (SL) Limited (MIOL) to undertake an Environmental and Social Impact Assessment (ESIA) for the proposed Marampa Iron Ore Project (the Project) in Sierra Leone. This document presents the Stakeholder Engagement Plan (SEP) used to guide the process of information disclosure and stakeholder consultations during the environmental and social assessment studies. The SEP is a dynamic document that will be updated at different stages of the Project. The consultation programme outlined in this SEP is based on the requirements of the Sierra Leone national legislation and where practical, the International Finance Corporation (IFC) performance standards. The specific objectives of this SEP are to: • provide an identification and analysis of potential Project stakeholders; • describe relevant Sierra Leone legal requirements and international standards; • document the community engagement process to date; • describe the methodology used for consulting with relevant key stakeholders and document their feedback; and • propose the grievance mechanism. Based on a visit to the Project site, assessment of the potential Project footprint area and meetings with government agencies, SRK compiled a list of potential Project stakeholders and analysed their interest in and influence on the Project. The stakeholders are categorised as: government authorities, residents of the villages around the mine site, community based organisations, non government organisations and other civil society groups. The stakeholder consultations comprised: • meetings with SLEPA and other relevant ministries to notify formal start of the ESIA process and understand their expectations; and • formal scoping meetings with local communities and other stakeholders to record their concerns and expectations. The approach to the consultation and disclosure activities undertaken in support of the ESIA process followed the commonly accepted international principles to maximise participation of all sections of the society including any marginalised groups. The outcomes of the meetings are summarised in the form of list of stakeholder issues and expectations which were; • Local people/youth (born in the area) and land owners should be involved in the employment and development process to avoid conflict. • Concerns over the decline in people working in agricultural production reducing the availability of farm workers and increasing pressure on food resources. Group Offices: Africa Registered Address: 21 Gold Tops, City and County of Newport, NP20 4PG, Asia Wales, United Kingdom. Australia SRK Consulting (UK) Limited Reg No 01575403 (England and Wales) Europe North America South America SRK Consulting Marampa Iron Ore Project –Executive Summary • Women must be considered for employment and child labour be avoided. • Apprehensions about noise pollution, air pollution, flora and fauna biodiversity loss. How will MIOL mitigate these issues? • Apprehension about depletion of water table, which needs to be addressed. • Concern over the inappropriate disposal of tailings. • MIOL should develop tangible structures instead of just giving out money. • Preference towards local businesses and shops for purchase of provisions and supplies. • Resettlement is a key issue and MIOL must do this sensitively and properly where they should buy land and build houses for them. • The authority of Paramount Chiefs is now declining MIOL and should not rely on them too much. The Company should identify other leaders and communicate directly with community members. Dialogue with the community should be sustained • The Community Liaison Officer (CLO) will be the key person for community outreach. • MIOL should hold monthly meetings with the community. • What will MIOL do about tailing storage facilities? • Landowners should be treated fairly whereby they receive the true money value of their land. • The rehabilitation of mined out areas is very crucial for the sustainability in agriculture. • Concerns over the effect of air pollution and dust from vehicles will have on human health • Concerns over heavy machines shaking nearby houses and blasting activity damaging their houses as structures are weak. • Concerns over increases in accidents due to an increase in traffic and the safety of people when crossing railways and roads. • Toilet facilities and clean water supply should be provided. Future stakeholder consultations on completion of the ESIA report (in the form of an Environmental and Social Impact Statement or ESIS) will comprise of: • feedback consultations to update the stakeholders on predicted impacts and proposed mitigation measures; and • a public hearing meeting by SLEPA to assess public opinion on the Project. For managing community relations MIOL will need a mechanism for effective and speedy resolution of stakeholder complaints and problems and also to provide a satisfactory response to their queries and issues on an ongoing basis. The mechanism will be developed in consultation with stakeholders for transparency. U3823_Marampa_SEP_Final.docx August, 2012 Page ii of ii SRK Consulting Marampa Iron Ore Project – Table of Contents Table of Contents 1 INTRODUCTION ................................................................................................. 1 1.1 Project background .................................................................................................................. 1 1.2 Structure of the document ....................................................................................................... 3 2 PROJECT DESCRIPTION .................................................................................. 3 3 REGULATORY REQUIREMENTS AND GUIDELINES ...................................... 6 3.1 Sierra Leone national policy guidelines ................................................................................... 6 3.1.1 Environmental Protection Agency Act, 2008 ................................................................. 6 3.1.2 Mines and Minerals Act, 2009 ....................................................................................... 6 3.2 International standards and guidelines .................................................................................... 6 4 PURPOSE OF THE SEP ..................................................................................... 8 4.1 Overview of Marampa consultation process ............................................................................ 8 5 PROJECT STAKEHOLDERS ........................................................................... 10 6 SUMMARY OF PREVIOUS CONSULTATIONS ............................................... 17 6.1 Initial community engagement by MIOL ................................................................................ 17 6.2 Scoping consultations with key government ministries ......................................................... 17 6.3 Scoping consultations with various stakeholders groups (March 2011) ............................... 18 6.3.1 Methodology used for consultation and disclosure activities ...................................... 18 6.3.2 List of stakeholders consulted ..................................................................................... 20 6.3.3 Outcomes of the consultation meetings ...................................................................... 21 7 FUTURE CONSULTATIONS............................................................................. 22 7.1.1 Consultations beyond the ESIA process ..................................................................... 23 8 GRIEVANCE MECHANISM............................................................................... 23 9 REFERENCES .................................................................................................. 23 GLOSSARY OF TERMS ............................................................................................. I ACRONYMS .............................................................................................................. II List of Tables Table 3-1: IFC Performance Standards: key principles for undertaking public consultations ................ 7 Table 5-1: Identification and analysis of stakeholders/ groups ............................................................. 11 Table 6-1: MIOL’s meetings with the communities in 2010 .................................................................. 17 Table 6-2: Summary of stakeholder meetings held in July 2010 .......................................................... 18 Table 6-3: Stakeholder consultation methods used .............................................................................. 19 Table 6-4: Meetings with various stakeholder groups in March 2011 .................................................. 20 List of Figures Figure 1-1: Location of the exploration area ........................................................................................... 2 Figure 2-1: Location of proposed Project infrastructure relative to local villages ................................... 5 Figure 4-1: Marampa ESIA stakeholder engagement process ............................................................... 9 U3823_Marampa_SEP_Final.docx August, 2012 Page i of ii SRK Consulting Marampa Iron Ore Project – Table of Contents List of Technical Appendices 1. STAKEHOLDER DETAILS ................................................................................ 1I 2. MEETING MINUTES .......................................................................................... 2I 3. DISCLOSURE MATERIAL ................................................................................. 3I 4. PHOTOS ............................................................................................................. 4I 5. ISSUES AND RESPONSE RECORD ................................................................. 5I U3823_Marampa_SEP_Final.docx August, 2012 Page ii of ii SRK Consulting (UK) Limited 5th Floor Churchill House 17 Churchill Way City and County of Cardiff CF10 2HH, Wales United Kingdom E-mail: enquiries@srk.co.uk URL: www.srk.co.uk Tel: + 44 (0) 2920 348 150 Fax: + 44 (0) 2920 348 199 MARAMPA IRON ORE PROJECT: STAKEHOLDER ENGAGEMENT PLAN FOR THE ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT 1 INTRODUCTION SRK Consulting (UK) Limited (“SRK”) has been appointed by Marampa Iron Ore (SL) Limited (MIOL) to undertake the Environmental and Social Impact Assessment (ESIA) for the proposed Marampa Iron Ore Project (the Project) located in Sierra Leone. This document presents the Stakeholder Engagement Plan (SEP), required as part of the above study, to guide the process of information disclosure and stakeholder consultations during the ESIA process. The SEP is a dynamic document that will be updated at different stages of the Project. This version of the SEP presents the findings and methodology of the stakeholder consultations undertaken during the scoping phase of the ESIA process and its outcomes. It also provides the plan for further consultations as part of the ESIA process. 1.1 Project background The Lunsar area was the focus of significant mining operations run by DELCO between 1933 and 1975. This mining operation, which is located within ML02/05, mined both the lateritic cap from Masaboin and Gafal Hills, and the underlying specular hematite schists. The specular hematite was concentrated by crushing, coarse grinding and gravity separation, with production reaching approximately 2.5 million tonnes per annum (“Mtpa”) of concentrate in the late 1960s (Cape Lambert, 2009). DELCO constructed a railway and port loading facility at Pepel Port for transport of the product to worldwide markets. During the DELCO period of operation, a large community and related infrastructure was established, which included hospitals, schools, community halls and sports facilities for use by employees and the local community. The health centre was a recognised training centre for student nurses and an apprentice scheme for young men was also established. The Delco mining operation closed in 1975, following a drop in iron ore prices, resulting in significant job losses. Smaller-scale operations started up again in 1981, which involved dredging of the tailings by Austrian company, Austromineral GMBH. This operation was abandoned in 1985 due to increasing production costs. Recent exploration by MIOL, within its Exploration Licences EL46/2011-A and EL46/2011-B (Figure 1-1), has identified six priority areas and is currently focussing on the development of the Gafal, Rotret, Mafuri and Matukia Prospects for the current ESIA and mining licence application. Group Offices: Africa Registered Address: 21 Gold Tops, City and County of Newport, NP20 4PG, Asia Wales, United Kingdom. Australia SRK Consulting (UK) Limited Reg No 01575403 (England and Wales) Europe North America South America SRK Consulting Marmpa Iron Ore Project – ESIA SEP Figure 1-1: Location of the exploration area File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 2 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP 1.2 Structure of the document This document consists of the following sections: • Section 1: introduction and background to the Project; • Section 2: Project description; • Section 4: regulatory requirements and guidelines; • Section 3: purpose and scope of the SEP; • Section 5: potential Project stakeholders’; • Section 6: consultations undertaken to date; • Section 7: future consultations; and • Section 8: grievance mechanism. 2 PROJECT DESCRIPTION The Company has completed initial exploration drilling of specular hematite deposits at the Gafal, Rotret, Mafuri and Matukia Prospects. A preliminary mining scoping study conducted by Bateman Engineering Pty Ltd (“Bateman”) concluded that mining at a capacity of up to 15Mtpa is technically feasible, and financial estimates to date are positive. The Project Mineral Resource is estimated at 680 million tonnes with an in-situ grade of 28.2% Fe (15% Fe cut-off grade) and, with processing, could generate a high quality saleable iron concentrate (~65% Fe), with low levels of deleterious elements. 1 The Project involves the construction of facilities and infrastructure to produce up to 15 Mtpa of iron concentrate. This will be done in two stages. Stage 1 will involve the construction of facilities to produce 2.5 Mtpa of iron concentrate through the mining of oxide ore only. Stage 2 (an extension to Stage 1) involves expanding these facilities, and the construction of additional facilities, to enable the production of a total of up to 15 Mtpa of iron concentrate through the mining of oxide and/or fresh ore. While the development plan of Stage 2 of the Project is reasonably known at this time, it will be the subject of a detailed feasibility study moving forward. Access to existing rail and port infrastructure, which was recently upgraded and returned to operation by African Minerals Limited (AML), offers the advantage of lower capital investment start-up costs and Project lead time, as well as significant environmental advantages, as opposed to construction of a new port and rail. Open pit mining is the preferred mineral extraction method, further reducing capital development costs. The main Project components included in this ESIA and indicated relative to the local villages on Figure 2-1 are listed below: • Four open pits (Matukia, Gafal, Rotret and Mafuri) and four associated waste rock dumps (“WRD”) • Run of mine (“ROM”) and low grade stockpiles • Beneficiation plant, comprising: − crushing; − stockpiling; − ore reclamation; 1 It should be noted that references to concentrate production rates refer to dry metric tonnes. The moisture content of the product may range between 8-10%, which will increase the actual tonnage of concentrate produced, transported and exported accordingly (wet metric tonnes). File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 3 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP o scrubbing / grinding; o rougher / scavenger magnetic separation; o rougher / scavenger concentrate regrind; o cleaner and recleaner magnetic separation; o concentrate thickening and filtration; o tailings thickening; o reagent storage and use; and o supporting utilities. • Tailings storage facility (“TSF”) • Power generation and distribution facilities • Water supply facilities • Stormwater management facilities • Waste water management systems • Communications systems • Accommodation • Medical and emergency services • Utilities (potable water supply, fire water system, air compressor systems) • Mobile equipment (vehicles etc) • Buildings for storage, offices, workshop, laboratory, etc • A rail spur and head, connecting to the existing Pepel railway line • Use of existing road routes for transport of supplies to the mine (including the existing Makeni Highway, connecting Freetown to Lunsar) and some new on-site roads to connect Project infrastructure File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 4 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP Figure 2-1: Location of proposed Project infrastructure relative to local villages File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 5 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP 3 REGULATORY REQUIREMENTS AND GUIDELINES This section describes both Sierra Leone requirements and international guidelines for conducting stakeholder consultation and disclosure activities during the ESIA process and throughout Project operation. 3.1 Sierra Leone national policy guidelines Current Sierra Leone legislation most relevant to the ESIA process is: • the Environment Protection Agency Act No. 11 of 2008 (EPA Act 2008); and • the Mines and Minerals Act 2009. Each of these is briefly described in the sections below. 3.1.1 Environmental Protection Agency Act, 2008 The EPA Act 2008,, Sections 27 (1) and (2) stipulate the procedure for release of the ESIA report to the public for review and invites their comments. It includes: • circulation of the ESIA report to professional bodies or associations, Government Ministries and non-government organisations by SLEPA; • notice by SLEPA in two consecutive issues of the Gazette to open the ESIA report for public inspection and comments; and • notice by the Company in two issues of newspapers, with an interval of seven days between first and second publication, inviting public inspection and comments. Any public comments received within fourteen days of the last publication in the Gazette or newspaper should be compiled by the company and reported to SLEPA. 3.1.2 Mines and Minerals Act, 2009 The Mines and Minerals Act (2009), Part XV (Protection of the Environment), Section 133 (2) corroborates the provisions of the EPA Act (2008). It states that a mining licence applicant, applying for an environmental licence, shall consult with the public to introduce the Project and to verify possible impacts of the Project from stakeholders’ perspectives. Subsection (3) further states that a copy of the ESIA report shall be considered non- confidential and shall be made available to the public at the Mining Cadastre Office. 3.2 International standards and guidelines The IFC’s Performance Standards (PS) published in January 2012 are regarded as a benchmark for large private sector Projects. The PS are also at the core of the revised Equator Principles, a code of practice applied by international financial organisations involved in the financing of such Projects. The stakeholder consultation programme for the Project will be guided by the standards and guidelines, modified to reflect the nature and scale of the Project and other relevant factors. The specific requirements for public consultation are contained in IFC’s Performance Standard 1: Social and Environmental Assessment and Management Systems. The requirements for consultation are further elaborated in the corresponding Guidance Notes. The concept of free, prior and informed consultation is explained in the same table. For Category A Projects (such as the Marampa Project), the Project proponent is required to consult with relevant stakeholders at least twice. First, during the scoping phase, before the Terms of Reference (ToR) for the assessment and baseline studies are finalised, and next on completion of the ESIA process to feedback on the potential impacts and resultant management plans. The consultation process then continues throughout the Project File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 6 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP construction, operation and closure phases, as necessary, to address relevant stakeholder issues and concerns which are shown in table 3.1. In addition, the Equator Principles and Performance Standards require Project proponents to set up a system to address grievances in a prompt manner. This system should be understandable, transparent, culturally appropriate, easily accessible and should be at no cost to the affected people. Table 3-1: IFC Performance Standards: key principles for undertaking public consultations Reference/guidance Key Principles/concepts Public consultation and disclosure should: • be free of external manipulation, interference, coercion or intimidation; • be inclusive of all segments of the affected communities (including women, children, the elderly, etc.); • be informed by preliminary stakeholder analysis; • entail both open (public) community meetings and discussions with community leaders; • clearly communicate potential Project-related risks and impacts; • start during early scoping (especially for Projects with significant impacts); PS 1: Social and • be based on timely, relevant, understandable and accessible Environmental information – this requires information to be provided in the languages Assessment and and methods preferred by the affected communities; Management System • inform the terms of reference (TOR) for social and environmental assessment; • allow time and opportunities for collective decision-making (especially for indigenous peoples) and for contextually appropriate feedback mechanisms; • lead to ‘broad community support’ defined as ‘a collection of expressions by the affected communities, through individuals and their recognised representatives, in support of the Project’. • entail a clear action plan based on the environmental and social management plan; and • accompany all significant changes to Project planning, scope and execution. As per the IFC Guidance Note 1: Social and Environmental Assessment and Management Systems, Free, Prior and Informed Consultation means that the: ‘…consultation should be “free” (free of intimidation or coercion), “prior” Free, Prior and Informed (timely disclosure of information) and “informed” (relevant, understandable Consultation and accessible information)’ and should lead to ‘…broad community support for the Project by the affected communities’. Broad community support is defined as ‘a collection of expressions by the affected communities, through individuals and their recognised representatives, in support of the Project’. File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 7 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP 4 PURPOSE OF THE SEP The purpose of the SEP is to ensure the views, interests and concerns of Project stakeholders are taken into consideration during environmental and social impact assessment process. The specific objectives of the SEP therefore are to: • identify potential Project stakeholders and analyse their interest/influence on the Project; • describe relevant Sierra Leone legal requirements and international standards; • present the approach and methodology for consultation and disclosure activities; • consult with Project stakeholders and document their feedback; • document the stakeholder engagement process to date; and • propose a framework for grievance mechanism. 4.1 Overview of Marampa consultation process An overview of the Marampa stakeholder engagement process is presented in Figure 4-1. The overall programme is closely linked to different stages the ESIA process so as to complement each other. File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 8 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP Figure 4-1: Marampa ESIA stakeholder engagement process File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 9 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP 5 PROJECT STAKEHOLDERS Project stakeholders are defined as those groups or individuals that ‘will be directly or indirectly affected, positively or negatively, by the Project and who can contribute to or hinder its success’ (IFC, 2012). Identification of potential stakeholders including vulnerable groups/individuals was undertaken as a first step while preparation of the initial SEP during July 2010. The initial list of stakeholders was drawn based on meetings with the Project staff (at the site and in Freetown) and assessment of the potential Project footprint area. Government representatives met during July 2010 were asked to provide further information on names of potential stakeholders. Each stakeholder met during the scoping process was asked to provide further information on potential stakeholders. Hence the current list of stakeholders was developed as a snowballing process and is presented in Appendix 1. The list of interested NGOs and other interest groups was drawn using SRK’s prior experience of working in Sierra Leone and in discussion with the in-country social specialist. Typically identification of stakeholders is an on-going and iterative process and more stakeholders are expected to be identified as the Project develops. The analysis of stakeholders involved stakeholder categorisation in terms of their potential interest in the Project, how they could be affected by the Project and to what degree, issues and concerns they have with the Project and what influence they may have on the Project. Mode and frequency of communication was suggested for each stakeholder or group. Table 5-1 presents the stakeholder analysis conducted after the scoping consultations. Updating the stakeholder analysis is also an on-going process and should be repeated after each round of stakeholder engagement. File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 10 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP Table 5-1: Identification and analysis of stakeholders/ groups Stakeholder Stakeholder (group)/ profile (STAKEHOLDER PROFILE) Impact/benefit Degree of Communication category Potential concerns and expectations from the Project from Project influence strategy over Project Government and • Port Loko District • Increased revenue for development programmes Medium Medium Information regulatory • Paramount Chiefs (Masimera, • Expect benefits to local communities and economy dissemination authorities Marampa and Maforki) • Concerned about in increase in population due to • Lunsar Town Administration migration of skilled and other workers • Sierra Leone Environment • SLEPA is responsible for issuing EIA licences which Low High Two way Protection Agency (SLEPA) are needed for the Project to be approved. communication and • Concerned about potential environmental and social negotiation impacts • Ministry of Minerals (Mining • National government ministry for mines and minerals Medium High Two way Division) formulates and presents policies and legislation for the communication consideration of Parliament • The Mines Division administers the regulations made under the mines and minerals Act and the explosive Act. These regulations include the issue of all mineral rights and the administration and supervision of all activities under these rights. • The Geological Survey Division advises Government on all matters of geological nature. This enables the government to grant mineral rights to interested investors with Government’s aim in pursuing a more creative mining development policy • Want to know the scale of and nature of mining operation and revenues • Ministry of Local Government • Expects investment for community development Medium Low Information dissemination • Ministry of Land Country Planning • Concerned about endemic species which are also Medium High Two way and Forests (Departments of vulnerable to hunting and illegal trade communication Forests and Wildlife) • Ministry of Agriculture and Food • Concerned that the Project will bring many people into Information Security the area and those who don’t get jobs will resolve to dissemination charcoal burning and fuel wood, thus exploiting the forest further. Expects the company to help develop the forest. • Already problems of low water levels and desertification, concerned these will be exacerbated. File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 11 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP Stakeholder Stakeholder (group)/ profile (STAKEHOLDER PROFILE) Impact/benefit Degree of Communication category Potential concerns and expectations from the Project from Project influence strategy over Project Affected • Villages falling within the potential • Expectation of jobs, business opportunities, training, High Medium Two way communities Project footprint area; villages improvement in physical infrastructure such as – communication impacted by restricted access to schools, health centre, water supply, roads, electricity land other natural resources; and other facilities villages downstream of water supply area; host resettlement areas • Land owners/farmers • Concerned about loss of shelter and access to land and High Medium Two way other natural resources communication and • Concerned about the potential stress and trauma negotiation related to resettlement and displacement • Expectations of replacement houses, fair compensation for land (and crops, trees) • Expectations of support in livelihood restoration and financial support during transition period • Lunsar residents • Expect expansion in consumer base and increase in Medium Low Information business and growth of town dissemination • Concerned about pressure on infrastructure as a result of influx of job seekers • Foreroad Baka women’s • Expectations in terms of opportunities for education and High Low association and Mabesene employment for females; and upward social mobility. women’s association Women should not be ignored in potential employment opportunities • Would like help to tackle pests destroying their crops • Expects assistance for business activities and for building up a storage facility for crops and produce. • Concerned blasting activities will damage their houses • Would like local people to be employed • Creation of toilet facilities and water supplies • Concerned about dust causing illness and increase in accidents due to traffic • Youth groups • Concerned about community development Medium Low Two way • Concerned about wildlife protection and forest communication conservation File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 12 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP Stakeholder Stakeholder (group)/ profile (STAKEHOLDER PROFILE) Impact/benefit Degree of Communication category Potential concerns and expectations from the Project from Project influence strategy over Project Non-government • Network Movement for Justice and NMJD is engaged in various rights based campaigns on Low Medium Two way Organisations Development (NMJD) the issues of mining in Sierra Leone. They build the communication (NGOs) and special capacity of community members and organisations on interest groups mining law and their rights to enable them negotiate and work with mining companies in a non-violent manner. They summarise mining and ESIA documents into simple language for community to understand as part of community. They are also working with the government to strengthen governance and accountability • Worried moving too fast could create problems • Communities should know what is happening at each stage to minimise impacts • Concerned about rights of local people • Green Scenery • Green Scenery is a local NGO involved in Low Medium Information environmental promotion and protection; livelihood dissemination security; human rights and governance; and peace building and conflict resolution. • Worried company won’t complete all stages prior to ESIA and just do enough to gain licence • Company should design programmes to engage with communities, talking to people is not enough • Chiefs are no longer in control of everything so company should engage with all people including youths • Re-vegetation is important • Concerned over change of ownership, a bond should be left for new companies to take up • Concerned about resettlement and land allocation • Concerned about how company will tackle climate change File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 13 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP Stakeholder Stakeholder (group)/ profile (STAKEHOLDER PROFILE) Impact/benefit Degree of Communication category Potential concerns and expectations from the Project from Project influence strategy over Project • Environmental Forum for Action • ENFORAC are a consortium of environmental NGOs, Low Medium Information (ENFORAC) community groups and academic institutions who work dissemination together to protect and advocate for Sierra Leone's natural resources. Their main aims are: • Natural resource management; • Policy reforms and enforcement; • Land use planning; • Water catchments management; • Waste management; • Biodiversity management research; • Sustainable development; and • Mass environmental education and information campaigns. • ENFORAC raised concerns about visual impacts as the landscape will be destroyed, future disaster and digging of pits Want to know what the company will do about • Noise and air pollution • Tailing storage facilities • Drilling/blasting –effects on workers and the communities • Flora and fauna • Budget for mitigation • Cotton Tree Foundation • Focuses on business agriculture, environmental Low Medium Information rehabilitation (how the environment can be dissemination rehabilitated), food security and education. • Concerned about impacts on water and on agriculture • Expects the company to show respect for all local people, and to engage with different groups especially youths • Amazonian Initiative Movement • The organisation campaigns against harmful practices Low Medium Information against women and girls. They specifically campaign dissemination against Female Genital Mutilation (FGM). • Concerned about HIV and AIDS with foreigners/employees coming from outside not being aware of the problem. File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 14 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP Stakeholder Stakeholder (group)/ profile (STAKEHOLDER PROFILE) Impact/benefit Degree of Communication category Potential concerns and expectations from the Project from Project influence strategy over Project • Concerned about young girls being brought into prostitution. • Expected preference to be given to locals in terms of employment. • Expects company to provide proper safety gear for employees. • Other concerns are with women, child labour and human resources Other stakeholders • Journalist, Universal Radio (Media) • Local and national newspapers, radio and T.V. Low High Information and stakeholder • Eager to cover issues relevant to the interests of its dissemination groups audience and constituency • Looks for negative aspects of the Projects • Marampa Community Bank • The Bank was re-established after the war in 2002 by Low Low Information the Government of Sierra Leone and started operating dissemination on 7th February 2003 to provide financial services to the Marampa community. • Expects the company to put a percentage of their money into the bank • Expects the company to do local banking and pay wages through the bank • District Medical Officer (DMO) Port • DMO based in the district hospital in Lunsar Medium Low Two way Loko • Problems with local people having to use unclean water communication from upstream • HIV/AIDS is prevalent in the area, concerned this may get worse with influx of people • Concerned about dust causing illness • Port Loko Teachers College • Concerned about biodiversity and soil depletion and Medium Low Information (PLTC) Administration toxicity causing damage to plants dissemination • Expects company to plant economic trees for the local people to enhance livelihoods • Concerned in migration may cause an increase health and social problems such as crime • Expects assistance for tertiary institutions as well as primary and secondary schools • Concerned with rail /roads and transport causing accidents. • Believes that if the company help the schools then there will be a ripple effect, they can develop training File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 15 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP Stakeholder Stakeholder (group)/ profile (STAKEHOLDER PROFILE) Impact/benefit Degree of Communication category Potential concerns and expectations from the Project from Project influence strategy over Project facilities to help people get jobs in the mine e.g. catering • Murialdo Secondary School • Concerned teachers may leave the school to get better High Low Two way paid jobs with the Project, the company should check communication employment records in interview • Concerned pupils may leave education to get work instead of staying in school • Expects MIOL to talk with and discipline employees who hassle the school girls. • Would like consultation to be a continuous process • Worried about demand on food, and people turning the theft if they cannot get work. • Would like MIOL to take part in school activities • Would like MIOL to give university scholarships to some pupils File Ref: U3823_Marampa_SEP_Final.docx August, 2012 Page 16 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP 6 SUMMARY OF PREVIOUS CONSULTATIONS This section provides a summary of the stakeholder consultation activities undertaken during this ESIA process (until March 2011). 6.1 Initial community engagement by MIOL Prior to the start of stakeholder consultations as part of the ESIA by SRK, MIOL were involved in meetings with the local community members and their leaders as part of the on-going exploration activities and its on-going community support programme. The meetings generally took the form of open public meetings in a communal venue in Lunsar. No formal records are available of these meetings. Based on discussions with MIOL staff SRK has noted two key meetings held during 2010. These are presented in Table 6-1. Table 6-1: MIOL’s meetings with the communities in 2010 Place & Date Stakeholder(s) Meeting topics Town Hall, General Public and community • The Company presented an update on the Lunsar, April representatives (about 800 participants) Project progress and ongoing community 2010 development programmes undertaken by MIOL • The community wanted to know when the Project would start and make employment opportunities available Primary School, Village residents, school children, First • The Primary School built with assistance Konta Village, 9 Lady of Sierra Leone, local administration, from the Company was formally inaugurated July 2010 community representatives and general by the First Lady on behalf of the people of pubic Sierra Leone • Scholarships were distributed to selected students to support them in the continuation of their education 6.2 Scoping consultations with key government ministries On start of the ESIA process, SRK conducted meetings with the key government agencies (mining, environment, forestry and the local government) during July 2010. The purpose of meetings was to: • formally initiate the ESIA process with SLEPA; and • to announce the intention to develop the proposed Project among other relevant ministries; • to seek inputs in the stakeholder identification process to identify additional Project stakeholders; and • to document the issues and concerns of Project stakeholders for consideration in the ESIA process. The meetings were held on a one-to-one basis in the ministry offices and were attended by a representative from MIOL. Meeting minutes were recorded for each meeting. Table 6-2 presents a summary of all the meetings held. Appendix 2 presents the records taken at the meetings. A Background Information Document (BID) outlining the status of the Project was prepared as a disclosure document and provided to Ministry representatives at the time of the meetings. A copy of the BID is provided in Appendix 3. U3823_Marampa_SEP_Final.docx August, 2012 Page 17 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP Table 6-2: Summary of stakeholder meetings held in July 2010 Place & Date Stakeholder(s) Meeting topics Follow up action by / MIOL/SRK Mining Cadastre Eugene Norman • MIOL introduced the Project Consultation with Office, 1 July (Assistant Government and announced the intention to SLEPA 2010 Mining Engineer) start the ESIA. Alusine Timbo (Assistant • Project Background Government Mining Information Document was Engineer), provided. • The Ministry representative asked that the ESIA requirements be discussed with SLEPA. SLEPA office, 2 Momodu A Bah, Acting • MIOL introduced the Project Send letter to SLEPA as July 2010 Deputy Executive Director and announced the intention to formal notice of intention (In-charge of EIA, Field start the ESIA. to undertake the ESIA operations & Extensions), • Project Background and request supply of SLEPA Information Document was application form and provided. screening form. • Mr Bah explained the steps leading to an ESIA licence and asked for a letter from the Company as formal notice to start the ESIA process. Office of the Mr Abdul-Abib F Conteh, • MIOL introduced the Project Letter to the Ministry for Forestry Deputy Director, Forestry and announced the intention to permission to proceed, Department, 2 Division start the ESIA. once the Project July 2010 • Project Background footprint area is defined. Information Document was provided. • Mr Conteh provided information on the protected areas and asked for a formal letter to the Ministry for permission to proceed with the Project if it does not interfere with any protected areas. Office of the Director, Ministry of the • MIOL introduced the Project Formal letter to the Ministry of the Local Government and announced the intention to Ministry to seek Local start the ESIA. community cooperation Government, 2 • Project Background in the development of July 2010 Information Document was Project. provided. • The Director explained the role of the ministry representative on the Minerals Advisory Board and in negotiation between land owners and mining companies (if required). 6.3 Scoping consultations with various stakeholders groups (March 2011) Following meetings with the key stakeholders (Section 6.2) SRK conducted consultation meetings with a full range of Project stakeholders in March 2011. It included meetings with community groups, local government, NGOs and other interest groups. 6.3.1 Methodology used for consultation and disclosure activities The methodology used for consultation meetings was based on analysis of the Project area and stakeholders. It took into consideration specific needs of the different stakeholders/groups (including vulnerable groups) and the following factors: U3823_Marampa_SEP_Final.docx August, 2012 Page 18 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP • literacy level and capacity to understand technical information; • cultural background; • gender; • geographic location; • vulnerability to potential Project impacts; and • level of interest in and influence over the proposed Project; Communication tools Table 6-3 presents appropriate communication methods used with different stakeholder groups. Table 6-3: Stakeholder consultation methods used Methods: Stakeholders: One-on-one meetings • Key Government stakeholders • NGOs • Paramount Chiefs Public hearing/ meetings / open days • Affected communities • General public Focus group meetings/ workshops/ • Vulnerable groups in communities (eg. women, the elderly) village meetings • NGOs • Special interest groups Telephone conversations • Government stakeholders • NGOs • Community Leaders Fax, E-mail • Government stakeholders • NGOs Media • All stakeholders • General public Distribution of disclosure documents • All stakeholders • Affected communities (non-technical summaries) (examples of disclosure materials are presented in Appendix 3) Invitations for the meetings Invitations for the consultation meetings were sent to institutional stakeholders 7-10 days in advance. Community groups were notified 3-4 days in advance of meetings, as longer notice periods tend to result in lower attendance levels in villages. Local communities were notified in person whereas Invitations/notices to other stakeholders were sent out either by letter, fax or email. Disclosure documents The BID and a fact sheet by MIOL was distributed among the stakeholders prior to and during the meetings. For community meetings posters were used to explain the proposed Project and aid the discussion. For meetings with the institutional stakeholders presentation slides were used to aid the consultation process. Appendix 3 shows the different disclosure documents used during scoping consultations. Location of community meetings 2 The community meetings were held at each village within the study area . Within the villages, meetings were held at centrally located open public areas to enable easy access by different 2 Study area is defined in the social baseline study (SRK, 2012) U3823_Marampa_SEP_Final.docx August, 2012 Page 19 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP stakeholders including participation of women, youth, elderly and any minority groups. The meetings were held in locally popular language – Temne with translation into English for MIOL and SRK representatives. In addition, a public meeting was held at Lunsar town which was open to the general public. Public notices were issued for participation in the meetings. This meeting was attended by about 1000 people from the Lunsar town and various villages in the vicinity of proposed Project site. It was also attended by the local leaders (both traditional and administrative). The meeting provide a forum for different sections of the society to exchange their opinion on the proposed Project which was largely in favour of the development. Documentation Record of stakeholder issues was kept at all meetings. These were compiled into an issues and response table, which shows how these were addressed during the ESIA process (Appendix 5). Copies of meeting minutes held during March 2011 (and example attendance register) are presented in Appendix 2. Selected photos from the meetings held in March 2011 are provided in Appendix 4. 6.3.2 List of stakeholders consulted Table 6-2 presents the list of stakeholders consulted during March 2011, along with a date- wise schedule of the various meetings conducted. Table 6-4: Meetings with various stakeholder groups in March 2011 Date Place/venue Stakeholder(s) 9 March 2011 49 Main Motor Road, Brookfields, Freetown • Aminata Lamin (Programme Director) -Mining and Extractive, Network Movement for Justice and Development (NMJD) 9 March 2011 Soldier Street, Freetown • Joseph Rahall (Director) - Green Scenery 9 March 2011 Upper Brook Street, Freetown • Abdul Conteh (Director) and Ansumana LM Swaray, (National Coordinator) -Environmental Forum for Action 9 March 2011 Cotton Tree Foundation Office, King Street, • Michael Kamara (Executive Freetown Director) - Cotton Tree Foundation 10 March 2011 Lunsar-Makeni Highway, Lunsar • Osman Kargbo (Administrative Officer), Luisa (Intern Plan Officer) and 9 other staff members - • Amazonian Initiative Movement 11 March 2011 Office of the Marampa Community Bank, • Aiah Fomba (Manager) - Lunsar Marampa Community Bank 11 March 2011 Office of Port Loko District Council • Abdul Koroma (Deputy Chief Administrator), • Sheik A M Gibril (Rural Development Officer), • Hassan Bruce (Journalist, Universal Radio) 11 March 2011 District Agriculture Officer’s Office, Ministry • Ministry of Agriculture and Food of Agriculture and Food Security, Port Loko Security District 12 March 2011 Town Hall, Lunsar Open Public Meeting, attended by: • General public, • Paramount Chief, • local villagers, • Village Chiefs, U3823_Marampa_SEP_Final.docx August, 2012 Page 20 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP • land owners, • Provincial Secretary, • Member of Parliament, • Deputy Minister of Local Government and Internal Affairs, • AIG North, • Religious leaders, • Youth Groups, • Women’s Groups, • Port Loko District Council, • NGOs, • Chiefdom Council, • MIOL/Cape Lambert 13 March 2011 Foreroad Baka Village, Lunsar Foreroad Baka Women’s Association 13 March 2011 Mabesene Village, Lunsar Mabesene Women’s Association 14 March 2011 DMO’s office, Port Loko Government Dr Victor Max-Lebbie - District Hospital, Hospital Road, Port Loko Medical Officer 14 March 2011 PLTC Campus, Lungi Road, Prot Loko Ahmed A Koroma (Vice Principal and Director of Studies) - Port Loko Teachers College (PLTC) Administration 14 March 2011 Murialdo Secondary School, Lunsar Fr. Giuliano Pini (Principal), Fr Emmanuel Koroma, Mr Ambrose Bangura (Vice Principal) - Murialdo Secondary School 6.3.3 Outcomes of the consultation meetings The outcomes of the consultation meetings, in the form of list of key issues, concerns and expectations raised the stakeholders, is provided below. The issues were divided into categories for ease of understanding and dealing with them. Appendix 4 presents the complete list of the issues, concerns and expectations recorded during the consultation meetings. Employment • Local people/youth (born in the area) and land owners should be involved in the employment and development process to avoid conflict. • Concerns over the decline in people working in agricultural production reducing the availability of farm workers and increasing pressure on food resources. • Expect the Company to apply preferential employment of local people over outsiders. • Women must be considered for employment and child labour be avoided. • Concerned that the teachers and some senior students in the local schools may leave the school to work for the Project. What can MIOL do to prevent this? • Rumours that one has to pay 200,000 to 400,000 Leones to get a job at the Project. Environment • Apprehensions about noise pollution, air pollution, flora and fauna biodiversity loss. How will MIOL mitigate these issues? • Apprehension about depletion of water table, which needs to be addressed. • Company should choose the vegetation species for rehabilitation, Gethropha is detrimental to local water. • Concern over the inappropriate disposal of tailings. U3823_Marampa_SEP_Final.docx August, 2012 Page 21 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP Corporate Social Responsibility • Communities should be involved in rehabilitation programmes • Local people, should benefit from mining operations in their area • MIOL should develop tangible structures instead of just giving out money • Safe drinking water should be provided to the communities. • Preference towards local businesses and shops for purchase of provisions and supplies. • MIOL should use Marampa Community Bank for domestic banking and to pay staff salaries as this will allow for an improvement in community infrastructure Stakeholder consultation process and participation • The authority of Paramount Chiefs is now declining MIOL should not rely on them too much. Company should identify other leaders and communicate directly with community members. Dialogue with the community should be sustained • The Community Liaison Officer (CLO) will be the key person for community outreach. • MIOL should hold monthly meetings with the community. Mining operations • What will MIOL do about tailing storage facilities? • There needs to be sufficient distance between the use of explosives and the communities. Resettlement and livelihoods restoration • Resettlement is a key issue and MIOL must do this sensitively and properly where they should buy land for them and build houses for them. • MIOL should negotiate with plantation owners and the names of the landowners should be recorded in the deal. • Landowners should be treated fairly, whereby they receive the true money value of their land. • The rehabilitation of mined out areas is very crucial for the sustainability in agriculture. • A request for assistance and support in business activities and the construction of a storage facility for crops and produce and agricultural expansion. Health and Safety • Concerns over the effect of air pollution and dust from vehicles will have on human health • Concerns over heavy machines shaking nearby houses and blasting activity damaging their houses as structures are weak. • Concerns over increases in accidents due to an increase in traffic and the safety of people when crossing railways and roads. • Toilet facilities and clean water supply should be provided. 7 FUTURE CONSULTATIONS The stakeholder consultations that will take place on completion of the draft ESIA report will comprise: • feedback consultations to update the stakeholders on predicted impacts and proposed U3823_Marampa_SEP_Final.docx August, 2012 Page 22 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP mitigation measures; and • a public hearing meeting by SLEPA to assess public opinion on the Project. The approach and methodology for the feedback consultations will be similar to the scoping consultations as described in Section 6.3.1. The location and methodology for the public hearing meeting will be decided in consultation with SLEPA. 7.1.1 Consultations beyond the ESIA process Beyond the ESIA process, consultations with the stakeholders will be continued by MIOL to build and maintain mutually beneficial relationship with the Project stakeholders. This will serve to maintain the dialogue and facilitate resolution of issues raised by stakeholders on an on-going basis throughout the life of the Project. This SEP will be updated to reflect the changing needs of the Project as it develops. 8 GRIEVANCE MECHANISM For managing community relations MIOL will establish a mechanism for effective and speedy resolution of stakeholder complaints and problems and also to provide a satisfactory response to their queries and issues on an ongoing basis. Key features that MIOL would consider in development of a grievance mechanism are provided below. • representatives from different stakeholder groups should be encouraged to participate in the development of the grievance mechanism to ensure transparency in the process; • stakeholders should be informed about the existence and functioning of the grievance mechanism to promote its utility; • the paramount chiefs and district officials should be invited to be part of a committee for handling grievances; • responses should be provided to all queries and grievances in a time bound manner with a commitment to a time frame for resolving the issues; and • when a dispute cannot be resolved, within a reasonable period, the grieving party should be free to take the matter to courts as a final resort (in other words the mechanism should not replace existing legal process but should, based on consensus, seek to resolve the issues quickly without resorting to expensive and time-consuming legal actions. 9 REFERENCES EPFIs (2006) The “Equator Principles”: A financial industry benchmark for determining, assessing and managing social & environmental risk in Project financing, Equator Principles Financial Institutions, 2006 GoS (2008) Environmental Protection Agency Act, Government of Sierra Leone, 2008 GoS (2009), Mines and Minerals Act, Government of Sierra Leone, 2009 IFC (1998) Doing Better Business through Effective Public Consultation and Disclosure: A Good Practice Manual, International Finance Corporation, 1998 IFC (2006) Performance Standards on Social & Environmental Sustainability, International Finance Corporation June 2006 IFC (2007) Guidance Notes: Performance Standards on Social & Environmental Sustainability, International Finance Corporation, 2007 U3823_Marampa_SEP_Final.docx August, 2012 Page 23 of 24 SRK Consulting Marmpa Iron Ore Project – ESIA SEP IFC (2007) Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets, International Finance Corporation, 2007 SRK (2012) Socio economic baseline report for the Marampa Iron Ore Project, SRK Consulting (UK) Ltd, April 2012 For and on behalf of SRK Consulting (UK) Limited Lalit Kumar, Hilde van Vlaenderen, Senior Consultant, Social Principal Consultant, Social SRK Consulting (UK) Limited SRK Consulting (UK) Limited U3823_Marampa_SEP_Final.docx August, 2012 Page 24 of 24 SRK Consulting Marampa Iron Ore Project – Glossary, Abbreviations, Units GLOSSARY OF TERMS TERM EXPLANATION Affected Community Local communities that are subject to risks or impacts from a Project. Consultation involves two-way communication between the client and the affected communities. The consultation process should be undertaken in a Consultation manner that is inclusive and culturally appropriate and that provides the affected communities with opportunities to express their views on Projects risks, impacts and mitigations measures, and allows the client to consider and respond to them. The consultation process will ensure free, prior and informed consultation. The process of providing information to the affected communities and other Information stakeholders that is timely, accessible, understandable, and in the appropriate Consultation and language(s). For Projects with potential adverse impacts, information on the Disclosure purpose, nature and scale of the Project, the duration of proposed Project activities, and any potential risks to and potential impacts on such communities should be included. Local Community Community within a Project’s area of influence. Management measures Remedial measures used to reduce the level of risk Project (the) The Marampa Iron Ore Project Settlement a groups of houses, similar to a village or hamlet Stakeholder groups or individuals that are ‘directly or indirectly affected by a Project as well as …… may have interests in a Project and/or ability to influence its outcome either positively or negatively’ U3823_Marampa_SEP_Final.docx August, 2012 Page i of ii SRK Consulting Marampa Iron Ore Project – Glossary, Abbreviations, Units ACRONYMS BID Background Information Document EIA Environmental Impact Assessment ESIA Environmental and Social Impact Assessment IFC International Financial Corporation NGO Non-governmental organisation PS Performance Standards SEP Stakeholder Engagement Plan SL Sierra Leone SLEPA Sierra Leone Environmental Protection Agency SRK SRK Consulting (UK) Limited ToR Terms of Reference UK United Kingdom U3823_Marampa_SEP_Final.docx August, 2012 Page ii of ii SRK Consulting Marampa Iron Ore Project – Technical Appendix 1 APPENDIX 1. STAKEHOLDER DETAILS U3823_Marampa_SEP_Final.docx August, 2012 Page 1i of 1iii SRK Consulting Marampa Iron Ore Project – Technical Appendix 1 Appendix 1: Stakeholders details Stakeholder category Stakeholder name Address Telephone Email Government and regulatory Port Loko District Council Chief Administrator’s Office, Port Loko authorities District Council, Port Loko Paramount Chiefs (Masimera, Marampa Marampa Paramount Chief’s residence and Maforki) is on Lunsar Makeni Highway; other chiefs are in their respective chiefdoms (exact location to be checked with PROs) Lunsar Town Administration Lunsar, Port Loko Sierra Leone Environment Protection SLEPA Office, 3rd Floor Youyi Building, Mobile number: modbah@yahoo.com Agency (SLEPA) Brookfields, Freetown. 078350627, Contact: Mr Momodu A. Bah, Acting 076668698, Deputy Director 088351725 Incharge of EIAs, Field operations & extensions, SLEPA, 3rd Floor, Youyi Building, Brookfields, Freetown, Sierra Leone Ministry of Minerals (Mining Division) Mining Cadastre Office, Ministry of Mineral Resources, 5th Floor Youyi Building, Brookfields, Freetown Ministry of Local Government Ministry of Local Government, Youyi Building, Brookfields, Freetown Ministry of Land Country Planning and Forestry Department, 1st Floor, Youyi Forests (Departments of Forests and Building, Brookfields, Freetown Wildlife) Ministry of Agriculture and Food Security District Agriculture Officer’s Office, MAFS, Port Loko Affected communities Villages falling within the potential Project Affected villages footprint area; villages impacted by restricted access to land other natural resources; villages downstream of water supply area; host resettlement areas Land owners/farmers Affected villages Foreroad Baka and Mabesene Women’s Foreroad Baka Village, Lunsar (suburb) Association Lunsar residents Lunsar town U3823_Marampa_SEP_Final.docx August, 2012 Page 1ii of 1iii SRK Consulting Marampa Iron Ore Project – Technical Appendix 1 Stakeholder category Stakeholder name Address Telephone Email Youth Groups Lunsar town and affected villages Religious Leaders Lunsar town Non-government Network Movement for Justice and NMJD Office, 49 Main Motor Road, +(232)26204036 nmjd@nmjd.org Organisations (NGOs) and Development (NMJD) Brookfields, Freetown +(232)76645314 special interest groups Green Scenery Soldier Street, Freetown gscenery@yahoo.co.uk Environmental Forum for Action 51 Upper Brook Street Freetown, Sierra Mr. Ansumana enforac@yahoo.com (ENFORAC) Leone West Africa, P. O. Box 1145 Swarray National Coordinator + 232 (0) 76 463 653 Mr. Abdulai Conteh Deputy Chairman + 232 (0) 33 407 164 Cotton Tree Foundation Cotton Tree Foundation Office, King Street, Freetown Amazonian Initiative Movement Lunsar-Makeni Highway, Lunsar +232-76-738517 aimgn2001@yahoo.co.uk 24 New Makeni Road, PO Box 77 Lunsar, Marampa Chiefdom, Port Loko aimsl2001@yahoo.co.uk District Sierra Leone Other stakeholders and Port Loko Teachers College (PLTC) PLTC Campus, Lungi Road, Port Loko stakeholder groups Administration Murialdo Secondary School Murialdo Secondary School, Lunsar District Medical Officer DMO’s office, Port Loko Government Hospital, Hospital Road, Port Loko Marampa Community Bank The Manager’s Office, Marampa Community Bank, Lunsar Journalist, Universal Radio (Media) Port Loko town U3823_Marampa_SEP_Final.docx August, 2012 Page 1iii of 1iii SRK Consulting Marampa Iron Ore Project – Technical Appendix 2 APPENDIX 2. MEETING MINUTES U3823_Marampa_SEP_Final.docx August, 2012 Page 2i of 2i Marampa Meeting Minutes March 2011 Network Movement for Justice and Development (NMJD) Meeting location: NMJD Office, 49 Main Motor Road, Brookfields, Freetown th Date and Time: 9 March 2011 at 08:06 hours Attendees: Aminata Lamin (Programme Director, Mining and Extractive, NMJD), Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK) Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra Leone) Limited (MIOL). A copy of the Background Information Document on the proposed project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation process and invited the participants to express their issues and concerns. The following key points were raised:  Aminata Lamin provided an over view of NMJD: o Mining and extractives is one of focus area for NMJD, which is engaged in various rights based campaigns on the issues of mining in Sierra Leone o They build capacity of community members and organisations on mining law and their rights to enable them negotiate and work with mining companies in a non-violent manner o They summarise the mining legislation and ESIA documents into simple language for community to understand as part of community capacity building o They are also working with the government to strengthen governance and accountability  NMJD engages with the ministry of mines  Most mining companies do not like talking with communities and NGOs to avoid conflict but this approach is short sighted. The companies should maintain direct contact with communities to prevent conflict.  NMJD is member of the steering committee for EITI and she encouraged MIOL to become a member of EITI and to join the chamber of commerce.  Aminata informed that due to weak governance mining companies in Sierra Leone are violating the laws and people‟s rights. She thinks that where national laws are weak, companies should use international standards.  She thinks that cost of resettlement of people, compensation for crops and community infrastructure should be factored in the project cost.  Communities do not have negotiating power. They are negotiating with the government that 1% of the profits should go directly to the affected community for their development.  She informed that the authority of Paramount chiefs is now declining and hence the company should not rely on them too much. Instead MIOL should identify other leaders and communicate directly with community members. The dialogue with the community should be sustained.  NMJD is supporting another NGO called Campaign for Just Mining in Lunsar. This campaign is focused on capacity building of the community members on the topics of mining laws and their rights.  She was not clear on the relationship between MIOL and Africa Minerals Limited (this was clarified by Simon).  She enquired if MIOL is active in Kambia District as one of their partner organisation „Conscience International‟ that is active in the district has asked then for sensitisation programme.  She reiterated that their organisation uses the right based approach – people should know what is happening around them so that ever impact will be minimised. Flying fast could create problems Green Scenery Email: gscenery@yahoo.co.uk Meeting location: Soldier Street, Freetown th Date and Time: 9 March 2011 at 09:25 hours Attendees: Joseph Rahall (Director, Green Scenery), Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK) Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra Leone) Limited (MIOL). A copy of the Background Information Document on the proposed project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation process and invited the participants to express their issues and concerns. The following key points were raised:  Purpose of meeting, overview  Small organisation but make a lot of noise  He said that it is not doing the ESIA but it is about companies not following procedures. This ignites community conflict giving the example of African Minerals Limited (AML) at Ferengbeya  He said that companies jump all other stages/procedures and obtain the ESIA process; procedures make a company legitimate.  Talking to the people is not enough; companies should design programmes with the communities and identify their needs and there are different needs.  His experience with community work is that people change their ideas, support and messages passed on to them. When they change, they should be engaged.  Advised MIOL to carefully study the community dynamics and the Chiefs. The Chiefs are sometimes a problem; hence the Company should engage the people.  Take time to study the community and talk to critical people in the community. Chiefs are no longer in total control of everything.  Regarding the work GS does, they do a 3600; they look at the environment from an angle of right, livelihood and conflict.  Green Scenery works in coalition with National Coalition on Extractives (NACE)  Examine technical issues. He said that NMJD deals with resettlement, social and compensation issues.  GS advises companies where issues and conflict may arise.  Consultants may do a good job but after ESIA phase companies may oversight all steps e.g. chemical disposal, tailings, water pollution, clearing of vegetation, possible restoration etc.  On the issue of implementation, Consultants should design a framework on how to monitor and include as an annex. He recommends that MIOL devices a framework on reporting their performance. He cited Sierra Rutile Limited (SRL) and said that they have not been able to present their annual environmental report and draw up a reporting template as guideline to go by what the law says.  He asked whether the Company can include activities to cope with climate impact.  Further more, Mr Rahall said that the work of MIOL will clear swamps and forests. He asked how MIOL will assist with communities coping with climate change – machines pollutants, carbon absorption, etc. This is not in the SLEPA 2008 but for good practice round the world.  The Director asked about the relationship between London Mining, African Minerals and MIOL. Simeon Elson gave historical background of the Company  He asked how the Company will manage the environment and development of people. The Company is in an area of stark poverty. There is potential for conflict when the community people see physical wealth in their area and see some youths being employed. Youths do like each other (jealousy).  The Company should therefore establish good relations with the communities and with youths.  Resettlement is a big issue. Government does not have a resettlement policy but companies need to do it properly.  Re-vegetation is important – NGOs have been fighting with Sierra Rutile Limited (SRL) on this issue. He reiterated the issue of companies moving fast with their operations and leaving the procedures.  He also highlighted the issue of change of ownership. When companies sell, the new ones do not usually take up liabilities of the old companies, e.g. SRL and Koidu Holdings (KH). He asked if a bond will be left behind for new companies to take up. Government does not have the capacity to monitor liabilities and risks and this is where the NGOs intervene.  He said that the ESIA should not only be sent to SLEPA but should be made available to other stakeholder groups to share their concerns before the ESIA disclosure.  He suggested that the communities should be involved in rehabilitation programmes e.g. tree planting, as this will provide employment.  Communities should be engaged and educated to avoid threats. This may not involve too many resources but will induce creative thinking.  MIOL is to keep a balance between community expectations and the Company.  Communities always see mining companies as government  The Community Liaison Officer (CLO) will be key person for community outreach.  On the relationship with NACE, Mr Rahall said that it is a coalition and Green Scenery is hosting the Secretariat. Other members are NMJD, Christian Aid, Talking Drum, Anti- Corruption Commission, Action Aid, Commission for Democracy and Human Rights and MADAM- they help to sensitize the communities.  He also said that livelihood will be a big issue e.g. farmers may not have much land any more.  He also mentioned resettlement – Where a village is relocated the chief will meet another chief in the new area of location. He may not have the powers of a chief. Environmental Forum for Action (ENFORAC) Meeting location: Upper Brook Street, Freetown th Date and Time: 9 March 2011 at 10:29 hours Attendees: Abdul Conteh (Director, ENFORAC), Ansumana LM Swaray (National Coordinator, ENFORAC), Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK) Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra Leone) Limited (MIOL). A copy of the Background Information Document on the proposed project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation process and invited the participants to express their issues and concerns. The following key points were raised:  Ansumana Mansaray introduced the organisation comprising a consortium of environmental NGOs, academic groups. They want to see change in management of resources for a better Sierra Leone. Sierra Leone is endowed with abundant resources but the country has been exploited without benefit to the people and the country.  He said that MIOL are in the right direction. AML came to their office in 2010, two (2) days to the disclosure. He said that their public participation is very poor; they rushed with license procedures. He said that there will be a lot of Green House Effect from the 5 billion tons of potential iron ore. 200million tons of carbon dioxide will cost US$2.3 billion but only a fraction is being accounted for.  Companies may get away with their responsibilities now but in the long run it will come back to them.  He stated that they are negotiating with SLEPA for international consultants to participate with local consultants  He said that social benefits in other mining companies are very poor.  He raised concerns about visual impacts as the landscape will be destroyed, future disaster and digging of pits.  Abdul Conteh asked about what MIOL is doing for: o Noise and air pollution o Tailing storage facilities o Drilling/blasting –effects on workers and the communities o Flora and fauna o Budget for mitigation  He said that they will make noise if the companies go political. He mentioned the Equator Principles  He also mentioned KEPCO, an international Korean Company.  Other issues include water – there is water crisis in the project area. He asked which type of explosives/blasters that will be used, training of staff to use explosives safely and the distance from the communities.  Mr. Swaray raised that there is heavy concentration on iron ore exploitation. He asked if AML, LML and MIOL will work together to combat the impacts.  Mr. Swaray said that he cannot stop companies from mining but would not want the cost of rehabilitation to be left on the Government.  He warned that Government connection is not enough; communities should be involved.  He would like to see the Mine Reclamation Plan as there is a lot of emphasis on this.  Abdul mentioned about the kind of plant species to be used as gethropha plant is not good for local water bodies.  Mr. Swaray further said that monitoring is a grey area and that IUCM is interested in to do State of Environment on monitoring. He said that companies do not like to be monitored but advised companies to abide by international standards.  Mr Swaray said that ENFORAC has the legal mandate to monitor and are working with SLEPA.  He advised MIOL not to depend on one or two guys but should work on national interest.  He expressed that ENFORAC would like to be part of the process; they do not want to be informed. He said that their work is support organisations, ensure that community needs are addressed and to develop sustainable environment. He asked MIOL to work with them.  Mr. Swaray said that ENFORAC is a member of the Green Actors of West Africa and ECOWAS Parliament.  In conclusion, he said that there is no Act on the Environment and there are many gaps on EPA 2008 and the Mines and Minerals Act and the legal act is weak. Cotton Tree Foundation Meeting location: Cotton Tree Foundation Office, King Street, Freetown th Date and Time: 9 March 2011 at 11:40: hours Attendees: Michael Kamara (Executive Director), Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK) Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra Leone) Limited (MIOL). A copy of the Background Information Document on the proposed project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation process and invited the participants to express their issues and concerns. The following key points were raised:  Michael Kamara said that his organisation had held a meeting with London Mining  The organisation is multi-sector, focussing on business agriculture, environment (how the environment can be rehabilitated), social (food security)  He said that mining will have impact on the environment. He gave example of SRL which he said had become a water body and created small rivers.  He encouraged intervention in agriculture and recommended the use of plants to rehabilitate the soil.  He said that mining may bring in more people into the area but this might live less people in the agriculture production.  Cotton Tree Foundation has an agriculture centre which is based in Lunsar. Since 2005, the organisation is supporting 5,000 families in agribusiness to date. The organisation was established in 2003. There has been increase in labour cost.  He cautioned on the problem to manage expectations.  He said that business should maintain some distance from the Government as dependence on government could create more problems. He cited that London Mining landed into problems with providing jobs that are resulting into huge running cost as a result of political influence. If the Company wants to work with the politicians, this is dangerous.  He also cautioned on dependence on the Paramount Chiefs and encouraged discussions at grassroots levels.  In agriculture, he wants to see how the agribusiness could impact on the project. The organisation provides farmers with inputs, seeds at 25% interest.  They do fruit project and ginger. The problem was access to market but they started exporting sesame to Japan.  They also engage in rice mechanisation. Although rice is the staple food, cassava and groundnut are also cultivated. As he intends to improve on revenue, ginger and cashew are also part of the project.  He stated education as the second core area of business. The organisation collaborates with other actors to promote education. They help in training teachers, provide standard buildings and good learning materials. They concentrate on primary, secondary and vocational skill training. He said that many people are trained as academicians but are not trained as business people.  He cautioned that few educated people in the project area might inject some negative influence. The Company should ass the level of reasoning of chiefs, councillors and youths.  Understanding the people, culture and values is critical.  Company should show respect for those in the communities  The Director said that the organisation also mainstreams HIV/AIDS into the project.  He encouraged MIOL to network with the right actors  Cotton Tree has established contacts with some European partners for business expansion. Amazonian Initiative Movement (AIM) Meeting location: Lunsar-Makeni Highway, Lunsar th Date and Time: 10 March 2011 at 08:06 hours Attendees: Osman Kargbo, Administrative Officer AIM, Luisa, Intern from Italy, Plan Officer and 9 others), Simeon Elson (Cape Lambert) Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK) Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra Leone) Limited (MIOL). A copy of the Background Information Document on the proposed project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation process and invited the participants to express their issues and concerns. The following key points were raised:  Osman Kargbo said that the organisation campaigns against harmful practices against women and girls. They are operating in 5 (five0 chiefdoms targeting 30 villages. They are specifically campaigning against Female Genital Mutilation (FGM). Campaign against FGM is difficult in the area. The project is a pilot and in its third year.  The Programme is supported by Plan International (SL) and a German organisation.  Their campaign slogan is “Breaking the silence for the rights of women and girls.  In sharing his experience, Osman said that the people find it hard to stop the FGM practice because it is hard rooted tradition. Initial campaign was very challenging but intense sensitisation has created awareness.  Training programmes are conducted and those who feel convinced go through an award ceremony. The people, children and elderly can now openly talk about FGM; myths about FGM are taken away.  Initial challenges included spells, threats and black magic.  The Paramount Chief (PC) put a band on the campaign when they started in 2000.  With intense campaign on human right issues, the PC can now condemn the practice openly. Some practitioners of FGM have abandoned it.  They have groups in schools. Children are informed that they have the right to take part in decisions that affects them. No child should be initiated before 18 years.  The challenge is alternative source of livelihood to traditional practitioners and how to support children who do not want to go through the FGM. Some children are neglected  AIM wants to help but lack funds  Tools used in sensitisation are films shows and meeting of all local authorities.  There are about 300 to 400 practitioners and children are also trained.  Another challenge is how to distract the chiefs who give authority/licences to the practitioners.  Some children go back to the act if they are not supported  Osman further said that they are using positive deviance approach. The are people/ ”ambassadors” that go out to campaign against FGM.  Other human right violations which Osman said are rampant in the area include: o Child abuse to wife battering. o Teenage pregnancy, o Child labour and, o Early marriage/forced marriage  Many children in the area do not go to school especially on Tuesdays when there is a weekly trade fair at Feredugu. Some children who go to such market never return and end up in the streets.  The campaign is limited to 6 chiefdoms but the above situation is the same in other communities.  Cecelia (Plan International) raised the issue on HIV and AIDS. She is concerned about foreigners/employees coming from outside; the girl child getting into early sex. He cautioned workers to be aware of HIV and AIDS.  Cecelia said that some chiefs/headmen complain about land grabbing.  Osman stated that some landowners do not receive the real money value due to the communities. He mentioned that EITI and NACE sensitise the communities.  He also said that the landowners are not treated fairly.  Osman expressed dissatisfaction on the manner of recruitment, wherein the contract is terminated without notice after 2 or 3 months. Outsiders get jobs overnight while people in the area are left without jobs. He suggested that preference be given to indigenes.  Osman cited the demonstration by youths on LMC. The Ministry of Mines and other government officials had to intervene.  Benefit should be given to people who are sacked as this has psychological impact.  Some workers do not have the proper gears. Company should give appropriate safety gears especially workers involved in drilling.  Margaret stated that some people have lived in the quarters built by Delco for over 30 years but LMC has threatened to remove them. The people suggested for building of new houses.  It is difficult to get rooms for rent in Lunsar due to influx.  Cecelia said that people have raised concern about chemicals used; the boreholes dug and distance from the chemical to the well is short.  Abdul said that blasting could be too close to the township. Demolishing the houses left by Delco could create tension; amicable decision should be reached.  Cecelia said that they would not like to what happened with KH. She said that some companies do not want to talk to the communities; only top ranking in society. MIOL should negotiate with the grassroots / land owners at all stages.  Plantation destruction- there is some conflict as names are written without assessment. MIOL have to negotiate with plantation owners.  “Why can‟t all three companies come together to construct one route, road, railway, etc?”  The relationship between AML and MIOL was asked and felt that the communities are cheated for carrying the same exploration license.  When will mining start?  Other concerns are with women, child labour and human resources  Luisa asked about how MIOL will do the monitoring and which areas of influence; how long does it take to monitor.  How will MIOL address urgent hazards e.g. blasting- noise if it affects people. Marampa Community Bank Meeting location: The Manager‟s Office, Marampa Community Bank, Lunsar th Date and Time: 11 March 2011 at 09:46 hours Attendees: Aiah Fomba, Manager), Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK) Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra Leone) Limited (MIOL). A copy of the Background Information Document on the proposed project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation process and invited the participants to express their issues and concerns. The following key points were raised:  The bank had operated before the war- it was a rural bank, private owned.  The Bank was re-established in 2002 by the Government of Sierra Leone and started th operating on 7 February 2003 to provide financial services to the Marampa community.  It is a limited liability that was given to the community on loan which is to be paid over 40 years period.  One hundred million leones was given as initial capital part of which was used to offset running costs.  The community people are poor; initial they had no money to open accounts.  Women who petty traders and bread winners- they found it difficult to pay back.  There were bad debts when the loan scheme started.  The bank got loan fro NACSA (National Commission for Social Action) and MITAF.  Number of accounts increased in 2004 when the Government decided to pay teachers and other workers through the bank.  Loan scheme for teachers was established and this proved successful.  Salary loans have helped many families to pay fees, travel abroad, start new businesses, etc.  The Authorities in Marampa (MP, PC and District Chairman) should work to promote the Bank.  There are over 80,000 shares to sell but there is no money for the people, little farming, trading and transport.  Mr Fomba welcomes the Company to do their domestic banking and to pay staff salaries through the Marampa Community Bank. He wants the companies to come together to improve community infrastructure.  Over 70 MIOL staff members are banking with them and have taken loans.  If the Bank becomes profitable, the profit will be ploughed back to the community. MIOL have opened and impress account but looking forward to MIOL depositing some of their money to expand their services. He said that they are partners in development; they cannot develop if they depend solely on the community.  IFAD (International Finance on Agriculture and Development) wants to come on board to assist farmers.  His concern is that the big banks will swallow them up.  He is aware of their limited capacity; but wishes MIOL should put percentage of their money in the Bank. They cannot handle the foreign exchange.  The Manager suggested that authorities should take the lead to advocate for their communities and not only for themselves. If MIOL helps the Bank to develop, they in turn will help the communities. Port Loko District Council Meeting location: Chief Administrator‟s Office, Port Loko District Council, Port Loko th Date and Time: 11 March 2011 at 12:02 hours Attendees: Abdul Koroma (Deputy Chief Administrator, Sheik A M Gibril, Rural Development Officer), Hassan Bruce, (Journalist, Universal Radio) Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK) Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra Leone) Limited (MIOL). A copy of the Background Information Document on the proposed project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation process and invited the participants to express their issues and concerns. The following key points were raised:  The Deputy Chief Administrator (DCA) Thanked the Visiting Team and said that such disclosures have been done by other companies.  The project will be economically viable because it will bring benefit to the communities. He also said that the country‟s as a whole will benefit but communities should benefit also.  He shared the experience he has had with AML and LMC. And cautioned MIOL to help the communities and not to take away only.  The DCA mentioned assistance in terms of health, trees, air pollution, and dust due to vehicle movement.  He said that MIOL should go by local laws. MIOL should incorporate facilities in their social programmes such as PHU (Peripheral Health Units), hospitals, etc. MIOL should develop tangible structures instead of giving out money.  Employment – Community people should benefit. In line with the Mining Act, priority should be given to the communities. He stressed that local labour should come from the communities.  Employment/requirement of technical labour could be explained during disclosure. When the Company employs those on the ground, they feel part of the project; they own it and act as securities.  Sheik Gilbil said that MIOL needs to recognise basic development principles/corporate social responsibilities, which some companies often neglect.  Sheik Gibril advised that for any development programme, e.g. building a school, the beneficiaries have to be involved in the initial planning.  MIOL should have community development personnel to guide them on development principles. He thanked MIOL for involving them and hopes to get feedback.  Hassan Bruce (Journalist) said that from his experience, all mining companies share similar issues- community interests are the same. Youths will be interested in employment, expectations of unskilled labour, scholarships to disable students, etc.  Council should be involved in all development programmes. He cited an example of upgrading a bridge in Feredugu section, wherein the Councillor of the area had to stop the project because he was not informed.  Local youths, indigenes and land owners should be involved.  The DCA asked about MIOL‟s relationship / future with other companies. He said that there is a notion that LMC is part of MIOL. He asked about MIOL‟s concession area.  He asked how MIOL intends to cope with youth employment as it is a critical issue and asked whether vacancies are advertised.  The DCA reiterated that the Company should contact the Council for community programmes to avoid duplication.  He also said that people who are affected directly should be the first to benefit.  He said that companies get problems because they avoid the Councils. Company information will be disseminated to the Government and other agencies.  Stakeholders present commended MIOL for this approach (involvement at initial stage). Ministry of Agriculture and Food Security (MAFS), Port Loko District Meeting location: District Agriculture Officer‟s Office, MAFS, Port Loko th Date and Time: 11 March 2011 at 12:50 hours Attendees: Aminata Lamin (Programme Director, Mining and Extractive, NMJD), Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK) Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra Leone) Limited (MIOL). A copy of the Background Information Document on the proposed project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation process and invited the participants to express their issues and concerns. The following key points were raised:  Philip Conteh said he was confused about LMC, MIOL and AML. He said that he has seen environmental degradation around Mange Acre (a village beyond the project area). He recommended planting of fast growing trees such as tactual grandis and acacia which can grow big within two to three years.  He said that cutting down tree decreases the water level and causes irregular rainfall.  MAFS once established a nursery but it was destroyed by fire  He said there is need to work closely with community youths and chiefs. The youth should take responsibility. Trees will make effective fire belts.  He expressed that MAFS (Port Loko) want to work in partnership in reforestation programmes.  Mr Conteh further said that the Company will bring many people to Port Loko in search of jobs. He said that some of those who will not get jobs resolve to charcoal burning and fuel wood, thus exploiting the forest further. He recommended the replanting of wood lot. He said that effort should be made to develop the forest.  The forest division is the smallest because MAFS concentrates more on crops and livestock. Less emphasis is placed on forestry which could be another source of livelihood.  He expressed that the level of the water table is a serious problem as it is rapidly being depleted. Women find it difficult to get water for their vegetable gardens.  Some rivers have become extinct, so they need to have trees that provide canopy to maintain the water level.  Prot Loko is not like Kailahun (Eastern Province) where there are cash crops like kola nut, cocoa, and coffee. The only suitable plantation in Port Loko is cashew.  Desertification is moving very close to the area because of increased activities in forest exploitation.  Influx of youths in Port Loko results to criminal acts, thieving; the police to provide records. Some ex-combatants had engaged in bike riding.  Swamps and low lying areas should be developed for increased production.  The DAO also said that water management should be developed and trees to be planted for availability of water. MAFS is interested in intensive farming rather that extensive.  Sensitisation has begun in Mange.  He said that the slash and burn is giving pressure on land.  The MAFS is encouraging farmers to increase production. IFAD and AFSAD were developing something. There were problems with funding and procedures.  The Land and Water Division is responsible to train farmers on how to develop swamp.  MAFS also has a programme with WFP on food and safety nets.  Communities are being sensitised on the benefits of improved agriculture; with increased in production, they can sell.  The Company will create access to market. An effective market can bring indirect benefits.  Port Loko is a low income area (very dry. There are many inland valley swamps in Port Loko. Lowland agriculture will reduce slash and burn.  Valuation of trees and crops is by MAFS  MAFS works with the Ministry of Interior and Local Government on matters of land compensation  In closing, Philip Conteh said that rehabilitation of mined out areas is very crucial for sustainability in agriculture. District Medical Officer (DMO) Port Loko Meeting location: DMO‟s office, Port Loko Government Hospital, Hospital Road, Port Loko th Date and Time: 14 March 2011 Attendees: Dr Victor Max-Lebbie (DMO, Port Loko), Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK) Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra Leone) Limited (MIOL). A copy of the Background Information Document on the proposed project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation process and invited the participants to express their issues and concerns. The following key points were raised:  The DMO mentioned dust in mining areas.  Waterborne diseases also do occur as many people depend on wells and rivers (which dry up in the dry season) for drinking and other domestic uses.  People use water coming from upstream which is already contaminated by users up stream as washing of dirty things and defecation is done there.  Cholera and diarrhoea occur in the district although there has been no outbreak of cholera in the district for the past six years.  There is existence of disease surveillance in the district.  There was lassa fever case at Buya Romende which killed one pregnant woman; there were cases in Makeni also. Lassa fever is endemic in the Eastern province.  Lassa fever is also found in the grassland/farmland in the North. Lassa is in urine, faeces of a long mouth rat.  Laboratory/blood services are very basic. Sometimes samples are taken to Abidjan.  STIs and HIV/AIDS do occur. HIV and AIDS is about 1.3%.  Polio has been kicked out in children.  Consultants should talk to Lunsar office for more details.  The DMO cautioned on the water system and artificial lakes. He said that the Company should take the environment into consideration.  He mentioned blasting – this might cause noise and houses might be affected.  He advise the Company to engage with the youths as it could be political  Unemployment – People may not have the relevant skills but might make noise for people who come from outside.  Idle youth, dependent culture and inadequate skills were also mentioned.  He mentioned that Port Loko has fertile land.  The DMO said his door will be opened if there is anything in the health sector. Port Loko Teachers College (PLTC) Administration Meeting location: PLTC Campus, Lungi Road, Prot Loko th Date and Time: 14 March 2011 at 12:09 hours Attendees: Ahmed A Koroma (Vice Principal and Director of Studies, PLTC), Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK) Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra Leone) Limited (MIOL). A copy of the Background Information Document on the proposed project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation process and invited the participants to express their issues and concerns. The following key points were raised:  Mr Koroma said that Delco came up with good package of corporate social responsibility. However, they reeled during operations. He welcomes MIOL as Sierra Leone cannot process the iron ore.  Companies provide employment (direct and indirect) apart from revenue that goes to the Government.  He said that biodiversity depletion can divert water to villages and get them extinct by relocation.  Soil depletion – good soils can no longer be fertile.  Toxicity – plants may not do well.  Operations may include removal of vegetation. No reforestation is done although it is in the package. Companies concentrate on the quantity of ore rather than what they should follow.  Mr Ahmed Koroma asked how much the company pays for economic trees e.g. mangoes.  Lease amounts depreciate - He asked what adjustments the Company makes to meet with the rate of inflation.  Planting economic trees will enable livelihoods for some people.  He also mentioned on the policy of the Company. He said that companies come with the Managing Director, accountants, etc. He said that less will be spent on salaries if Sierra Leoneans are employed for jobs they can do.  Congestion may bring health and social problems such as thieving. Those who seek employment and do not get jobs resort to crime.  He said that mining companies usually concentrate assistance in primary and secondary schools and leave the tertiary institutions.  He appealed for support stating that they had sent a proposal to MIOL for a generator and electrification but there has been no reply.  The College intends to develop a technical institution.  Whatever benefit the College receives will be advertised and he believes that it will have a ripple effect.  Blasting may destroy the houses  The company will occupy farmland  Mr Koroma also asked about who determines what is compensated to the people. He said that it should be reasonable and adjustable.  He also mentioned destruction of land and land reclamation. The Company should consider reforestation, reclamation and economic trees.  He reiterated that they lack the structures. Caterers could be trained under their technical department (they currently do community health and business administration). He stated that helping PLTC is helping the district.  Company should consider assistance in the education sector.  Safety aspect was also mentioned. Sharing his experience with Europe, he said that the rail-road crossing could cause accidents. Murialdo Secondary School Meeting location Murialdo Secondary School, Lunsar th Date and Time: 14 March 2011 at 14:50 hours Attendees: Fr. Giuliano Pini (Principal), Fr Emmanuel Koroma, Mr Ambrose Bangura (Vice Principal), Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Aminata Kamara and Lalit Kumar (SRK) Simon Elson gave an introduction to the proposed project and the Marampa Iron Ore (Sierra Leone) Limited (MIOL). A copy of the Background Information Document on the proposed project was presented. Lalit Kumar explained the ESIA process, the stakeholder consultation process and invited the participants to express their issues and concerns. The following key points were raised:  Children suffer when a teacher leaves during school session.  School teachers might leave. Mar Bangura asked if MIOL will fist find out about employment records if a teacher applies for job.  What incentive will be given to the school for teachers to stay?  Teachers who want to leave should notify the school.  Fr Emmanuel said that it is difficult to stop teachers.  At Sierra Rutile, NGOs lobby companies to give incentives to teachers.  There are lots of graduates in the area. Company should be careful not to sideline the trained personnel. If chiefs select those that they like and are employed, even if they are not trained, tensions might crop up.  Chiefs to campaign.  Pupils might leave school to work for the Company. Parents depend on the Catholic mission for education; but if they get jobs and if teachers do not teach well, pupils might leave.  MIOL should follow the employment process.  On the issue of salary payment, people lament that they get less salary than what they sign for, a percentage is taken from their monthly salaries. MIOL to make follow ups rather than leaving all the processes in the local authorities.  Categorise the kind of jobs, do a test and apply the process to wipe out those who are not qualified.  Company should create avenues for incentives – scholarships should be given for university and create support and assurance of employment when they return.  Workers interfere with girls in senior secondary school. MIOL to talk to employees/ discipline  Method of extraction will be similar to Delco- noise, dust, washer, etc.  The agric sector will be affected. Mining will interfere with swamps.  How will the Company store the concentrate?  There will be more demand on food. The soil is good as long as people plant on time and get good seeds.  The environment to be protected.  There is technical vocational institute. LMC come to Murialdo‟s institute for workers. There should be collaboration- teachers to give notice to the school.  The rate of unemployment is high and it was one of the causes of the war. MIOL should try to employ the young people but child labour should be avoided.  Assistance to the school was promised but never given. MIOL never takes part in the activities of this school.  They hoped that this consultation will be a continuous process.  People are sent out of houses because of increase in rent. Teachers cannot cope with increase in rent. There are delays in salaries of teachers,  Job seekers who do not get jobs result to stealing. Marampa Scoping Consultations- Ministries March 2011 Ministry for Mineral Resources th Meeting location: Mining Cadastre Office, Ministry of Mineral Resources, 5 Floor Youyi Building, Brookfields, Freetown st Date and Time: 1 July 2010 at 10.30 am Attendees: Eugene Norman (Assistant Government Mining Engineer) and Alusine Timbo (Assistant Government Mining Engineer), Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), Emily Robinson and Lalit Kumar (SRK)  Simon Elson began by giving an introduction to the Marampa Iron Ore Limited (MIOL) and explaining the status of the Marampa Mining Project. A Background Information Document on the proposed project was presented to the Ministry representatives.  Mr Norman explained that the new Mining and Minerals Act had been implemented since March 2010 and provided us with a document entitled “A Guide for License Holders and Applicants”.  Emily Robinson explained that Cape Lambert intend to undertake an EIA as part of the mining application and asked for any areas that the Ministry would like to be included.  Mr Norman explained that the EIA requirements should be discussed with SLEPA but that from the Ministries perspective, the requirements will depend on the concession. The areas he mentioned specifically that should be covered included landscape, geology and social issues such as resettlement, economic considerations and community development. The new Act provides guidance on social issues.  Mr Norman also explained the role of regional mining engineers in visiting sites and monitoring/auditing the operations from a technical, environmental, social and health and safety perspective, in line with the new act. Sierra Leone Environmental Protection Agency (SLEPA) Meeting location: SLEPA Office, 3rd Floor Youyi Building, Brookfields, Freetown Date and Time: 2nd July 2010 at 10.15 am Attendees: Momodu A Bah, Acting Deputy Executive Director (In-charge of EIA, Field operations & Extensions), SLEPA, Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), and Lalit Kumar (SRK)  Simon Elson explained the status of the Marampa Project and the Background Information Document was presented to Mr Bah (SLEPA).  Mr Bah explained the steps leading to applying for the EIA licence. Which involved the following (in sequence): o Marampa Iron Ore Limited (MIOL) should give a formal letter to SLEPA providing an introduction to the MIOL and a brief profile of the proposed project. SLEPA will respond by opening a file for the project and sending application and screening form to MIOL (the cost of forms is Le 200,000). o MIOL should send filled in application and screening forms to SLEPA for categorisation. Being a mining project the Marampa Project will classify as category A project, hence SLEPA will send a formal letter to conduct the EIA. o MIOL should provide draft Terms of Reference (ToR) for the EIA programme, which SLEPA will review, discuss with MIOL/SRK and approve. o On completion of the EIA as per the approved ToR, MIOL should provide 15 hardcopies of the completed EIA report to SLEPA along with electronic version. SLEPA will send the EIA report to relevant ministries for review. SLEPA will also issue notification in gazette about the EIA and provide a format to MIOL for announcement in a local newspaper. MIOL should issue an advertisement in the newspapers as per the format received from SLEPA. o SLEPA will allow 14 days disclosure period to receive feedback from stakeholders. On completion of the EIA, MIOL should organise consultation meetings with stakeholders which should be held in the presence of SLEPA representatives. o On completion of the stakeholder meetings, MIOL should submit a disclosure report to SLEPA. o On completion of the 14 days disclosure period and receipt of disclosure report, SLEPA will send the EIA to its board for approval. The board comprises of experts from different ministries. Based on board‟s review the EIA licence is issued which may be subject to fulfilling certain terms and conditions. The EIA licence is non-transferable.  Mr Bah provided his contact address as follows: Mr Momodu A. Bah, Acting Deputy Director Incharge of EIAs, Field operations & extensions, SLEPA, rd 3 Floor, Youyi Building, Brookfields, Freetown, Sierra Leone Mobile number: 078350627, 076668698, 088351725 Email: modbah@yahoo.com  Mr Bah confirmed that the most recent regulations were contained in the EPA Act 2008 and the guidelines on EIA procedures issued in 2002 were still valid.  Mr Bah also informed that SLEPA has started the process of preparing sector specific EIA guidelines with technical assistance from EU. However until these are ready MIOL/SRK could refer to World Bank‟s guidelines for the mining and other relevant sectors.  SRK informed Mr Bah that it has installed a meteorological monitoring station at MIOL‟s project office in Lunsar. Mr Bah suggested that MIOL should formally inform the Meteorological Department about installation of the monitoring station. Forestry Department, Ministry of Agriculture st Meeting location: Forestry Department, 1 Floor, Youyi Building, Brookfields, Freetown Date and Time: 2nd July 2010 at 11.30 am Attendees: Mr Abdul-Abib F Conteh, Deputy Director, Forestry Division, Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), and Lalit Kumar (SRK)  Simon Elson explained the status of the Marampa Project and the Background Information Document was presented to Mr Conteh.  Mr Conteh informed that the Forestry Act 1988 was currently in the last stages of review by the Law Reform Commission. It was due for presenting to the parliament and may come into force in next 6 months. In the meantime he suggested that MIOL should refer to the existing Act to comply with national regulations.  Mr Conteh asked MIOL to procure, from the office of Sierra Leone Information System (SLIS), an official copy of the map showing boundaries of national parks, forest estates, and wetland conservation sites in Sierra Leone to check if the project area was not interfering with any protected areas.  Although the proposed project was unlikely to interfere with any existing protected area, Mr Conteh suggested that MIOL should still send a formal letter to Minister of Agriculture (and Forestry) informing about the intention to develop the Marampa project. The letter should describe the location and project footprint area on the map and provide names of villages and chiefdoms that are likely to be within the project footprint area.  The minister will send the above letter to Director of Forestry and other relevant departments for review and issue permission to proceed with the proposed project. Ministry of Internal Affairs, Local Government and Rural Development Meeting location: Ministry of Local Government, Youyi Building, Brookfields, Freetown Date and Time: 2nd July 2010 at 12.30 pm Attendees: Director, Ministry of Local Government, Simon Elson (Cape Lambert) representing the Marampa Iron Ore Limited (MIOL), and Lalit Kumar (SRK)  Simon Elson explained the status of the Marampa Project and the Background Information Document was presented to the Director.  The Director explained that the role of the ministry representative on the Minerals Advisory Board was to oversee (if required) the agreement between land owners and mining companies. This role has been given to the ministry as the Paramount Chiefs and other community chiefs come under its jurisdiction. This becomes necessary because land in provinces is held in community trust through the Paramount Chiefs. While the right over minerals can be passed by the government on to the mining companies it still needs permission from the community to mine.  He also informed that in the new Minerals Act (2009) there is provision for mining companies to discuss with local community and agree upon its corporate responsibility in terms of what developmental assistance will be given to community. The Ministry and the Paramount Chiefs are usually key players in such negotiations.  It is Ministry‟s intention to help create cordial environment between project developers and communities for peaceful co-existence.  The Director asked MIOL to send a formal letter to the Ministry to inform its intention to develop the Marampa Mining Project and seek its cooperation in community relations. Marampa Scoping Consultations- Stakeholders March 2011 1. Foreroad Baka Women’s Association Meeting location: Foreroad Baka Village, Lunsar (suburb) th Date and Time: 13 March 2011, 11 AM Attendees: See attached (scanned) for list of group members, Simon Elson (representing the Marampa Iron Ore (SL) Limited, Aminata Kamara and Lalit Kumar (both SRK) Intro para  General introduction about the group (by the chair): o There are many women‟s organisations in Lunsar o Appreciate the current employment opportunities by MIOL o Women carry majority of burden at household level, most men don‟t help with household duties or in vegetable farming o Women don‟t have formal education, they are skilled only in farming and gardening o Food insecurity is a key challenge faced by the members o Vegetable farms are affected by brown coloured ants which damage the crops o 13 women among those present for the meeting are single (are widow or do not have support from men), however they have children to support o There are three women in the group who can read and write o The group is three years old, it has 51 members, meets twice a month and collect Le2000 on monthly basis o it last year received assistance from MIOL in the form of seeds for cultivating groundnut  Some women want to work at the mine but are not considered for jobs. They expect MIOL not to ignore women in the potential employment opportunities.  Expect assistance/support for business activities and with building up of a storage facility for crops/produce. 2. Mabesene Women’s Association Meeting location: Mabesene Village, Lunsar th Date and Time: 13 March 2011, 1 PM Attendees: See attached (scanned) for list of group members, Simon Elson (representing the Marampa Iron Ore (SL) Limited, Aminata Kamara and Lalit Kumar (both SRK) Intro para  General introduction about the group (by the chair): o The group had received support from MIOL for Cassava growing project on farm if 3 Acres, but it did not succeed as the grasshoppers destroyed the crops o Now the group is trying to cultivate leafy vegetables in the swamp areas o The group was started in 1998 but had to leave the area during the war, on its returned it was faced with difficulty of bringing people together o Besides farming the group also does weaving and gara-tie dyeing (some women also know sewing)  Expect MIOL to: o continue supporting the group with seed supply for cassava and groundnut o assistance in fighting with the problem of grasshoppers and other pests o toilet facilities, water supply and expansion of agricultural assistance  They are happy that some people are getting jobs but none of their own family members have succeeded in getting job. In order to get a job one has to pay 200 to 400 thousand Leones.  Concerned that the blasting activity will damage their houses as the house structures are already weak and some have cracks. Remember that during Delco operations the vibrations due to blasting had caused damaged to houses. Sometimes stones/debris would fly and land into the village.  The Magbenkte Village is experiencing increase in water level. It is surrounded by old Dleco Lake, where some digging is being undertaken (not clear if this is in LM area). Hence there is fear of flooding.  Other apprehensions are: o Illness due to dust o Heavy machines may shake houses o Increase in accidents due to increase in traffic o Jobs will be taken by outsiders as is the current practice SRK Consulting Marampa Iron Ore Project – Technical Appendix 3 APPENDIX 3. DISCLOSURE MATERIAL U3823_Marampa_SEP_Final.docx August, 2012 Page 3i of 3i MARAMPA IRON ORE PROJECT BACKGROUND INFORMATION DOCUMENT March 2011 This document provides information on the proposed Marampa Iron Ore Project and explains the Environmental and Social Impact Assessment (ESIA) process that is being undertaken. 1. Background The Marampa Iron Ore Project (the Project) is a hematite iron ore project which is currently at the exploration and evaluation stage. The Project is owned by Marampa Iron Ore (SL) Limited (the Company), which is 100% owned by Marampa Iron Ore Limited, a wholly owned subsidiary of Australian company Cape Lambert Resources Limited. The Project is located on 2 exploration license EXPL09/06, which covers a 305 km at Lunsar, in the Port Loko District of Sierra Leone. The license area encloses but excludes the closed and abandoned Marampa mine, which was operated by Delco until 1975 and is now owned by London Mining Plc. The Company is currently studying the area from a technical perspective and they have appointed SRK Consulting (UK) Ltd (SRK) to commence an Environmental and Social Impact Assessment (ESIA) process, known as an EIA in Sierra Leone, which, during the course of the study, will assess potential impacts of the construction and operational phase of the proposed mine. This assessment process will interact with the technical studies as much as possible. Figure 1: Location of the Marampa Iron Ore Project 2. Project Description The Company has completed initial exploration drilling of specular hematite deposits at the Gafal West Prospect and the Matukia Prospect (see tentative project layout in Figure 2). The maiden Project mineral resource has been estimated at 197 million tonnes by Golder Associates Pty Ltd in accordance with the JORC Code. There is potential to mine this resource by open pit mining methods, including drilling, blasting, loading and hauling operations, and processed at an on-site beneficiation plant comprising; crushing, grinding, and concentrate cleaning via wet high-intensity magnetic separation. Waste material will be stored in waste rock dumps and a tailings storage facility. The Company has undertaken a preliminary engineering and infrastructure study in 2010, and is continuing with a pre-feasibility study as well as further drilling of the two prospects through 2011. Construction of the Project, if determined feasible, would not occur until 2012 at the earliest. Based on preliminary assumptions, water for the Project will be supplied via a pump from the nearby Rokel River and power will be supplied from a purpose-built on-site power station. Other site infrastructure, such as the beneficiation plant, offices, workshops and accommodation, will also need to be constructed. The ore would be transported from the site via the 84 km existing railway to Pepel Port. The railway and port are currently in the process of being refurbished by others, and will be operated and maintained by a third party. 3. Regulatory framework and ESIA process The ESIA process is being undertaken in accordance with Sierra Leone laws and regulations, as well as internationally accepted best practices. The process follows three main steps (see below). The Screening and Scoping Phase is to decide if an ESIA is required and defines the contents of the assessment. The Impact Assessment Phase rates the significance of the potential impacts to assess whether there will be any unacceptable impacts resulting from the Project that cannot be managed. The ESIA team will also assess project alternatives and will provide environmental input into the Project decision- making processes. SCREENING AND SCOPING PHASE • Initial site visit and review of existing data • Consultations with regulatory agencies to identify their requirements • Research of national and international regulations • Develop Terms of Reference for specialist studies with SLEPA • Consultations with community based stakeholders to identify their concerns and issues IMPACT ASSESSMENT PHASE • Specialist baseline studies • Identification and assessment of potential impacts on the environment and local community • Stakeholder consultations to report the outcomes of the ESIA MANAGEMENT PLANNING PHASE • Design of measures to reduce the significance of the impacts • Development of a plan to manage and monitor the impacts Review and decision by SLEPA Specialist studies are being undertaken to determine the current environmental and social conditions of the study area. The type of studies required has been determined from the screening and scoping phase, and include assessment of potential impacts on climate and air quality, water resources (including surface water, groundwater and water chemistry), soils, geochemistry, noise, landscape (visual impacts), ecology and biodiversity (flora and fauna), socio-economic factors, archaeology and cultural heritage. 5. Consultation Process Consulting with the Project stakeholders (the interested and affected parties) is a very important part of the ESIA process, so that the Project developers and decision makers can take account of their views. For the Project, SRK intend to consult with stakeholders at least twice; firstly during the Screening and Scoping Phase to identify potential issues and concerns of the Project stakeholders and secondly on completion of the ESIA to report back findings of the assessment process. As the Project becomes more definitive, stakeholders will also be able to make comments throughout the life of the Project through a recognized pathway. The scoping consultations are further split into two rounds, the first round with key governmental stakeholders was completed in July 2010 and the second one covering the potentially affected community members, relevant Paramount Chiefs, Village Chiefs, general public and any other stakeholders will take place in March 2011. 6. Issues and Concerns Any issue and concerns raised by stakeholders, as well as the responses to them, will be recorded throughout the assessment process and will be included in the final ESIA report. If you have any comments, please contact Chris Gybl (Marampa Iron Ore (SL) Limited) email Information@miolb.com) or Nicola Rump (SRK Consulting email nrump@srk.co.uk). Figure 2: Tentative Project Layout                                   Marampa Iron Ore Project      General Fact Sheet                                                Updated: March 2011      Contact: information@miolb.com        Nominal Project Layout    Project  Engineering Studies  Infrastructure  Mineral Resource  Engineering Studies being conducted:  Railway and Port  • 197.2 Mt @ 28.5% Fe  • Metallurgical Testwork  • Access agreement in place to Pepel Railway  As at 12 November 2010  • Process Plant Development and Layout  and Port  • Drilling continues to target 500 Mt  • Geotechnical  Water  Production  • Hydrology  • Power Assessment  • Source from Rokel River  • Initial 5 Mtpa    Power  • Plant Expandable to 10 Mtpa  Environmental and Social Studies  • Construct standalone Heavy Fuel Oil Power  Capital Investment – US$  Station nominally 70 MW for 5 Mtpa plant  Civil  $ 34 M  Baseline Studies being undertaken for ESHIA    Mining  $ 8 M  • Geomorphology and Soils Assessment    Process Plant  $ 307 M  • Geochemistry    Infrastructure  $ 95 M  • Climate and Air Quality    Mobile Fleet  $ 10 M  • Noise Assessment.    Indirect Costs  $ 91 M  • Ecology and Biodiversity Assessment    Contingency  $ 200 M  (Stage 1 Complete)    Total  $ 655 M  • Water Resources    • Socio Economic    Key Milestones Targetted  • Archaeology and cultural heritage    • ESHIA Licence  2011    • Mining Lease  2012  Economic Impact  Legend  • Feasibility Study  2012  Total Construction workforce:  800  • Detailed Engineering  2012  ESHIA  Environmental, Social and Health Impact  • Project Finance  2011 / 12  Permanent Workforce:  630  Assessment  • Construction  2012  Fe  Iron  Indirect Jobs:  ~ 2,000  M  Million  • First Production  2013  Mt  Million Tonnes    Export Revenue: LoM Nominally USD 7 Billion  Mtpa  Million Tonnes per Annum    Royalties:  3% of Revenue  MW  Mega Watts      US$  United States Dollars    LoM  Life of Mine    MARAMPA PROJECT DEVELOPMENT OVERVIEW DRILLING RESOURCE ESTIMATION EXPLORATION 2-3 YEARS STUDY AND PUBLIC RESEARCH CONSULTATIONS FEASIBILITY STUDIES 2011 CONSTRUCTION NO FURTHER STUDIES OR IF POSITIVE? NO PROJECT YES CONSTRUCTION MINING 2012 PROCESSING MINING OPERATIONS LATE 2013 COMMUNITY TRANSPORTATION DEVELOPMENT MARCH 2011 SRK Consulting Engineers and Scientists LOCATION OF THE MARAMPA PROJECT IN SIERRA LEONE NOMINAL PROJECT LAYOUT MARCH 2011 SRK Consulting Engineers and Scientists SCOPING CONSULTATIONS WITH PROJECT STAKEHOLDERS Environmental and Social Impact Assessment (ESIA) Marampa Iron Ore Mining Project PROJECT INTRODUCTION • The project is owned by Marampa Iron Ore (Sierra Leone) Limited, which in turn is owned by Cape Lambert of Australia • Exploration license EXPL09/06 PROJECT FACTS Key facts • 197.2 Mt (Nov 2010) • Target 500 Mt • Initial production 5Mtpa raise to 10 Mtpa Water • Source from Rokel River Power • Standalone Heavy Fuel Oil Power Station : 70MW for 5 Mtpa Nominal Project Layout ECONOMIC IMPACTS • Total investment: $655 M • Construction workforce: 800 • Operation workforce: 630 • Royalties 3% of revenue Environmental and Social Impact Assessment Process • Sierra Leone Environmental Protection Agency Act 2008 • International standards and best practices LIST OF ENVIRONMENTAL AND SOCIAL BASELINE STUDIES • Ecology and biodiversity (flora and fauna) • Socio-economic • Water resources • Climate & air quality • Soils & Geochemistry • Noise • Landscape (visual impacts) • Archaeology and cultural heritage ESIA AND CONSULTATION PROCESS ENVIRONMENTAL AND SOCIAL SCOPING STUDY 2010 SCOPING CONSULTATIONS WITH STAKEHOLDERS RELEVANT MINISTRIES (JULY 2010) LOCAL STAKEHOLDERS (MARCH 2011) ENVIRONMENTAL AND SOCIAL BASELINE STUDY PROGRAMME 2011 IMPACT ASSESSMENT AND MANAGEMENT PLANNING 2011 ESIA REPORT DISCLOSURE AND FEEDBACK CONSULTATIONS IDENTIFICATION OF STAKEHOLDER ISSUES AND CONCERNS QUESTIONS AND FEEDBACK FROM THE STAKEHOLDERS SRK Consulting Marampa Iron Ore Project – Technical Appendix 4 APPENDIX 4. PHOTOS U3823_Marampa_SEP_Final.docx August, 2012 Page 4i of 4iv SRK Consulting Marampa Iron Ore Project – Technical Appendix 4 Open Pubilc Meeting, Lunsar Open Public Meeting, Lunsar U3823_Marampa_SEP_Final.docx August, 2012 Page 4ii of 4iv SRK Consulting Marampa Iron Ore Project – Technical Appendix 4 Meeting with Amazonian Initiative Movement (AIM), Lunsar Meeting with Mabesene Women’s Group U3823_Marampa_SEP_Final.docx August, 2012 Page 4iii of 4iv SRK Consulting Marampa Iron Ore Project – Technical Appendix 4 Meeting with Foreroad Baka Women’s Association Village meeting in Mafira U3823_Marampa_SEP_Final.docx August, 2012 Page 4iv of 4iv SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 APPENDIX 5. ISSUES AND RESPONSE RECORD U3823_Marampa_SEP_Final.docx August, 2012 Page 5i of 5xxiii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) Employment 16, 09-Mar-11 Soldier Street, Green Scenery, Port Loko Local youths, indigenes and land MIOL appreciates it is important to establish 81, 11-Mar-11 Freetown/ Chief District Council, Public Meeting, owners should be involved in the good relations with the communities Administrator’s Murialdo Secondary School, d development (including the youth) and is committed to 92, 12-Mar-11 employment an 157, 14-Mar-11 Office, Port District Medical Officer Port process. This will avoid conflict. preferential employment of local people 133, Loko District Loko How will this be undertaken? Will (see Impact ED1 in the ESIS). 80 Council, Port vacancies be advertised? Loko /Town A Recruitment Plan will be developed to Hall, Lunsar / address this issue (see enhancement Murialdo measures listed for Impact ED1 in the ESIS) Secondary School, Lunsar 46 09-Mar-11 Cotton Tree Cotton Tree Foundation Concerns over the decline in Foundation people working in agricultural Office, King production due to employment Street, opportunities in mining. This will Freetown reduce the availability of farm workers and increase pressure on food resources. 54, 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement, Preferential employment of local 74, 11-Mar-11 Highway, Port Loko District Council, people over outsiders. 130 13-Mar-11 Lunsar / Chief Mabesene Women’s Administrator’s Association, Public Meeting Office, Port Loko District Council, Port Loko /Mabesene Village, Lunsar 3 Where actions over and above the commitments stipulated in the ESIA and specific to the comment raised are required, these are indicated in italics and will be followed up as part of the implementation of the ESMS outlined in the ESIS. U3823_Marampa_SEP_Final.docx August, 2012 Page 5ii of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 55 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement Compensation should be given to This will be part of the employment contract. Highway, employees who are made Impacts relating to retrenchment are Lunsar redundant as this can have a assessed in the ESIS (see Impact DC1) and psychological impact. MIOL has committed to the mitigation measures listed. 63, 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement, Women must be considered for Agreed and this will be reflected in the 119, 13-Mar-11 Highway, Foreroad Baka Women’s employment and child labour must Human Resources policy to be developed Association, Murialdo Section 11.1.1 of ESIS) and 157 Lunsar be avoided. by MIOL ( /Foreroad Baka Secondary School Recruitment Plan (see enhancement Village, Lunsar measures for Impact ED1 in the ESIS). (suburb) 63 a, 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement, Human resources must be carried See above (Impact ED1 and associated 94 Highway, Public Meeting out in a legitimate manner. An management measures) Lunsar appropriate recruitment process should be undertaken. 93 12-Mar-11 Town Hall, Public Meeting Chairman - Hon Local stakeholders should be See above (Impact ED1 and associated Lunsar Alhaji O Daramy contacted because they have management measures) technical and educated youths that are capable of doing any company job. 149 14-Mar-11 PLTC Campus, Port Loko Teachers College Mining employees should be MIOL is committed to developing a training Lungi Road, trained through the technical and skills development plan as part of its Prot Loko department of the college. Recruitment Plan (see enhancement measures listed for Impact ED1). MIOL will consider inclusion of use of the technical department in the training and skills development plan. 150, 14-Mar-11 Murialdo Murialdo Secondary School, Concerns teachers will leave the Noted. MIOL will continue dialogue with the 117 12-Mar-11 Secondary Public Meeting school to work in mining. This will school to keep track of the problem and if School, Lunsar / disrupt the pupils progress. What necessary jointly identify measures to Town Hall, incentive will be given for teachers address it. Lunsar to stay? U3823_Marampa_SEP_Final.docx August, 2012 Page 5iii of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 152 14-Mar-11 Murialdo Murialdo Secondary School Concerns that children will leave Child labour will not permitted as part of the Secondary school to work for the mining Human Resources Policy. School, Lunsar company. 153 14-Mar-11 Murialdo Murialdo Secondary School Concern over inconsistency Noted. See above (Impact ED1 and Secondary between employees monthly associated management measures) and School, Lunsar salary and the salary they were MIOL human resources manager to follow initially told. A percentage may be up on the issue of salaries. taken from their monthly salaries. MIOL should deal with salary payments, not the local authorities. 154 14-Mar-11 Murialdo Murialdo Secondary School Concern about This has been identified and assessed as a Secondary foreigners/employees coming from potential impact in the ESIS (Impact SO2) outside and increasing the School, Lunsar and MIOL has committed to the mitigation vulnerability of young girls to measures listed. becoming involved in the sex industry. MIOL need to talk to employees about this. Noted. MIOL will consider inclusion in the 143 Port Loko Teachers College Mining companies concentrate Community Development programme. assistance in primary and secondary schools. Tertiary institutions should be considered. 141 14-Mar-11 PLTC Campus, Port Loko Teachers College Money can be saved if jobs higher Noted and see above (Impact ED1 and Lungi Road, up can be given to Sierra associated management measures), where Prot Loko Leoneans. suitable skill levels exist local people will be employed. 131 13-Mar-11 Mabesene Mabesene Women’s Alleged concerns that in order to Noted and see above (Impact ED1 and Village, Lunsar Association get a job one has to pay 200 to associated management measures). 400 thousand Leones. MIOL will investigate allegations and develop a fair and transparent recruitment plan. U3823_Marampa_SEP_Final.docx August, 2012 Page 5iv of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 109 12-Mar-11 Town Hall, Public Meeting attendee Request for employment of local Noted and see above (Impact ED1 and Lunsar youth. associated management measures). Environment 14, 09-Mar-11 Soldier Street, Green Scenery, Port Loko Concerns over mining operations The preliminary Project layout has taken 18, 14-Mar-11 Freetown / Teachers College clearing swamps and forests. these areas into account and where 146 PLTC Campus, Reforestation and economic trees possible they have been avoided. Only a Lungi Road, should be provided. small area of gallery forest (1.25 ha) and no Prot Loko swamp forest will be cleared. Impacts on habitat are assessed in the ESIS (Impact EB1) and appropriate compensation for losses to local communities will be addressed through a Resettlement Action Plan (see mitigation measures listed for Impact RL1). 30 09-Mar-11 Upper Brook Environmental Forum for Action Concerns over the greenhouse Noted. The contribution of the Project to Street, effect from iron ore mining. Will greenhouse gases or climate change has Freetown MIOL include activities for not been included in the ESIA but is communities to cope with climate considered to be negligible. change? 32c 09-Mar-11 Upper Brook Environmental Forum for Action What will MIOL do about flora and Assessment of the impacts on biodiversity Street, fauna biodiversity loss from mining resulting from the Project is included in the Freetown activities? ESIS (Impacts EB1-4), and MIOL has committed to the mitigation measures listed. 33 09-Mar-11 Upper Brook Environmental Forum for Action The level of the water table is a Impacts on groundwater levels resulting Street, serious problem as it is rapidly from pit dewatering have been assessed in Freetown being depleted. This needs to be Impact WR1 of the ESIS. MIOL has addressed. committed to the mitigation measures listed, which include provision of water to affected communities if required. MIOL will continue to actively consult with affected communities in accordance with this SEP. 31 09-Mar-11 Upper Brook Environmental Forum for Action Concerns about visual impacts as Visual impacts are assessed in the ESIS Street, the landscape will be destroyed. (Impact LT3). MIOL has committed to the Freetown mitigation measures listed to minimise U3823_Marampa_SEP_Final.docx August, 2012 Page 5v of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) visual impacts. 41 09-Mar-11 Upper Brook Environmental Forum for Action The Company should choose the Local indigenous species will be used for rehabilitation where possible, and expert Street, vegetation species for advice will be sought in this regard. Freetown rehabilitation carefully, as Gethropha is detrimental to local Consideration of this will be included in the water bodies. Rehabilitation Plan. 45 09-Mar-11 Cotton Tree Cotton Tree Foundation Agricultural support should be MIOL has committed to supporting various Foundation provided as plantations can help livelihood strategies for affected Office, King rehabilitate the soil. communities (see mitigation measures Street, listed for Impact RL1 in the ESIS). MIOL will Freetown consider inclusion of agricultural support in Community Development programme. 71 11-Mar-11 Chief Port Loko District Council Concerns over air pollution and Specialists have quantitatively modelled the Administrator’s the effect dust pollution will have potential impacts on air quality in the Office, Port on the environment. surrounding area, the results of which are Loko District summarised in Impact AQ1 of the ESIS. Council, Port MIOL has committed to the mitigation Loko measures listed. 58 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement Concerns over the chemicals used No chemicals will be used in boreholes. A Highway, in boreholes and the distance from water quality monitoring programme is in Lunsar these to the wells. A sufficient place to monitor changes to water quality on distance should be provided. an ongoing basis. 155 14-Mar-11 Murialdo Murialdo Secondary School Mining will interfere with the Impacts on wetland areas resulting from pit Secondary swamps and the agricultural dewatering and changes to surface water School, Lunsar sector. flow have been assessed in Impacts WR1 and WR3 of the ESIS. MIOL has committed to the mitigation measures listed, which include making alternative wetland areas available. Compensation for land lost will be addressed through the RAP (see Impact RL1). U3823_Marampa_SEP_Final.docx August, 2012 Page 5vi of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 146 14-Mar-11 PLTC Campus, Port Loko Teachers College Concerns over the destruction of Impacts due to land acquisition and Lungi Road, land and land reclamation. relocation are assessed in Impact RL1 in Prot Loko the ESIA. MIOL has committed to the mitigation measures listed, which include preparation of a RAP in consultation with communities. The concerns will be addressed through the RAP. 136 14-Mar-11 PLTC Campus, Port Loko Teachers College Concerns over infertile soil and Impacts relating to soil erosion and land Lungi Road, depletion, resulting in plants not capability are assessed in Impacts LT4 and Prot Loko being able to grow due to toxicity. LT5. Changes in soil chemistry resulting from fugitive dust are not expected, and MIOL has committed to the mitigation measures listed. 135 14-Mar-11 PLTC Campus, Port Loko Teachers College Changes in the water table can Agreed. Impacts on wetland areas resulting Lungi Road, result in biodiversity loss. from pit dewatering have been assessed in Prot Loko Impact WR1 of the ESIS. MIOL has committed to the mitigation measures listed. 122 13-Mar-11 Mabesene Mabesene Women’s A request for assistance in the Request noted. MIOL is yet to decide which Village, Lunsar Association termination of grasshoppers and community development initiatives to other pests. support in consultation with communities. MIOL will consider inclusion in Community Development Programme. 118 12-Mar-11 Town Hall, Public Meeting attendee Concerns about the sludge which Waste will not be deposited in wetlands or Lunsar will damage the swamps and any other natural areas. Sewage sludge will directly affect agriculture. be deposited in a landfill after appropriate treatment, and sludge from HFO's will be removed from site for appropriate disposal. MIOL will develop a Waste Management Plan (Section 11.1.4 of the ESIS) detailing the management of wastes produced. U3823_Marampa_SEP_Final.docx August, 2012 Page 5vii of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 85 11-Mar-11 District Ministry of Agriculture and Food Environmental degradation around Noted. Impacts relating to soil erosion due Agriculture Security Mange Acre (a village beyond the to clearing of vegetation have been Officer’s Office, Project area) has occurred and assessed in the ESIA as Impact LT4, and MAFS, Port planting fast growing trees such as MIOL has committed to the mitigation Loko tectona grandis (Teak) and acacia measures listed, which include revegetation should be undertaken for of disturbed areas as soon as possible. prevention of soil erosion. Expert advice will be sought and recommendations regarding suitable species for use during revegetation will be included in the Rehabilitation Plan (Section 11.1.4 of the ESIS). 86 11-Mar-11 District Ministry of Agriculture and Food Trees should not be cut down as Noted. Disturbance of trees and particularly Agriculture Security this interrupts the water table indigenous forest habitat will minimised – measures to this effect will be included in Officer’s Office, which is currently a serious MAFS, Port problem. the Construction Management Plan Loko (Section 11.1.4 of the ESIS). 88 11-Mar-11 District Ministry of Agriculture and Food MAFS (Port Loko) want to work in Noted. MIOL will engage in further consultation with MAFS in this regard. Agriculture Security partnership in reforestation Officer’s Office, programmes. MAFS, Port Loko 11 09-Mar-11 Soldier Street, Green Scenery Concern over the inappropriate Tailings material will be disposed of in a Freetown disposal of tailings. dedicated and appropriately designed Tailings Storage Facility (see detail in Section 4.4 of the ESIS and Appendix 5), and used to backfill Matukia pit, with suitable design requirements in place. No tailings material will be disposed of elsewhere. CSR 3 09-Mar-11 NMJD Office, Network Movement for Justice Allocation of 1% of revenues for Noted. MIOL will investigate options for 49 Main Motor and Development local development. investment in local development through a Road, Community Development Plan (Section Brookfields, 11.1.4 of the ESIS). Freetown U3823_Marampa_SEP_Final.docx August, 2012 Page 5viii of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 13 09-Mar-11 Soldier Street, Green Scenery, Environmental Communities should be helped to Noted. However no impacts on climate Freetown Forum for Action cope with climatic impact. resulting from the Project are anticipated. 22 09-Mar-11 Soldier Street, Green Scenery Communities should be involved in Chapter 8 of the ESIA proposes a Freetown rehabilitation programmes, such Livelihood Restoration Plan. MIOL will as tree planting, as this will consider the inclusion of specific Projects in provide employment. the livelihood restoration measures included in the Community Development Plan (Section 11.1.4 of the ESIS) in consultation with community members 27, 09-Mar-11 Upper Brook Environmental Forum for Action, Local people, landowners and Noted. The Project’s contribution to local 70, 97 11-Mar-11 Street, Port Loko District Council, children should benefit from economic development has been assessed 12-Mar-11 Freetown /Chief Public Meeting mining operations in their area and in the ESIA (Section 8.1) and MIOL has Administrator’s help should be provided to the committed to the enhancement measures Office, Port communities. listed, to improve benefits to local Loko District communities. Council, Port Loko / Town Hall, Lunsar 32d 09-Mar-11 Upper Brook Environmental Forum for Action What will the budget be for The budget estimate will be an outcome of Street, environmental/community the detailed management action planning if Freetown strategies which mitigate the effect the Project goes ahead. MIOL will devise a mining operations will have. detailed management action plan, including budgetary estimations. 73 11-Mar-11 Chief Port Loko District Council MIOL should develop tangible Noted. MIOL will include this in the Administrator’s structures instead of just giving out Community Development Plan (Section Office, Port money, such as incorporating 11.1.4 of the ESIS). Loko District facilities into their social Council, Port programmes such as Peripheral Loko Health Units and hospitals. 76 11-Mar-11 Chief Port Loko District Council MIOL needs to recognise basic Noted. MIOL has committed to developing a Administrator’s development principles/corporate Community Development Plan in Office, Port social responsibilities. consultation with local communities. Loko District Council, Port Loko U3823_Marampa_SEP_Final.docx August, 2012 Page 5ix of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) Noted. MIOL will consider inclusion in 98 12-Mar-11 Town Hall, Public Meeting attendee Medical assistance should be Lunsar provided through facilities and Community Development Plan (Section 11.1.4 of the ESIS). especially a malaria control programme as mosquitoes breed in the ponds and pits mining companies have produced. 104 12-Mar-11 Town Hall, Public Meeting attendee A request to give children This is an ongoing programme and could be Lunsar scholarships. expanded if the Project goes ahead. MIOL will consider inclusion in Community Development Plan (Section 11.1.4 of the ESIS). 100, 12-Mar-11 Town Hall, Public Meeting attendee High quality schools, hospitals and This is not MIOL's but government's 105 Lunsar roads should be built. responsibility. 106 12-Mar-11 Town Hall, Public Meeting attendee Safe drinking water should be MIOL will provide safe drinking water to Lunsar provided to the communities. Project-affected communities if impacts are shown to occur, currently no impacts on water quality are predicted (Impact WR6). 91 12-Mar-11 Town Hall, Public Meeting attendee Delco left houses, therefore the Replacement housing will be built for Lunsar Company has no right to destroy affected community members under the them without building new ones. RAP. 96 12-Mar-11 Town Hall, Public Meeting attendee Preference towards local This is acknowledged in Chapter 8 of the Lunsar businesses and shops for ESIS, which includes enhancement purchase of provisions and measures MIOL has committed to, to supplies. maximise benefits to local suppliers (Impact ED4 and associated management measures). 101 12-Mar-11 Town Hall, Public Meeting attendee Programmes in which women can Noted. Impacts on vulnerable groups Lunsar become involved should go (including women) are acknowledged in directly to them giving them the Chapter 8 of the ESIA. MIOL will consider opportunity to participate. vulnerable groups in the Community Development Plan (Section 11.1.4 of the ESIS). U3823_Marampa_SEP_Final.docx August, 2012 Page 5x of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 83 11-Mar-11 Chief Port Loko District Council People who are affected directly Noted. This is acknowledged in the ESIA, Administrator’s should be the first to benefit and MIOL has committed to the Office, Port enhancement measures listed in Section Loko District 8.1, which focus on benefits to affected Council, Port communities. Loko 57 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement Concerns over displacement as Impacts relating to other Projects are Highway, LMC has threatened to move the beyond the scope of this ESIA or MIOL's Lunsar people who are living in the area of influence. Relocation of quarters built by Delco. Will new communities affected by MIOL's Project will houses be built? Demolition will be addressed via the RAP (Impact RL1). create tension therefore an amicable decision should be reached. 82 11-Mar-11 Chief Port Loko District Council MIOL should contact the Council Agreed. MIOL will follow up with the local Administrator’s for community programmes to council in this regard when preparing the Office, Port avoid duplication. Community Development Plan (Section Loko District 11.1.4 of the ESIS). Council, Port Loko 144 14-Mar-11 PLTC Campus, Port Loko Teachers College A proposal has been sent to MIOL Noted. MIOL will take up the proposal for Lungi Road, for a generator and electrification consideration as part of the Community Prot Loko but there has been no reply. Development Plan. 2 09-Mar-11 NMJD Office, Network Movement for Justice The Project cost should include Agreed. Cost for resettlement will be 49 Main Motor and Development the cost of resettlement, included. MIOL has committed to a RAP Road, compensation for crops and (Impact RL1), which will include this. Brookfields, community infrastructure. Despite Freetown the Government not currently having a resettlement policy, it is important that companies go about resettlement correctly. Business Operations U3823_Marampa_SEP_Final.docx August, 2012 Page 5xi of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 1, 116 09/03/2011, NMJD Office, Network Movement for Justice Mining companies should use Agreed. MIOL is using not just national laws 12/03/2011 49 Main Motor and Development, Public international laws as national laws but referring to international standards as Road, Meeting are weak. well for the ESIA process (Section 2.2 of Brookfields, ESIS). Freetown / Town Hall, Lunsar 5,15 09-Mar-11 NMJD Office, Network Movement for Justice What is the relationship between There is no relationship with London Mining 49 Main Motor and Development, Green London Mining, MIOL and African and African Minerals, except that African Road, Scenery Minerals Limited? Minerals is a shareholder in Cape Lambert Brookfields, who own MIOL. Freetown 7 09-Mar-11 Soldier Street, Green Scenery Concerns over companies moving Noted. MIOL is strongly committed to Freetown fast with their operations and following the correct procedures. procedures not being followed properly. 20 09-Mar-11 Soldier Street, Green Scenery Concern over the issue of change Noted. International good practice, which Freetown in company ownership resulting in MIOL has committed to requires the a displacement of liabilities. Will a company to make provision for rehabilitation bond be left behind for new should it decide to close the operation. companies to take up? When companies sell on mining Projects, the new owners do not usually take on the liabilities of the old companies (example Sierra Rutile and Koidu Holdings). In such situations the government does not have the capacity to monitor liabilities, and NGOs tend to become involved. 72 11-Mar-11 Chief Port Loko District Council It is important for MIOL to conform Agreed. MIOL is committed to conforming to Administrator’s to local laws. all national laws and also to international Office, Port good practice. Loko District Council, Port U3823_Marampa_SEP_Final.docx August, 2012 Page 5xii of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) Loko 61 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement All three mining companies (MIOL, Noted. A degree of collaboration in this Highway, AML and LMC) should come regard between AML and MIOL with regard Lunsar together to construct one road and to shared use of rail (and possibly port) railway. infrastructure for product export has been agreed to (Section 4 of the ESIS). 69 11-Mar-11 The Manager’s Marampa Community Bank MIOL should use Marampa Noted. Office, Community Bank for domestic Marampa banking and to pay staff salaries Community as this will allow for an Bank, Lunsar improvement in community infrastructure. 84 11-Mar-11 Chief Port Loko District Council Company information will be MIOL will provide the legally required Administrator’s disseminated to the Government documents to relevant authorities and Office, Port and other agencies. communicate to stakeholders as specified Loko District in this SEP. Council, Port Loko 139 14-Mar-11 PLTC Campus, Port Loko Teachers College What adjustments do MIOL make This level of detail has not yet been Lungi Road, in order to meet with the rate of determined. Prot Loko inflation? 115 12-Mar-11 Town Hall, Public Meeting attendee Rev JS Mans also recommended Noted. However, the Company has decided Lunsar that, in order to ensure justice, the that its head office will remain in Freetown Headquarter/ administrative office at this stage. of MIOL should be located in Lunsar and not in Freetown 112 12-Mar-11 Town Hall, Public Meeting attendee All grievances should be reported Noted. MIOL will report relevant problems/ Lunsar to the authorities or the Police. grievances, if criminal in nature, to the police or relevant authorities. Reference to this will be included in the Grievance Management Plan (Section 11.1.4 of the ESIS). U3823_Marampa_SEP_Final.docx August, 2012 Page 5xiii of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 12 09-Mar-11 Soldier Street, Green Scenery Issue of implementation: Agreed. The Environmental and Social Freetown Consultants should design a Management System in Chapter 11 of the framework on how to monitor and ESIS includes specifications for monitoring include as an annex. A framework and reporting. An environmental on reporting their performance management programme (EMP) is included should be constructed. in Appendix F of the ESIS. 145 14-Mar-11 PLTC Campus, Port Loko Teachers College Who determines what is Government will make final decisions on the Lungi Road, compensated to the people? compensation- decisions will be based on Prot Loko current Sierra Leone legislation, international good practice and local prices. Details on compensation will be specified in the RAP (Impact RL1). 17 09-Mar-11 Soldier Street, Green Scenery, Public Meeting Resettlement is a key issue and Impacts relating to resettlement have been Freetown companies must do this sensitively assessed in Section 8.2 of the ESIS (Impact and properly where they should RL1). These issues will be addressed more buy land for communities and build thoroughly in the RF (Appendix D of the houses for them. ESIA) and RAP. Stakeholder Consultation Process and Participation 4, 9, 09-Mar-11 NMJD Office, Network Movement for Justice The authority of Paramount Chiefs Noted. MIOL will ensure continuous 48, 60 49 Main Motor and Development, Green is now declining and hence MIOL dialogue between the company and Road, Scenery, Cotton Tree should not rely on them too much. stakeholders throughout the Project life Foundation, Amazonian Instead the Company should Brookfields, cycle, as described in this SEP. Freetown, Initiative Movement identify other leaders and Soldier Street, communicate directly with Freetown community members. The dialogue with the community should be sustained even after permitting. 8 09-Mar-11 Soldier Street, Green Scenery A programme should be designed A Community Development Plan is Freetown which identifies communities committed to and this will include evaluation needs. of community needs (Section 11.1.4 of the ESIS). U3823_Marampa_SEP_Final.docx August, 2012 Page 5xiv of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 21 09-Mar-11 Soldier Street, Green Scenery The ESIA should not only be sent When the ESIS is made public it will be Freetown to SLEPA but should be made available to stakeholder groups, as per the available to other stakeholder required SEP (Section 3.3.5 of the ESIA). groups as well to share their concerns before the ESIA disclosure. 23 09-Mar-11 Soldier Street, Green Scenery Communities should be engaged Agreed. Community engagement will take Freetown and educated to avoid threats. place throughout the Project life cycle and after closure as set out in the SEP. 24 09-Mar-11 Soldier Street, Green Scenery A balance between the community Agreed. Continued community engagement Freetown and company’s expectations throughout the Project is set out in the SEP. should be kept. 25 09-Mar-11 Soldier Street, Green Scenery The Community Liaison Officer Agreed. Freetown (CLO) will be the key person for community outreach. 28 09-Mar-11 Upper Brook Environmental Forum for Action Concern over MIOL's public Noted. MIOL is strongly committed to Street, participation in 2010 as it was very following good practice procedures, Freetown poor. They do not want a repeat of especially with regard to community this. consultation. MIOL to follow up on reasons for this comment. Agreed. The company will have a dedicated 49 09-Mar-11 Cotton Tree Cotton Tree Foundation MIOL should beware of the Foundation uneducated people in the Project non-technical summary report of the ESIA Office, King area, as they can have a negative for disclosure of relevant Project related Street, impact. information to communities as outlined in Freetown this SEP. Consultations will take place throughout the Project life cycle to ensure communities are kept up to date with information. The community liaison officer will also facilitate dissemination of information to communities. U3823_Marampa_SEP_Final.docx August, 2012 Page 5xv of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 50 09-Mar-11 Cotton Tree Cotton Tree Foundation MIOL should understand the Agreed. Communities will be engaged with Foundation people, culture, values and show at each step of the Project cycle as outlined Office, King respect to the local communities in this SEP. Dedicated social and natural Street, through involving them. resource studies have taken place to gain Freetown understanding of the local culture and values (Section 6 of the ESIS). 79 11-Mar-11 Chief Port Loko District Council Sheik Gibril requests feedback Noted. MIOL will follow up and ensure the Administrator’s from the meeting. requested feedback has been provided. Office, Port Loko District Council, Port Loko 78 11-Mar-11 Chief Port Loko District Council The council should be involved in Government and governmental agencies Administrator’s all development programmes. will be involved in community development Office, Port as laid out in the RF. Loko District Council, Port Loko 159, 14-Mar-11 Murialdo Murialdo Secondary School, Will this consultation be a Engagement with stakeholders will continue 99 Secondary Public Meeting continuous process? Engagement throughout the Project life as outlined in this School, Lunsar with stakeholders should continue. SEP. 113 12-Mar-11 Town Hall, Public Meeting attendee A request for similar meetings to Noted. If the Project proceeds the frequency Lunsar be held by MIOL every month. of meetings will be reviewed and if necessary the SEP updated to reflect the needs of the community. 87 11-Mar-11 District Ministry of Agriculture and Food It is important that work is Noted. Agriculture Security undertaken with community youths Officer’s Office, and chiefs. MAFS, Port Loko 77 11-Mar-11 Chief Port Loko District Council MIOL should have community A Community Development Plan is Administrator’s development personnel to guide committed to and this will include input from Office, Port them on development principles. relevant specialists (Section 11.1.4 of the Loko District ESIS). U3823_Marampa_SEP_Final.docx August, 2012 Page 5xvi of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) Council, Port Loko Mining Operations 32 09-Mar-11 Upper Brook Environmental Forum for Action International consultants have a Noted. MIOL is committed to implementing Street, history of ignoring their the measures listed in the EMP (Appendix F recommendations (eg. on Freetown of the ESIS). Adherence to the EMP may be chemical disposal, tailings, a condition of the Project’s environmental pollution prevention, clearing of authorisation. vegetation and restoration) given in management plans. 32a 09-Mar-11 Upper Brook Environmental Forum for Action What will MIOL do about tailings Tailings material will be disposed of in a Street, storage facilities? dedicated and appropriately designed Freetown Tailings Storage Facility (see Section 4.4 of the ESIS and Appendix E), and used to backfill Matukia pit (with appropriate design in place). 37 09-Mar-11 Upper Brook Environmental Forum for Action Will AML, LML and MIOL work Noted. No formal arrangement in this regard Street, together to mitigate impacts of iron has been reached yet. Cumulative impacts Freetown ore exploration? (in most cases resulting from the multiple mining Projects in the area) have been assessed in Chapter 10 of the ESIS. MIOL will consider approaching AML and LMC in this regard. 38 09-Mar-11 Upper Brook Environmental Forum for Action The cost of rehabilitation should Agreed. MIOL will be responsible for the Street, not be to be left on the cost of rehabilitation of the site, as Freetown government. described in Section 4.11, and specified in the EMP (Appendix F). 40 09-Mar-11 Upper Brook Environmental Forum for Action Request to see the Mine A Closure and Rehabilitation Plan will be Street, Reclamation Plan. developed if the Project proceeds and will Freetown be made available upon request to stakeholders. 43 09-Mar-11 Upper Brook Environmental Forum for Action ENFORAC has the legal mandate Noted. Street, to monitor and are working with U3823_Marampa_SEP_Final.docx August, 2012 Page 5xvii of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) Freetown SLEPA. 44 09-Mar-11 Upper Brook Environmental Forum for Action ENFORAC have requested to be Noted. ENFORAC are registered as Street, part of the process and that MIOL stakeholders and will be consulted in future Freetown should work with them. as outlined in this SEP. 156 14-Mar-11 Murialdo Murialdo Secondary School How will the concentrate be Concentrate will be stored in stockpiles at Secondary stored? the rail loading spur before being exported School, Lunsar from the site. See Section 4.3 of the ESIS. 62 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement When will mining start? Stage 1 (oxide ore) mining is scheduled to Highway, start in Q$ of 2014 subject to the Company Lunsar receiving financing. 64 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement How will MIOL undertake MIOL will undertake monitoring as per the Highway, monitoring and which areas are of requirements of the Environmental and Lunsar influence? How long does it take Social Management System (Section 11.3 to monitor? of the ESIA). Monitoring programmes recommended by specialists are included in the specialist study reports (Volume 3 of the ESIS). Monitoring will in most cases be ongoing through the life of mine. Livelihoods (Agri schemes) 66, 52 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement MIOL should negotiate with MIOL will make the decision on Highway, plantation owners and the names compensation in consultation with affected Lunsar of the landowners should be land owners and government in line with recorded in the deal. Landowners Sierra Leone legislation and international should be treated fairly whereby standards. Landowners will be paid they receive the true money value compensation at full replacement value. of their land. Further detail on compensation will be determined via the RAP (Impact RL1 in the ESIS). 123 a 13-Mar-11 Mabesene Mabesene Women’s Assistance for agricultural Noted. Decisions on community Village, Lunsar Association expansion should be provided. development programmes will be made during the development of the RAP. MIOL will consider inclusion in the community development programme. U3823_Marampa_SEP_Final.docx August, 2012 Page 5xviii of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 140, 14-Mar-11 PLTC Campus, Port Loko Teachers College Economic trees such as Mango Economically important trees lost through 138 Lungi Road, trees, should be planted as these land acquisition will be compensated (detail Prot Loko provide livelihoods. How much will be determined via the RAP), and would MIOL pay for these? community development plans will be decided in consultation with the community. MIOL will consider inclusion in the Community Development Plan (Section 11.1.4 of the ESIS) 120 13-Mar-11 Foreroad Baka Foreroad Baka Women’s A request for assistance and Noted. Decisions on community Village, Lunsar Association support in business activities and development programmes will be made in (suburb) the construction of a storage consultation with the community members. facility for crops and produce. MIOL will consider inclusion in the 121 13-Mar-11 Mabesene Mabesene Women’s MIOL is expected to continue in Community Development Plan (Section Village, Lunsar Association supporting this group with seed 11.1.4 of the ESIS) supply for cassava and groundnut. 103 12-Mar-11 Town Hall, Public Meeting attendee What will happen if MIOL relocates MIOL will buy land for them and build them Lunsar landowners? houses, in accordance with a RAP (Impact RL1), which will be developed in consultation with the community. 107 12-Mar-11 Town Hall, Public Meeting attendee What will happen to their land after The land will be rehabilitated and handed Lunsar MIOL has left? back to the community (Section 4.11). 108 12-Mar-11 Town Hall, Public Meeting attendee When MIOL pay the landowners Noted. Engagement with stakeholders on Lunsar their surface rent, they should tell issues such as this will continue throughout them then what will happen to their the Project life as outlined in this SEP. land once the company has left. 111 12-Mar-11 Town Hall, Public Meeting attendee MIOL should address the This is being addressed in the resettlement Lunsar relocation of communities and planning process (see RF in Appendix D crop compensation. and Impact RL1) and will further be addressed via the RAP. 90 11-Mar-11 District Ministry of Agriculture and Food The rehabilitation of mined out Disturbed areas will be rehabilitated, but not Agriculture Security areas is crucial for the necessarily to their original use. MIOL will Officer’s Office, sustainability of agriculture. devise a Rehabilitation and Closure Plan MAFS, Port (Section 11.1.4 of the ESIS). U3823_Marampa_SEP_Final.docx August, 2012 Page 5xix of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) Loko 89 11-Mar-11 District Ministry of Agriculture and Food Swamps and low lying areas Suggested noted. Wetland areas also Agriculture Security should be developed for increased serve important ecological functions, which Officer’s Office, agricultural production. need to be maintained. MAFS, Port Loko 26 09-Mar-11 Soldier Street, Green Scenery The issue of livelihood. Farmers Noted. The issue of livelihoods is Freetown may not have much land anymore. discussed in Section 8.2 of the ESIS. Health and Safety 71, 11-Mar-11 Chief Port Loko District Council, Concerns over the effect air Impacts on air quality (including those 127 Administrator’s Mabesene Women’s pollution and dust from vehicles resulting from dust from vehicles) were Office, Port will have on human health. assessed by a specialist, the findings of Association Loko District which are summarised in the ESIS (Section Council, Port 9.1). MIOL has committed to the mitigation Loko / measures listed. Mabesene Village, Lunsar 128, 13-Mar-11 Mabesene Mabesene Women’s Concerns over heavy machines Impacts resulting from vibrations and air 124 Village, Lunsar Association shaking nearby houses and overpressure have been modelled blasting activity damaging their assessed in the ESIS (Impact NV1). houses as structures are weak. Impacts on built structures are expected to be insignificant (and lower than those on humans). 129, 13-Mar-11 Mabesene Mabesene Women’s Concerns over increases in Traffic safety risks are assessed in the ESIS 148 Village, Lunsar Association, Port Loko Teachers accidents due to an increase in as Impacts TS1 and TS2. MIOL has College traffic and the safety of people committed to the mitigation measures listed, when crossing railways and roads. including provision of safe crossing points where possible. U3823_Marampa_SEP_Final.docx August, 2012 Page 5xx of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 132 14-Mar-11 DMO’s office, District Medical Officer Port Concerns over the water system Noted. Impacts on surface water quality Port Loko Loko and artificial lakes as waterborne resulting from discharges are assessed in Government diseases can be transmitted. Impact WR6 of the ESIA, and MIOL has Hospital, committed to the mitigation measures listed. Hospital Road, Ongoing water quality monitoring will take Port Loko place to timeously detect issues. 125 13-Mar-11 Mabesene Mabesene Women’s Safety measures need to ensure Agreed, and addressed in Impact OH1 of Village, Lunsar Association debris and stones do not fly into the ESIA. MIOL will ensure good practice the village from blasting activities. safety measures are in place during blasting operations. 123 13-Mar-11 Mabesene Mabesene Women’s Toilet facilities and clean water MIOL cannot provide what usually is Village, Lunsar Association supply should be provided. government responsibility. However this request would be considered during ongoing consultations with community as part of the Community Development Plan (Section 11.1.4 of the ESIS). 126 13-Mar-11 Mabesene Mabesene Women’s There is a fear of flooding due to Changes to flood risk have been assessed Village, Lunsar Association Magbenkte Village being in the ESIS in Impact WR4, and is predicted surrounded by old Delco Lake to be of low significance. Various good where some digging is being practice measures are recommended to undertaken (not clear if this is in further decrease any negative impacts on London Mining area). local villages. 142 14-Mar-11 PLTC Campus, Port Loko Teachers College Concerns over health and social This risk is assessed in Impacts SR2, and Lungi Road, issues associated with congestion. SO1-3 of the ESIS and MIOL has Prot Loko committed to the measures proposed for mitigating them. 114 12-Mar-11 Town Hall, Public Meeting attendee - Dr. It is requested that employees use Noted. MIOL will follow up in this regard at Lunsar Rev. Joseph Saidu Mans the St John of God Hospital and the appropriate time. the Baptist Eye Hospital for medical tests and examination. U3823_Marampa_SEP_Final.docx August, 2012 Page 5xxi of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 65 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement External workers should be aware Workers will be made aware of risks and Highway, of an increased risk of HIV and preventative measures on commencement Lunsar AIDS. of employment, as part of the health awareness programme committed to by MIOL, which are likely to be captured in a Community Health and Safety Plan (Impact SR2 of the ESIS). HIV awareness will be included. 68 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement How will MIOL address hazards This impact has been assessed by a noise Highway, such as the effect blasting noise specialist, and reported as Impact NV1 in Lunsar will have on people. the ESIS. The impact on local communities is predicted to be of low significance, and no mitigation measures are required. Impacts on mine workers are an occupational health and safety issue, and the appropriate PPE will be used. 56 10-Mar-11 Lunsar-Makeni Amazonian Initiative Movement Will appropriate safety gear be Yes, appropriate health and safety Highway, supplied to the employees? measures will be followed with relevant Lunsar safety gear (PPE) being provided to all employees with the expectation it will be worn at all times 32 09-Mar-11 Upper Brook Environmental Forum for Action What will MIOL do about noise Specialists have quantitatively modelled the Street, and air pollution? potential impacts on air quality and noise in Freetown the surrounding area, the results of which are summarised in Impacts AQ1 and NV2 of the ESIS. MIOL has committed to the mitigation measures listed to manage these impacts. 34 09-Mar-11 Upper Brook Environmental Forum for Action Which type of explosives/blasters The type of explosives is yet to be Street, will be used? Will staff be trained determined. MIOL staff will be appropriately Freetown to use explosives safely? trained and the appropriate safety measures will be in place. U3823_Marampa_SEP_Final.docx August, 2012 Page 5xxii of 5xxii SRK Consulting Marampa Iron Ore Project – Technical Appendix 5 Issue Date Meeting venue Stakeholder Description of Issue/Concern Responses provided and required action 3 No. (if any) 32b 09-Mar-11 Upper Brook Environmental Forum for Action What will MIOL do about the This impact has been assessed by a noise Street, drilling/blasting effects on workers specialist, and reported in Impact NV1 of Freetown and the communities? the ESIS. The impact on local communities is predicted to be of low significance, and no mitigation measures are required. Impacts on mine workers are an occupational health and safety issue, and the appropriate PPE will be used. 35, 59 09-Mar-11 Upper Brook Environmental Forum for Action, There needs to be sufficient Staff will be appropriately trained in the use Street, Amazonian Initiative Movement distance between to use of of explosives and the appropriate safety Freetown explosives and the communities. measures will be in place. U3823_Marampa_SEP_Final.docx August, 2012 Page 5xxiii of 5xxii SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix D APPENDIX D D RESETTLEMENT FRAMEWORK U3823_Marampa_ESIS_Final.docx September 2012 Page D1 of D1 A RESETTLEMENT FRAMEWORK FOR THE MARAMPA IRON ORE PROJECT, SIERRA LEONE Prepared For MARAMPA IRON ORE (SL) LIMITED Report Prepared by SRK Consulting (UK) Limited UK3823 SRK Consulting Marampa RF – Details COPYRIGHT AND DISCLAIMER Copyright (and any other applicable intellectual property rights) in this document and any accompanying data or models which are created by SRK Consulting (UK) Limited ("SRK") is reserved by SRK and is protected by international copyright and other laws. Copyright in any component parts of this document such as images is owned and reserved by the copyright owner so noted within the document. 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SRK Project Director Fiona Cessford Corporate Consultant (Environment) and Project Manager: Client Legal Entity: Marampa Iron Ore Ltd Date: September, 2012 Project Number: UK3823 Client Address: Victoria Place 31 Victoria Street Hamilton Bermuda (British Overseas Territory) HM10 U3823_Marampa_Resettlement_Final.docx September, 2012 SRK Consulting Marampa RF – Executive Summary A RESETTLEMENT FRAMEWORK FOR THE MARAMPA IRON ORE PROJECT, SIERRA LEONE – EXECUTIVE SUMMARY 1. INTRODUCTION Marampa Iron Ore Limited (MIOL) intends to develop an open pit iron ore mine in the vicinity of Lunsar. The Project will require land acquisition and as a result some people will need to be physically and/or economically displaced from the Project area. SRK Consulting (UK) Limited (“SRK”) has been requested by Marampa Iron Ore Limited (“MIOL”, hereinafter also referred to as the “Company” or the “Client”) to prepare a Resettlement Framework (”RF”). Of the total area (2 173 ha) potentially impacted by Project infrastructure, approximately 89% is currently used for agriculture. It is estimated 10 villages (162 households and 1780 people) will require relocation and could lose some or all access to agricultural land, natural resources, social infrastructure, sacred sites and access routes. In addition to the above villages, 13 villages (270 households and 2936), which are on the outskirts of the Project footprint, may lose some access to land and natural resources. The RF is based on relevant Sierra Leone national laws and international best practices for compensation and resettlement. In particular the IFC Performance Standard (PS) 5 on Land Acquisition and Involuntary Resettlement is used as a guideline for this framework. A comparison between the Sierra Leone laws and the international guidelines shows the latter are more stringent in terms of: replacement value of lost assets, emphasis on compensation in kind rather than cash, requiring more intensive consultations with Project Affected People (PAP), recognising informal land owners/users (those who lack legal title), placing special emphasis on vulnerable groups and providing for a cut-off date for eligibility for compensation. IFC PS 5 on resettlement and land acquisition requires that any resettlement of households only occurs if all possible measures have been exhausted to avoid resettlement. Where resettlement cannot be avoided it must be minimised as far as practicably possible. In line with IFC PS 5 this RF provides an approach for the development of a Resettlement Action Plan (RAP) and provides guidelines for compensation of those who will be physically and/or economically displaced by the Project land acquisition. The RF: • outlines international best practice (IBP) guidelines and national legal requirements for compensation for loss of property, livelihood and relocation; • describes the social context of those who will be resettled; and • defines the tasks and steps which should be undertaken to plan the resettlement; including identification of PAPs. 2. RESETTLEMENT PLANNING ACTIONS The development of a RAP involves the following key actions: • identification and implementation of measures for minimising resettlement; • identification of affected people and assessment of eligibility for compensation; • development of an entitlement framework, outlining compensation criteria and rates; • identification of host areas for resettlement; • identification of procedures for monitoring and evaluating; and • identification of institutional arrangements for the execution of the resettlement and compensation process. A census and assets inventory will be undertaken to fully understand the current baseline U3823_Marampa_Resettlement_Final.docx September, 2012 Page i of iii SRK Consulting Marampa RF – Executive Summary conditions of PAP and assess potential losses in terms of private and communal assets. Following the survey a cut-off date will be announced to prevent opportunistic claims for compensation. An agreement will need to be reached with the local authorities and the affected communities on the procedures to be used in the event of disputes. An entitlement framework, which describes the compensation for different impacts, will be compiled. It will be based on valuation methods derived from both international best practice and Sierra Leone national laws. Valuation rates should be ratified by a Resettlement Working Group (RWG), relevant authorities and the affected stakeholders. The valuation process will take cognisance of the compensation rates used by recent projects in Sierra Leone, such as the London Mining Project and Addax Biofuel Project. Resettlement will require the identification of a single large area or multiple smaller host areas for residential resettlement purposes (for those physically displaced) and identification of multiple areas of agricultural land for those economically displaced. Ideally for each affected household several options will be explored. Assessment of different options will be conducted in consultation with the affected villages and the RWG in terms of legal aspects and perceived advantages and disadvantages of the various options. Once the feasibility of the host areas has been established a detailed plan of the host areas will be developed indicating any existing dwellings and infrastructure as well as the areas allocated to new dwellings, additional infrastructure, agricultural land and the existing transport network. Both internal and external monitoring should be conducted to ensure the resettlement process meets its set objectives and standards. 3. STAKEHOLDER ENGAGEMENT Engagement with stakeholders facing involuntary resettlement is one of the main requirements of IFC PS5. Consultations will comprise initial meetings with PAP at the start of the resettlement process to gather their inputs and meetings at the completion of the planning process to disclose the RAP. Consultations with PAP will be ongoing during the planning process through the RWG and the Community Resettlement Committees (CRCs). The RWG will comprise representation from MIOL, local government, affected people and NGOs and is expected to take the lead on negotiations, reaching agreements and resolving grievances. The CRCs will comprise affected people and be established in each (cluster or single) village(s). These will assist with the implementation of the census and assets survey and be involved in the negotiations and identification of the host areas. The resettlement process will also need an effective grievance mechanism for the PAP to resolve their issues. The mechanism should work in tandem with the RWG. 4. COMPANY RESPONSIBILITIES MIOL is responsible for financing the resettlement and compensation activities, managerial and technical resources and expertise. The Company will develop a Resettlement Unit which will be managed by the Social Manager who is responsible for reporting to the General Manager. MIOL may decide to contract out their resettlement responsibilities to an external contractor with specific expertise in the area. A detailed budget will be developed. The key components of the budget are: • the cost of replacement land; U3823_Marampa_Resettlement_Final.docx September, 2012 Page ii of iii SRK Consulting Marampa RF – Executive Summary • the cost of building replacement housing and community structures such as schools, churches, grain banks, etc; • cash compensation for the crops/ trees and relocation; • the cost of implementing a livelihoods restoration programme for the directly affected people; and • monitoring and evaluation costs. The resettlement schedule should be linked with the Project’s construction schedule to ensure timely availability of land for start of different Project activities. U3823_Marampa_Resettlement_Final.docx September, 2012 Page iii of iii SRK Consulting Marampa RF – Table of Contents Table of Contents 1 INTRODUCTION ................................................................................................. 1 2 PROJECT DESCRIPTION .................................................................................. 1 3 POTENTIAL DISPLACEMENT ........................................................................... 2 3.1 Physical Displacement ............................................................................................................. 2 3.2 Economic Displacement .......................................................................................................... 2 4 LEGISLATIVE FRAMEWORK ............................................................................ 5 4.1 Sierra Leone Legislation .......................................................................................................... 5 4.1.1 Land Acquisition law ...................................................................................................... 5 4.1.2 The Mines and Minerals Act .......................................................................................... 5 4.1.3 ENVIRONMENTAL AND SOCIAL REGULATIONS FOR THE MINERALS SECTOR . 8 4.2 International Best Practice ....................................................................................................... 8 4.3 Comparison of Sierra Leone Legislation and International Standards .................................... 9 5 SOCIO-ECONOMIC PROFILE OF AFFECTED AREAS .................................. 11 5.1 Demography .......................................................................................................................... 11 5.2 Livelihood Strategies ............................................................................................................. 11 5.3 Access to Land ...................................................................................................................... 11 5.4 Standard of Living .................................................................................................................. 12 5.5 Health ..................................................................................................................................... 12 6 RESETTLEMENT PLANNING ACTIONS ......................................................... 12 6.1 Minimising Resettlement ........................................................................................................ 13 6.1.1 Project Affected People ............................................................................................... 13 6.1.2 Types of Loss .............................................................................................................. 13 6.2 Eligibility: Cut-Off Date ........................................................................................................... 14 6.3 Census and Assets Inventory ................................................................................................ 14 6.3.1 Census ........................................................................................................................ 14 6.3.2 Assets Inventory .......................................................................................................... 14 6.3.3 Census and Inventory Asset Methodology .................................................................. 15 6.4 Entitlement Framework .......................................................................................................... 16 6.4.1 Valuation ...................................................................................................................... 16 6.4.2 Compensation for Loss of Homesteads and Fixed Structures .................................... 16 6.4.3 Compensation for loss of Land .................................................................................... 16 6.4.4 Compensation for Crops and Trees ............................................................................ 17 6.4.5 Compensation for Disturbance of Graves and Sites of Cultural, Historical or Religious Importance ................................................................................................................... 18 6.4.6 Compensation for Loss of Natural Resources ............................................................ 19 6.4.7 Compensation for Affected Businesses ...................................................................... 19 6.4.8 Compensation for Loss of Communal Social Infrastructure ........................................ 19 6.5 Identification and Evaluation of Resettlement Sites/host areas ............................................ 20 U3823_Marampa_Resettlement_Final.docx September, 2012 Page i of ii SRK Consulting Marampa RF – Table of Contents 6.6 Support provision ................................................................................................................... 20 6.7 Income Restoration and Sustainable Development Initiatives .............................................. 20 6.8 Vulnerable Individuals and Households ................................................................................ 21 6.9 Community Development Initiatives ...................................................................................... 21 6.10 Resettlement Process ............................................................................................................ 22 7 STAKEHOLDER ENGAGEMENT ..................................................................... 22 7.1 The Resettlement Working Group (RWG) ............................................................................. 22 7.2 Community Resettlement Committees .................................................................................. 23 7.3 Public Consultation ................................................................................................................ 23 7.4 Grievance Mechanism ........................................................................................................... 23 8 COMPANY RESPONSIBILITIES ...................................................................... 24 9 MONITORING .................................................................................................... 25 9.1 Internal Monitoring ................................................................................................................. 25 9.2 External Independent evaluation /audit ................................................................................. 26 10 BUDGET ............................................................................................................ 26 11 TIMING .............................................................................................................. 27 12 CONCLUSION ................................................................................................... 27 13 REFERENCES .................................................................................................. 27 List of Tables Table 3-1: Approximate area of disturbance by main Project components ............................................ 2 Table 3-2: Villages potentially requiring resettlement ............................................................................. 2 Table 3-3: Villages which will lose access to land/ resources ................................................................ 3 Table 4-1: Comparison of Sierra Leone national legislations and international standards .................. 10 Table 6-1: Types of assets and resources impacted ............................................................................ 13 Table 6-2: Proposed Compensation Rates ........................................................................................... 17 List of Figures Figure 3-1: Villages affected by land acquisition..................................................................................... 4 U3823_Marampa_Resettlement_Final.docx September, 2012 Page ii of ii SRK Consulting (UK) Limited 5th Floor Churchill House 17 Churchill Way City and County of Cardiff CF10 2HH, Wales United Kingdom E-mail: enquiries@srk.co.uk URL: www.srk.co.uk Tel: + 44 (0) 2920 348 150 Fax: + 44 (0) 2920 348 199 A RESETTLEMENT FRAMEWORK FOR THE MARAMPA IRON ORE PROJECT, SIERRA LEONE 1 INTRODUCTION SRK Consulting (UK) Limited (“SRK”) has been requested by Marampa Iron Ore Limited (“MIOL”, hereinafter also referred to as the “Company” or the “Client”) to prepare a Resettlement Framework ”RF” on the Mineral Assets of the Company comprising the Marampa Iron Ore Project (The Project) located in Sierra Leone. MIOL intends to develop an open pit iron ore mine in the vicinity of Lunsar. During the development of the Project land acquisition and resettlement will be required. This RF provides an approach for the development of a Resettlement Action Plan (RAP) and provides guidelines for compensation of those who will be physically and/or economically displaced by the Project land acquisition. This RF: • outlines international best practice (IBP) guidelines and national legal requirements for compensation for loss of property, livelihood and relocation; • describes the social context of those who will be resettled; and • defines the tasks and steps which should be undertaken to plan the resettlement; including identification of PAPs. 2 PROJECT DESCRIPTION 2 MIOL has an exploration licence for an area of 305.12 km . The proposed Project 2 footprint/development area is 52.3 km . The Project will be conducted in two stages; Stage one will involve the construction of facilities to produce 2.5 Mtpa of iron concentrate through the mining of oxide ore and Stage two will involve the expansion of these facilities and construction of new facilities to enable the production of up to 15Mtpa of iron concentrate. The expected life of the mine is a minimum of 14 years. The construction period for the Project will be approximately 3 – 3 ½ years and during this time temporary facilities will be provided to house construction personnel. The location of this site is currently unknown. A fenced construction laydown area will be built in proximity of the camp to store construction materials. Aside from the construction camp facilities the Project infrastructure will be developed within the Project exploration limit. Group Offices: Africa Registered Address: 21 Gold Tops, City and County of Newport, NP20 4PG, Asia Wales, United Kingdom. Australia SRK Consulting (UK) Limited Reg No 01575403 (England and Wales) Europe North America South America SRK Consulting Marampa RF – Main Report 3 POTENTIAL DISPLACEMENT The Project needs to acquire land for the development of MIOL’s mining infrastructure and operations. As a result local people will be both physically and economically displaced from the Project area. In line with international standards, any economic or physical displacement of Project affected peoples (PAPs) requires the application of IFC Performance Standard (PS5) on land acquisition and involuntary resettlement as well as compliance with Sierra Leone requirements. According to PS5, involuntary resettlement refers to physical and economic displacement as a result of Project-related land acquisition and/or restrictions on land use. Of the total area (2 173 ha) that will be impacted by Project infrastructure, approximately 89% is currently used for agriculture (Section 7, ESIA). The scale of displacement is determined by the requirement for land by the main Project components as presented in Table 3-1. Based on these estimates, the scope of both physical and economic displacement is described in the following sub-sections. Table 3-1: Approximate area of disturbance by main Project components Project component Disturbed area (ha) Pits (four open pits) 550 Tailings Storage Facility (TSF) 695 Waste Rock Disposal (WRD) 800 Processing areas 113 Haul roads* 15 Total 2 173 *Based on a 10 m wide haul road 3.1 Physical Displacement It is estimated that 10 villages will require relocation and will lose some or all access to agricultural land. Table 3-2 provides information on the villages to be relocated (see also Figure 3-1). Assuming there is one main structure per household a total of 162 private structures and some community structures will be affected. Table 3-2: Villages potentially requiring resettlement Village Name Population Total Number of Reason for relocation Households Gbese 254 23 Near Run Of Mine (ROM) pad Konta 146 11 Near Matukia haul road and plant (noise and dust) Ma Sesay 7 2 Near Rotret Pit Mafuri 178 23 On Mafuri Pit Magbungbu 100 7 On the edge of TSF Marunku 519 40 On TSF Maso 175 13 Near Gafal Pit Matukia 271 19 On Matukia Pit Rolal c/o Gafal 26 4 Near Gafal Pit Rosint 104 20 On Mafuri Pit Total 1780 162 Source: MIOL town population survey 2010 and SRK primary survey 2010 3.2 Economic Displacement In addition to the above villages, the villages in Table 3-3 below, which are on the outskirts of U3823_Marampa_Resettlement_Final.docx September, 2012 Page 2 of 28 SRK Consulting Marampa RF – Main Report the Project footprint, may lose access to land and natural resources. Table 3-2 and Table 3-3 indicate that a total of 432 households will be impacted by land acquisition required by the Project. Table 3-3: Villages which will lose access to land/ resources Village Population Total Number of Households Makel 153 18 Mafira 94 15 Magbafat 542 34 Rolal-co-Mafuri 89 9 Monbaia 17 2 Matoko 328 37 Konta Bana 403 34 Manonko 446 31 Molumpo 137 12 Kalangba 133 15 Royema 449 44 Royail 108 12 Konta Loi 37 7 Total 2936 270 Source: MIOL town population survey 2010 and SRK primary survey U3823_Marampa_Resettlement_Final.docx September, 2012 Page 3 of 28 SRK Consulting Marampa RF – Main Report Figure 3-1: Villages affected by land acquisition U3823_Marampa_Resettlement_Final.docx September, 2012 Page 4 of 28 SRK Consulting Marampa RF – Main Report 4 LEGISLATIVE FRAMEWORK The Sierra Leone national legislation and IBP for compensation and resettlement are described in this chapter. 4.1 Sierra Leone Legislation 4.1.1 Land Acquisition law The Provinces Land Act, Chapter 122 of the Law of Sierra Leone (1960) relates to land acquisition. Section 4 of the Provinces Act states a non-native cannot own free hold land. A non-native can lease land in the provinces, but the initial lease cannot be for a period exceeding 50 years; it can however subsequently be renewed for periods of up to 21 years. A lease is defined in the Act as “a grant of the possession of land by the tribal authority (now known as the ‘Chiefdom Council’), as lessor, to a non-native, as lessee, for a term of years or other fixed period with a reservation of a rent”. The lease agreement is required to state: • the rent; • the term of years; • the purpose for which the land is to be used; • whether the interest is assignable; • whether buildings or permanent structures are to be erected and the rights of the parties on the expiration/determination of the lease; and • that the rent is subject to review every seven years by the District Officer/Chief Administration office (when the lease term exceeds seven years). The lease must be made between the chiefdom council and the lessee. The lease requires the rent to be split in accordance with the traditional approach of one-third being retained by the Chief Administrative Officer, one-third being paid to the Chiefdom Council and one-third being paid to the traditional landowners of the leased land. 4.1.2 The Mines and Minerals Act The Sierra Leone Mines and Minerals Act 2009 outlines the legislation in terms of occupation of land, resettlement and compensation. The relevant sections are outlined below: Section 32 The holder of a mineral right shall not exercise any of his rights under the mineral right, except with the written consent of the owner or lawful occupier or his duly authorised agent, in respect of: • any land dedicated as a place of burial or which is a place of religious or other cultural significance; • any land which is the site of, or which is within two hundred metres or such greater distance as may be prescribed, of any inhabited, occupied or temporarily unoccupied house or building; • any land which is within fifty metres or such greater distance as may be prescribed, of land which has been cleared or ploughed or otherwise bona fide prepared for the growing of, or upon which there are growing agricultural crops; • any land which is the site of, or within one hundred metres or such greater distance as may be prescribed, of any cattle dip, tank, dam, or other body of water; • in respect of any land within any township, or within two hundred metres or such U3823_Marampa_Resettlement_Final.docx September, 2012 Page 5 of 28 SRK Consulting Marampa RF – Main Report greater distance as may be prescribed, of the boundaries of any township, except with the written consent of the local authority having control over the township. Section 33 • The owner or lawful occupier of any land which within an area that is the subject of a mineral right shall retain the right to graze stock upon or to cultivate the surface of such land in so far as such grazing or cultivation does not interfere with the proper use of such area for reconnaissance, exploration, or mining operations. • The rights conferred by a mineral right shall be exercised reasonably so as to affect as little as possible the interests of any owner or lawful occupier of the land on which such rights are exercised consistent with the reasonable and proper conduct of the operations concerned. Section 34 1 Subject to the provisions of any law relating to the acquisition of land titles and Section 38, the holder of a large-scale mining license shall obtain a land lease or other rights to use the land upon such terms as to the rents to be paid for the license, the duration or the extent or area of the land to which such license shall relate, as may be agreed between such holder and such owner or lawful user of the land or failing that, such agreement as may be determined by the Minister on the advice of the Minerals Advisory Board. Section 35 1. The holder of a mineral right shall on demand being made by the owner or lawful occupier of any land subject to such rights pay such owner or lawful occupier fair and reasonable compensation for any disturbance of the rights of such owner or occupier and for any damage done to the surface of the land by his operations and shall on demand being made by the owner of any crops, trees, buildings or works damaged during the course of such operations pay compensation for such damage subject to the following: a) subject to Section 38, payment of rent under the provisions of Section 34 shall be deemed to be adequate compensation for deprivation of the use of land to which such rent relates; b) in assessing compensation payable under this section, account shall be taken of any improvement effected by the holder of the mineral right or by his predecessor in title the benefit of which has or will inure to the owner or lawful occupier; c) the basis upon which compensation shall be payable for damage to the surface of any land shall be the extent to which the market value of the land (for which purpose it shall be deemed saleable) upon which the damage has occurred has been reduced by reason of such damage, but without taking into account any enhanced value due to the presence of minerals; d) no compensation shall be payable to the occupier of a state grant of land in respect of any operations under a mineral right existing at the date of such grant; and 1 See below: Provinces Land Act, Chapter 122 of the Laws of Sierra Leone, 1960. Section 4. U3823_Marampa_Resettlement_Final.docx September, 2012 Page 6 of 28 SRK Consulting Marampa RF – Main Report e) no demand made in terms of this subsection shall entitle the owner or lawful occupier to prevent or hinder the exercise by the holder of a mineral right of his rights thereunder pending the determination of compensation to be paid: 2. If the holder of a mineral right fails to pay compensation when so demanded under the provisions of this section, or if the owner or lawful occupier of any land is dissatisfied with any compensation offered, such compensation may be determined by the Minister on the advice of the Mineral Advisory Board. 3. A claim for compensation under the provisions of subsection (1) shall be made within a period of two years from the date when the compensation became due failing which, notwithstanding the provisions of any other enactment, such claim shall not be enforceable. Section 36 1. The Government may, by order published in the Gazette, compulsorily acquire in the name of the Republic, private land or rights over private land for use by the holder of a large scale mining licence. 2. Before making an order under subsection (1) the Government shall be satisfied that: a) the holder of a large-scale mining licence has taken all reasonable steps to acquire on reasonable terms by agreement with the owner, the land which he wishes to use or the right which he wishes to exercise and has been unable to do so; and b) the acquisition of such land or right is necessary for mining purposes or for purposes ancillary to mining. Section 37 1. Subject to Section 38, when land is acquired compulsorily pursuant to Section 36, those persons having an interest in or rights over the land concerned shall be paid adequate compensation by the holder of the mineral right determined on the same basis as compensation for disturbance of rights pursuant to Section 35. 2. The holder of a large-scale mining licence shall, before entering into possession for enjoyment of any land or before exercising any right over the land, make payment of compensation as determined in accordance with subsection (1) to the person or persons concerned or if the whereabouts of the person or persons concerned or any of them are unknown, give such undertakings concerning the payment of compensation as the Government may require. Section 38 1. The Minister shall ensure that all owners or lawful occupiers of land who prefer to be compensated by way of resettlement as a result of being displaced by a proposed mining operation are resettled on suitable alternate land, with due regard to their economic well-being and social and cultural value so that their circumstances are similar to or improved when compared to their circumstances before resettlement, and the resettlement is carried out in accordance with the relevant planning laws. 2. The cost of resettlement shall be borne by the holder of the mineral right: U3823_Marampa_Resettlement_Final.docx September, 2012 Page 7 of 28 SRK Consulting Marampa RF – Main Report a) as agreed by the holder and the owner or lawful occupier of land or by separate agreement with the Minister, or b) in accordance with a determination by the Minister, except that where the holder elects to delay or abandon the proposed mining operation which will necessitate resettlement, the obligation to bear the cost of resettlement shall only arise upon the holder actually proceeding with the mining operation. 3. Subject to this section, the Minister and a person authorised by the Minister may take the necessary action to give effect to a resettlement agreement or determination. 4.1.3 ENVIRONMENTAL AND SOCIAL REGULATIONS FOR THE MINERALS SECTOR In 2011 the Sierra Leone government released draft regulations on environmental impact assessments. Article 34 relates specifically to projects which involve resettlement. This article states: • A new inter-ministerial committee entitled the “Resettlement Committee” dealing with resettlement related issues shall be established in accordance with the provisions contained in any law relating to the resettlement of local communities and to further implement the objectives of Section 38 of the Mines and Minerals Act 2009; • Where a Category A project application involves the potential for resettlement, the Executive Chairman or its Authorised Officer shall refer the Social Impact Assessment (SIA) and the Social Management Principles (SMP) to the Resettlement Committee for its consideration; • The Resettlement Committee shall review the SIA, the SMP and the Resettlement Management Plan (RMP, internationally known as the RAP) in accordance with the criteria set out in any law relating to the resettlement of local communities and make recommendations in accordance with the procedures described therein; and • For a Category A project involving potential resettlement the board shall consider the SIA in the light of comments and recommendations provided by the Resettlement Committee. 4.2 International Best Practice 2 World Bank Operational Policy (OP) 4.12 (World Bank, 2004) is regarded internationally as the standard for resettlement guidance. The objective of resettlement planning is to avoid resettlement whenever feasible and to explore all viable alternatives, and when resettlement is unavoidable, to minimise its extent. IFC PS5 Land Acquisition and Involuntary Resettlement (IFC, 2012) was developed by the IFC (as part of the World Bank group) from OP 4.12 and provides internationally accepted policies and guidelines for resettlement. PS5 is deemed relevant as the Project development will involve land acquisition and relocation of communities. PS5 applies to both physical and economic displacement which results from the following land transactions: • land rights or land use rights acquired through expropriation or other compulsory procedures in accordance with the legal system of the host country; • land rights or land use rights acquired through negotiated settlements with property owners or those with legal rights to the land if failure to reach settlement would have resulted in expropriation or other compulsory procedures; 2 (www.worldbank.org) and in the World Bank's Resettlement and Rehabilitation Guidebook. U3823_Marampa_Resettlement_Final.docx September, 2012 Page 8 of 28 SRK Consulting Marampa RF – Main Report • project situations where involuntary restrictions on land use and access to natural resources cause a community to lose access to resource usage; • certain situations requiring evictions of people occupying land without rights; or • restriction on access to land or use of other resources. The main objectives of PS5 in relation to resettlement and land acquisition include the following: • Avoid, or when not possible to avoid minimise displacement by exploring alternative project designs. • Avoid forced eviction. • Minimise adverse social and economic impacts by: a) providing compensation for loss of assets at replacement cost; and ensuring that resettlement activities are implemented with appropriate disclosure of information, consultation, and the informed participation of those affected; b) improving or at least restoring the livelihoods and standards of living of displaced persons; and c) improving living conditions among displaced persons through provision of adequate housing with security of tenure at resettlement sites. • Prepare a RAP and have it accepted by the relevant authorities prior to implementing resettlement activities. The RF is a stepping stone towards the RAP which can be developed once the Project land acquisition impacts are more clearly defined. • Ensure provision of compensation and the restoration of livelihoods of those affected prior to any actual resettlement. In particular, the policy requires that possession of land for Project activities may take place only after compensation has been paid, or alternatively, if adequate guarantees of compensation have been made to the PAP’s satisfaction. If the latter is chosen, compensation payments must not be delayed once resettlement has taken place. Resettlement sites, new homes and related infrastructure, public services and moving allowances must be provided to the affected persons in accordance with the provisions of the RAP. • Pay attention to the needs of vulnerable groups, generally defined as: a) those below the poverty line; b) the landless; c) the elderly; d) women and children; e) indigenous groups; f) ethnic minorities; g) orphans; h) disabled people, and i) other disadvantaged persons. 4.3 Comparison of Sierra Leone Legislation and International Standards This RF is based on both Sierra Leone national laws on mining projects, and resettlement and international best practice guidelines set by the World Bank and IFC. A comparison between the Sierra Leone laws and the international guidelines is presented in Table 4-1 below. In many areas the national laws and international guidelines are similar. In cases where one set of guidelines is more stringent than the other, such as in the cases of resettlement assistance, monitoring, consultation with directly affected parties, payment of compensation for land and U3823_Marampa_Resettlement_Final.docx September, 2012 Page 9 of 28 SRK Consulting Marampa RF – Main Report special provision for vulnerable groups, the more stringent should be followed. In addition to the above, IFC standards make provision for a cut-off date for claiming eligibility for compensation. Table 4-1: Comparison of Sierra Leone national legislations and international standards Area Sierra Leone legislation IFC PS 5 Preferred approach Calculation of Negotiated Replacement costs or more Replacement costs or compensation more Strongly recommends in-kind Compensation can be in any compensation, (replacement Recommend in-kind Compensation form housing and replacement land compensation, but is especially for those with land negotiable based livelihoods) All affected parties should be Provides for participation of involved in planning and Consultation with local authorities insofar as implementing resettlement All affected parties and PAP and host negotiation for compensation programmes. Displaced stakeholders need to be arises persons and host areas are consulted provided timely and relevant info If no moratorium is provided by the Government, the Project A cut-off date needs to No moratorium provided by should establish and be established and Cut-off date the Government disseminate a cut-off date. No disseminated. No compensation is provided for compensation for PAPs those affected after the cut-off after cut-off date date Those who have legal rights All those who are to the land and those who do All those who are physically physically and/or Eligibility for not have formal legal rights and/or economically-displaced, economically-displaced, compensation but have claim to such land or including those without legal including those without criteria assets provided that such status to occupy land legal status to occupy claims are recognised under land the law The Project is responsible for The Project is Monitoring No specific legislation monitoring of the resettlement responsible for activities monitoring of the resettlement activities Paid to local authorities Payment of Land lease is paid to local Payment should involve but with mechanism to compensation authorities / not directly to the directly affected parties safeguard for land landowners compensation of directly affected Recommended if affected Recommended if Resettlement Optional depending on choice parties’ livelihoods are land affected parties’ of affected based livelihoods are land based Resettlement No specific legislation Compulsory Compulsory assistance Negotiated between Project and Negotiated between Resettlement affected parties. If negotiation is Negotiated between Project and Project and affected decision not successful forced removal is affected parties parties possible Vulnerable No specific provisions for Require special attention and Special attention for groups vulnerable groups monitoring of vulnerable vulnerable groups groups. required U3823_Marampa_Resettlement_Final.docx September, 2012 Page 10 of 28 SRK Consulting Marampa RF – Main Report 5 SOCIO-ECONOMIC PROFILE OF AFFECTED AREAS A short description of the socio-economic baseline of the Project area is presented to contextualise the resettlement process. A detailed description of the social baseline conditions of the Project area can be found in the Social Baseline report (SRK, 2012). The Project is located in the northwest of Sierra Leone within the Port Loko District which 2 covers an area of 5,719km , has a population of approximately 478,000 and has ten chiefdoms. The Project is located across three chiefdoms – Marampa, Masimera and Maforki. The Project is situated in a rural area but close to the town of Lunsar, which is the largest town in the area and is an important administrative, social and commercial centre for the local people. 5.1 Demography In the Project area people are settled in villages differing greatly in size from as small as 2 to 259 households. The average household per village is 38 and the average village population is 344. There is a slight gender imbalance in the local population with 49.2% being male and 50.8% female. The household survey indicated that, 42% of the population is below the age of 15; 54% between 15 and 64, and 4% over 64. The main ethnic groups in area are the Temne, followed by the Fula and the Susu, The population is largely Muslim. 5.2 Livelihood Strategies The most important livelihood strategy in the Project area is subsistence farming, It is practiced by 82% of households (SRK Household survey, 2011). The sale of surplus crops is the most readily accessible income for most villagers. Some of the other important economic activities in the district are small scale fishing, small businesses, small scale diamond mining, charcoal production making and animal husbandry. Access to natural resources is also important to villagers who are reliant on the land for access to construction materials, firewood, wild foods and plants. 5.3 Access to Land Access to land for farming and collection of natural resources is important for the livelihoods of the local population. In Sierra Leone, there are two main systems of land holding: freehold rights in the Western Area and a customary system in the provinces where land is principally owned and controlled by families or traditional leaders. In the Project area villages the customary land tenure rules, which were established in 1965 under Section 76 (1) of the Courts Act, apply. However, the validity of customary law is dependent on its compatibility with statutory law. The following statutes are relevant to customary landholding practices in Sierra Leone: • The Provinces Lands Act (Cap 122). • The Chiefdom Councils Act – (Cap 61). • The Local Government Act – 1994. According to customary law, families, chiefdoms and communities hold the ownership of property and therefore a plot of land can never be owned freehold. Land always belongs to the communities or families/clans and is used by individuals under different forms of tenure laid out by customary law. This principle is established by the Chiefdom Councils Act as well U3823_Marampa_Resettlement_Final.docx September, 2012 Page 11 of 28 SRK Consulting Marampa RF – Main Report 3 as by Section 28 (d) of the Local Government Act 1994 (Ajei, 2008) . The Paramount Chief is the custodian of the land on behalf of the entire chiefdom and ultimately grants access to land to households besides mediating any land disputes. In the context of resettlement, a national policy states that, as much as possible, land disposal or acquisition of any kind should not render a land title holder (including customary land ownership), his kith and kin and descendants completely landless, nor tenants on the land to which they originally had legitimate title, save in the case of compulsory acquisition in the public interest. 5.4 Standard of Living The standard of living in the Project area is poor with only 8% of families, included in the SRK household survey conducted in terms of the ESIA baseline, receiving a stable and regular income. 80% of houses in the Project area consist of clay and earth. Houses typically have two or three internal rooms and an outdoor cooking area. Approximately 15% of households do not have bathrooms. 71% of households use paraffin lamps for lighting and 94% of households use wood for cooking. Water quality in the study area was observed to be poor and wells often dry out, causing villagers to have to walk long distances to collect water. The SRK household survey also revealed that 81% of households deposit waste in areas close to their homesteads. 5.5 Health Health conditions are poor in the area and life expectancy in the district is 49 years. Prevalent diseases in the area include malaria, diarrhoea, pneumonia/ respiratory infections and malnutrition. Incidences of Sexually transmitted diseases and HIV/AIDS are on the increase. The district has nine community health centres, four hospitals, 23 community health posts and 58 maternal child health posts. In addition to the health centres, there are six peripheral health units (“PHU’s”) in Marampa Chiefdom, which provide primary health care. However the units are understaffed and running costs are high. Education In line with poverty and poor health conditions, education and literacy levels are also poor in the area with 47% of people being illiterate (SRK Household survey 2011). Local people understand the importance of education; however education is a risky investment for families as it is expensive and there is no guarantee families will see a return on their investment. Very few people in the area complete secondary school. 6 RESETTLEMENT PLANNING ACTIONS To develop a RAP the following actions will be undertaken; • identification and implementation of measures to minimise resettlement; • identification of affected people; • assessment of eligibility for compensation; • execution of a census and assets register; • development of an entitlement framework, outlining compensation criteria and rates; • identification of host areas for resettlement; • development of procedures for resettlement and compensation; 3 Ajei, M.O (2008). Government of Sierra Leone/World Bank Mining Sector Technical Assistance Project Resettlement Policy Framework Final Draft. Nimba Research & Consulting Co. Ltd. U3823_Marampa_Resettlement_Final.docx September, 2012 Page 12 of 28 SRK Consulting Marampa RF – Main Report • identification of procedures for monitoring and evaluating the resettlement process; and • identification of institutional arrangements for the execution of the resettlement and compensation process. 6.1 Minimising Resettlement IFC PS 5 on resettlement and land acquisition requires that any resettlement of households only occurs if all possible measures have been exhausted to avoid resettlement. Where resettlement cannot be avoided it must be minimised as far as practicably possible. The location of open pits is determined by the ore body. The relocation of the villages that are located directly on the proposed open pits or in close proximity to them therefore cannot be avoided. However the location of other infrastructure such as the TSF, the WRD and the plant has, together with other technical factors, been determined so as to minimise any direct impacts on existing villages. The alignment of the haul road also takes into consideration the location of existing villages. Further exploitation of measures to minimise resettlement will be undertaken during the RAP process. 6.1.1 Project Affected People Project affected people (PAP) can be divided into two categories: • Affected households: households are affected if one or more of the household members are impacted by physical or economic displacement including loss of assets, land and property, and/or access to natural/economic/social resources. • Host area households: host area households refer to those households in the area(s) where displaced peoples will be resettled. These area(s) will be selected prior to any resettlement based on thorough investigation of suitable options. Households in the selected host area(s) may be impacted by increased population pressure on social and/or natural resources due to. 6.1.2 Types of Loss It is anticipated that PAPs are expected to experience a loss or disruption of access to the assets and resources outlined in Table 6-1. A detailed description of the number and type of affected people in terms of the various eligibility criteria will need to be provided in the RAP. Table 6-1: Types of assets and resources impacted Category of loss Description Homesteads It is estimated 10 villages (comprising 162 households, 1,780 people) within will need to be entirely resettled. Agricultural Land It is estimated the 10 villages to be resettled will also lose their agricultural land. In addition a further 13 villages (270 households (or 2,936 people)) may experience partial loss of access to land which is currently being used for agricultural purposes. Sacred sites Sacred sites including places/ features such as forests and bushes which are important for customary rituals and culture, graves and cemeteries may also be lost (or access to them may be disrupted). Natural resources Areas used by local inhabitants for harvesting of natural resources including hunting, collecting of firewood or wild plants will be lost. Approximately 432 households will lose access to land based resources. U3823_Marampa_Resettlement_Final.docx September, 2012 Page 13 of 28 SRK Consulting Marampa RF – Main Report Small enterprises Small businesses such as shops and kiosks which are operating in directly or indirectly affected villages may experience loss of customer base or suppliers. Social Communal infrastructures in the 10 directly affected villages including schools, infrastructure health centres, religious and community buildings will be lost. This may also affect neighbouring villages that are not relocated but share the use of those resources. Access routes Access routes to natural resources, markets and other villages may be impacted. 6.2 Eligibility: Cut-Off Date Eligibility for compensation is defined in terms of PAPs affected by the categories of loss described above and whether they were present before an eligibility cut-off date. A cut-off date signifies a date after which any building work or improvements on affected land will not be compensated for. This includes new households moving into the area or current households improving their houses. This cut-off date needs to be made public to all those affected through a public consultation process and be well advertised throughout the Project area. Sierra Leone national law does not make provision for the declaration of a cut-off date (or moratorium); however it is required by IFC PS5. MIOL will be responsible for identifying and effectively publicising the cut-off date. An agreement will need to be reached with the local authorities and the affected communities on the procedures to be used in the event of claims being submitted after the cut-off date, as well as in the event of counter-claims and disputes. 6.3 Census and Assets Inventory To develop the RAP a thorough understanding of the existing socio-economic context of the affected households and an inventory of their assets are required. The process for achieving this is set out in the following sections. 6.3.1 Census A census will be undertaken of all households which will lose access to land for agriculture and/or be physically displaced to fully understand their current baseline conditions. The census should include: • demographics of each household; • illness amongst household members in the past year; • deaths and births within the household in the past year; • usage of communal social infrastructure; • access to land and access to resources on communal land; • livestock ownership; • household economic activities; • household income and sources; • details of loans / savings; • expenditure; • food availability, and • ownership of a predetermined collection of material possessions to be used as indicators in ascertaining the socio-economic status of the households. 6.3.2 Assets Inventory U3823_Marampa_Resettlement_Final.docx September, 2012 Page 14 of 28 SRK Consulting Marampa RF – Main Report Inventories will need to be made of affected household and of communal assets. Aspects for inclusion are outlined below. Individual Household Assets The assets inventory will record both permanent and temporary losses of physical infrastructure and natural resources including: • homesteads and homestead structures including the number of buildings their size and the condition (photographic evidence should also be taken); • family business-related structures; • graves associated with the household; • agricultural fields owned/rented/ leased, or given for use; • crops; and • economically beneficial trees, within the homestead and plantations. The census and assets inventory provides a register of the legitimate beneficiaries within the Project area prior to the cut-off date and also provides a baseline for monitoring. Communal Infrastructure An inventory of communal infrastructure in the affected area will also be required. This should include: • schools; • health centres; • community toilets; • market areas; • churches/ religious buildings; • grain banks; • food drying areas; • sites of cultural or historical importance. • administrative buildings; and • recreational buildings or sports facilities. 6.3.3 Census and Inventory Asset Methodology The following steps will be undertaken in the execution of the census, household assets survey and community infrastructure audit: • recruitment and training of local fieldworkers; • design and piloting of the census and asset survey; • meeting with PAPs to explain the purpose and method of the surveys; • provision of an ID number to all households/individuals involved in the census. The household head will be photographed with the ID number in front of his homestead /affected structures/area; • photographing of all structures, with GPS coordinates of the main building; • interviewing the PAPs. Ensure the household head is present during the interview and that he/she countersigns the inventory sheets as proof that he/she agrees to the assets that have been recorded (Note: the signature of the household head does not signify acceptance of a compensation package only recognition that the data were correct when collected);ensure a community representative, also signs the inventory sheets as a witness to the recording exercise, and U3823_Marampa_Resettlement_Final.docx September, 2012 Page 15 of 28 SRK Consulting Marampa RF – Main Report • entry of data from the census and assets register and photographs in an electronic database for record keeping and analysis. 6.4 Entitlement Framework 6.4.1 Valuation Valuation will be based on both international best practice guidance and Sierra Leone national law. Valuation rates and the process should be ratified by a Resettlement Working Group (RWG) (see Section 7.1 below), relevant authorities and the affected stakeholders. The valuation process should take cognisance of the compensation rates used by the London Mining Project due to its close proximity. 6.4.2 Compensation for Loss of Homesteads and Fixed Structures There are two options to compensate PAPs for loss of homesteads and fixed structures. These are: Option 1: Compensation for all homestead structures is provided in cash, that covers replacement costs of materials, cost for transportation away from current homestead to the new home and cost for labour to construct the new homestead. Option 2: Compensation is provided by replacement (to the same or better standard) of the primary structures of the homestead in an identified host area. It is recommended that a local contractor is hired to build the houses and that local labour is employed, whilst MIOL ensures quality control. In this option cash compensation will be given for secondary structures that will not be replaced. Any of the structures which can be deconstructed and removed are allowed to be taken to the new homestead. MIOL will undertake the transportation of removable items to the new home. Option 2 is the recommended option. In accordance with IFC PS 5 cash compensation for structures is discouraged to avoid the risk cash is not spent on housing (which would leave households without shelter). Compensation should be provided for loss of materials in the case of incomplete structures but no compensation will be offered for abandoned structures. 6.4.3 Compensation for loss of Land The Project will require the lease of land, which will be guided by Sierra Leone’s Provinces Land Act, Chapter 122 of the Laws of Sierra Leone, 1960 (section 4.1.1). A land lease contract will be required for the affected land in the Marampa, Maforki and Masimera Districts. Lease rent will be paid. Government guidelines are US$3.60 per acre, with one third paid to the Chiefdom council, one third to the District Council and one third to the respective traditional landowners. It is the task of the District Council to pay out the fees to the respective parties. The process of paying out compensation for loss of land can be complex because: • land is not individually owned rather it belongs to family clans/ villages; • land has generally not been surveyed and no records of ownership exist and disputes over land are common; • people using the land are either a member of a landowning family or rent land from the land owning family, therefore tenants will be a vulnerable group as they will not receive lease rent, and • land lease infers that land will be returned on completion or termination of the lease agreement. In some instances land will not be returned and this should be taken into U3823_Marampa_Resettlement_Final.docx September, 2012 Page 16 of 28 SRK Consulting Marampa RF – Main Report account. Affected households will be provided assistance to access alternative land. Livelihood restoration programmes to enhance agricultural productivity will also be included in the RAP. 6.4.4 Compensation for Crops and Trees Standing crops will be compensated for. The main crops are rice, cassava, groundnuts, maize and sweet potatoes. Only exotic trees belonging to households or communities which have been specifically planted and are used for food or other economic benefits will qualify for compensation. The most common trees used for food and as a source of income are palm trees, mangoes, bananas, oranges and pineapple. The quantity of affected crops needs to be measured and number of trees counted by a team including the affected person, a company representative, a representative of the Ministry of Agriculture and a representative of the local chiefdom. The numbers of trees and areas of crops will be included in the assets inventory. According to IFC PS 5, crops and trees need to be compensated in line with the market rates. The Government of Sierra Leone provides compensation rates, but these were determined in 2006 and are regarded as out-dated (see Table 6-2). It is therefore recommended the compensation rates are guided by the recent rates identified for the Addax Biofuel Project in Sierra Leone (See Table 6-2) and those use by London Mining and AML (if these can be obtained from the relevant companies). Table 6-2: Proposed Compensation Rates Item Government Value 2006- Value 2010 (Addax 2007 (SL Leones) Project) (SL Leones) Banana tree 20,000 26,620 Bread fruit tree 40,000 53,240 Cabbage ½acre 35,000 46,585 Cashew tree 50,000 148,000 Cassava ½ acre 150,000 350,000 Cassava ½ acre immature 50,000 175,000 Cassava not dense - grown in heaps ½ acre mature 200,000 Cassava not dense - grown in heaps ½ acre immature 100,000 Citrus tree 50,000 72,500 Cocoa tree 45,000 73,500 Coconut tree 40,000 73,500 Coffee 1 acre 35,000 46,585 Cucumber ½ acre 30,000 39,930 Economic tree (Timber individually owned) 20,000 54,400 Groundnut ½ acre 150,000 199,650 Guava ½ acre 15,000 19,965 Hot pepper ½ acre 30,000 39,930 Kola nut tree 40,000 76,400 Krain krain ½ acre 50,000 66,550 Lettuce ½ acre 35,000 46,585 Maize ½ acre 100,000 133,100 Mango tree improved 50,000 66,550 Millet ½ acre 100,000 133,100 U3823_Marampa_Resettlement_Final.docx September, 2012 Page 17 of 28 SRK Consulting Marampa RF – Main Report Item Government Value 2006- Value 2010 (Addax 2007 (SL Leones) Project) (SL Leones) Oil palm tree 25,000 33,275 Oil palm tree improved 40,000 57,000 Okra ½ acre 40,000 53,240 Paw paw tree 10,000 13,310 Pear / avocado tree 60,000 79,860 Pineapple plant 1,000 1,331 Plantain tree 20,000 26,620 Plum tree 50,000 66,550 Pumpkin ½ acre 30,000 39,930 Rice (inland valley swamp) ½ acre 200,000 266,200 Rice (upland) ½ acre 200,000 266,200 Sweet pepper ½ acre 36,000 47,916 Tomatoes ½ acre 35,000 46,585 Water melon ½ acre 40,000 53,240 Note: At the time of the writing of the report US$1 = 4,368 SLL The crop/tree owner will be paid the agreed rate multiplied by the acres of crops/number of plants/trees lost. This compensation fee is a one off payment. However the loss of fruits over a period of time, until new seedlings are of fruit bearing age needs to be taken into account for the calculation of the compensation fees. If the farmer does not own the land, the crop compensation will still be paid to the farmer while any land compensation is paid to the owner of the land. In line with IFC PS5 the Company will provide replacement seedlings to replace the trees lost. According to IFC PS5 replacement seedlings will only be provided for fruit/nut trees and not for timber trees. 6.4.5 Compensation for Disturbance of Graves and Sites of Cultural, Historical or Religious Importance There are three options for compensation for disturbance of graves: • homesteads may choose to re-bury remains of the deceased on or near their resettlement plot, • communal re-burial may be arranged with local entities (municipality, and traditional leaders, as well as religious leaders). In such cases an appropriate piece of land is to be identified in consultation with the local authorities, and • homesteads may choose not to relocate graves, but may instead hold a ceremony in accordance with local customs. In the first two options appropriate timing and arrangements for the relocation and re-burial of the deceased will be agreed upon with all stakeholders. The Company will meet associated costs, which may include: • exhumation including permit (if required), transport and re-burial (re-interment) of the deceased; • provision of a coffin from an approved supplier; • provision of a flat rate per grave to satisfy any customary cost; • all works associated with the burial; and • all reasonable costs associated with a ceremony if not relocating the grave. Affected households/religious leaders are responsible for organising the appropriate ceremonies in accordance with their religious beliefs and/or customs. U3823_Marampa_Resettlement_Final.docx September, 2012 Page 18 of 28 SRK Consulting Marampa RF – Main Report In terms of communal sacred sites or cultural heritage, a process for appeasement of disturbance of the site and potentially the establishment of a new site will be negotiated with affected communities. MIOL will cover the cost of obtaining the new site and the appropriate ceremonies. Local communities and religious leaders will be responsible for organising the ceremonies. 6.4.6 Compensation for Loss of Natural Resources The extent and nature of loss of access to different types of natural resources will be assessed in the RAP census and compensation strategies for each type of loss negotiated with local communities and in the RWG. These may include: • development of wood lots in case of loss of timber and firewood; • development of nurseries for lost plants (especially wild herbs); • development of alternative livelihoods for those relying on natural resource production; and • identification and arrangement of alternative grazing areas. 6.4.7 Compensation for Affected Businesses Loss of local businesses will be compensated. For the valuation of the loss of an enterprise its function, intensity of use (average monthly income), location, importance and market catchment areas will be determined. Valuation will be based on the cost of re-establishing the commercial activity at a new location. This may include costs for: • acquisition of new land; • material and construction costs of replacement structures; • compensation for lost stock; • compensation of lost income during period of closure during resettlement; and • compensation for loss of staff wages. 6.4.8 Compensation for Loss of Communal Social Infrastructure The most important requirement of the IFC PS 5 is to ensur resettled households are not worse off after the resettlement process. This may require the upgrading of existing social infrastructure or building of new infrastructure in the host areas. Infrastructure should be equal to or better than that being replaced. Community structures or resources to be upgraded or developed may include: • health centres (including the clinic at Marunku); • community halls; • markets; • schools; • religious buildings; • village grain banks and drying floors or structures, and • wells/boreholes. The valuation of community infrastructure and resources will require consultation with community leaders, committees or individuals that have responsibility for community structures of both the resettled community and the host community. The valuation will be based on replacement costs of materials, buildings costs and the acquisition of additional land. Not all community structures will need to be replaced - religious buildings are often not rebuilt by companies, however compensation will be provided. U3823_Marampa_Resettlement_Final.docx September, 2012 Page 19 of 28 SRK Consulting Marampa RF – Main Report 6.5 Identification and Evaluation of Resettlement Sites/host areas Resettlement will require the identification of a single large area or multiple smaller areas for residential purposes (for those physically displaced) and identification of multiple areas of agricultural land for those economically displaced. Ideally for each affected household several options will be explored. In order to assess the feasibility of different options the following is required: • assessment of land ownership and tenure rights; • assessment of the need for improvement of infrastructure to accommodate additional inhabitants; • assessment of the impact of resettlement on small businesses in resettled communities and host community; • assessment of available agricultural land in the vicinity of the resettled communities;. • assessment of access to natural resources ; • assessment of access to livelihood strategies, and • assessment of disturbance of community and family support networks. The assessment should be conducted: • in consultation with the affected villages, and • in consultation with the RWG in terms of legal aspects, perceived advantages and disadvantages of the various options. The process will involve: • pre-selection of candidate sites; • visits to pre-selected resettlement sites with affected community members; • selection of preferred sites in collaboration with relevant authorities; • conducting an Environmental and Social Impact Assessment (ESIA) to assess the impacts on the selected sites, and • validation of the choice in general community meetings; Once the feasibility of the host areas has been established a detailed plan for the host areas will be developed indicating any existing dwellings and infrastructure as well as the areas allocated to new dwellings, additional infrastructure, agricultural land and the existing transport network. 6.6 Support provision IFC PS 5 states that additional support may be required for PAPs during the resettlement period. Depending on the timing of the resettlement, it is possible that households will not be able to farm during a particular period. Others may need time to develop new livelihood strategies. These households will require support and support packages will be developed together with the affected households. It is recommended that this is done in cooperation with competent organisations and in consultation with the RWG. 6.7 Income Restoration and Sustainable Development Initiatives Besides the loss of assets, resettlement may lead to permanent disruptions of income-earning or subsistence capacity. IFC PS 5 resettlement guidelines require that if Project-related impacts are significant (with a 10% or greater loss), livelihood restoration needs to be included in the RAP. To restore livelihoods for the affected people, there may be a need to assist with the U3823_Marampa_Resettlement_Final.docx September, 2012 Page 20 of 28 SRK Consulting Marampa RF – Main Report preparation of new land and the provision of agricultural support and extension programme. This may include: • provision of training on improved agricultural techniques, and • support for the purchase of agricultural equipment, fertilisers and improved seeds. Skills replacement training will be provided for households in which the continuation of an agricultural lifestyle is not possible or desired. The primary objective of the skills replacement training will be to teach skills that could be of value in the local economy and could replace agriculture in terms of income generated. Potential skills to be taught include building; carpentry; plumbing; welding, Partnerships can be established with NGOs and other relevant agencies to run the skills training. 6.8 Vulnerable Individuals and Households Vulnerable individuals, households and groups need to be identified and receive specific attention throughout the RAP in line with international best practice. Vulnerable groups are those who are likely to be more affected by resettlement than the rest of the population as they are less likely to have the capacity to deal with negative impacts, and to benefit from enhancement measures. The groups listed below are generally defined as vulnerable; however the Project should seek to identify specific vulnerable groups in their area: • the extremely poor (those below the general level of poverty which exists in the area); • female or child headed households; • households without access to land; • elderly, specifically households where no members are below the age of 60; • disabled or sickly people or those who cannot work land; • internally displaced and orphaned children, and • groups suffering social or economic discrimination such as indigenous groups. It is often observed that vulnerable people do not participate in community life to the same extent as the general population and therefore may be invisible to the Project. Efforts need to be made to identify the vulnerable people. Vulnerable groups should be given specific assistance at all stages of the Project but in particular during the resettlement process. These groups should also be monitored and offered further assistance once they have been compensated/ resettled. Specific assistance for vulnerable groups may take one or several of the following forms: • provision for separate and confidential consultation; • priority in site selection in the host area; • relocation near to kin and former neighbours; • assistance with gathering materials from their home which can be moved to the new site; • assistance with moving to the new site; • assistance with building structures and collection of materials; • assistance with compensation payment procedure; • priority access to mitigation and development assistance during the post-resettlement period, particularly if the support networks that the vulnerable person was relying on have been affected, and • access to health care if required during the resettlement and transition periods. 6.9 Community Development Initiatives U3823_Marampa_Resettlement_Final.docx September, 2012 Page 21 of 28 SRK Consulting Marampa RF – Main Report To comply with international best practice, Projects which involve involuntary resettlement - either physical or economic - should seek to implement community development initiatives. The aims of community development initiatives are to: • stimulate long-term community, economic and social development programmes; and • assist in building relationships between the company and other community development programmes running in the Project area of influence. Community Development Plans (CDP) should be developed using the data collected during the census and as part of the social impact assessment process. Community development benefits will apply to everyone living within the Project area of influence; however people directly impacted by physical and or economic displacement and host communities should receive priority in terms of development initiatives. 6.10 Resettlement Process When relocated families take occupation of the new homestead the following points are recommended best practice: • a reasonable and agreed time period should be allowed prior to relocating people so they have time to salvage building materials from their old homestead; • transport should be provided for each homestead to move themselves and their belongings to the new home including livestock, food and personal furniture, • households need to sign a document to forego all rights to the old homestead once they have collected all of their belongings. The old residence should be demolished as soon as possible to remove the risk of squatters; and • a company representative should visit households a month after they have moved in to assess the new structure and note potential defects and arrange for repairs, the company should provide a 5 year structural warrantee for the dwelling to cover design, workmanship and material defects. 7 STAKEHOLDER ENGAGEMENT Engagement with stakeholders facing involuntary resettlement is one of the main requirements of IFC PS5. PAPs should have ample opportunity to participate in the planning and execution of the resettlement programme which affect them. Engagement should include a two way exchange of information allowing the Project staff to provide the PAPs with timely information but also for the Project staff to listen to stakeholders’ concerns and opinions on the resettlement plan. The stakeholder engagement approach should build upon the existing Stakeholder Engagement Plan (SEP) prepared by SRK for the ESIA process. 7.1 The Resettlement Working Group (RWG) The Project will assist in the development of a RWG to take charge of the resettlement preparation and execution. The RWG should consist of: • a representative of MIOL; • representatives from relevant provincial government departments; • representatives from the traditional and community leadership; • representatives of directly affected land owners; • representatives of directly affected tenants; • a representative of local women’s organisations; U3823_Marampa_Resettlement_Final.docx September, 2012 Page 22 of 28 SRK Consulting Marampa RF – Main Report • a representative of local youth organisations; • relevant local NGOs; • a representative of the District Council, and • a representative of the chiefdom council; The main objectives of the RWG are: • to identify and approve the host area(s) where people will be resettled to; • to act as the primary channel of communication between the various stakeholders involved in the resettlement process particularly between PAPs and the Project; • to act as a forum at which MIOL can consult on various resettlement aspects, i.e. debate the Entitlement Framework (EF) that is generated for the RAP, and • to deal with grievances that arise during the resettlement process. 7.2 Community Resettlement Committees Community Resettlement Committees (CRCs) will also need to be established in each (cluster or single) village(s). The CRC should be made up of: • the village chief(s); • a representative of the tenants of the village; • a representative of the landowners of the village; • a representative of the youth organisation of the village, and • a representative of women’s organisations of the village. The CRCs should meet on a regular basis to ensure the timely and effective flow of communication between the Project and the communities. The CRCs should also assist with the implementation of the census and assets survey and be involved in the negotiation of identifying host areas. 7.3 Public Consultation In addition to the RWG and the CRCs regular meetings, public meetings should take place with the PAPs in the local areas. An initial meeting will need to take place before the RAP is developed to ensure people are aware of the resettlement process. In this initial meeting PAPs should be informed about the census and assets inventory which all households will need to complete. A second round of public meetings should occur after the RAP has been developed. This second round of meetings is to disclose the RAP to the PAPs. Appropriate documentation should be provided to PAPs and they should be allowed time to read the information and be given opportunity to express their concerns and opinions. 7.4 Grievance Mechanism IFC guidelines require a grievance mechanism, which should be an effective, accessible method for individuals or groups of PAPs to raise grievances with the Project through an official channel. PAPs should be able to raise grievances during community meetings, through the Company community liaison officer or the RWG or CRC. The grievance mechanism should follow the steps outlined below: Step 1: Receipt of Grievance Grievances received through any of the channels outlined above should be passed to the community liaison officer who should enter the complaints into a complaints register. There U3823_Marampa_Resettlement_Final.docx September, 2012 Page 23 of 28 SRK Consulting Marampa RF – Main Report should be a register in each of the community liaison offices around the Project area (if more than one) and grievances should be entered in English and Krio. Once the grievance has been submitted a receipt should be supplied to the complainant. Step 2: Assessment of the Grievance The community liaison officer should initially attempt to resolve the grievance locally. If not able to resolve the grievance it should be communicated to the Project’s social manager. Step 3: Acknowledgement of Complaint/Grievance The decision on how the issue will be resolved should be communicated to the complainant both verbally and in writing. It should also be explained what the expected time frame for resolving the grievance will be. Step 4: Investigation and Resolution of Grievance The Project should undertake an internal investigation to determine the underlying cause of any grievance and if required make changes to internal systems to prevent the grievance reoccurring. In order to fully investigate and resolve the grievance it may be necessary for the Project to hold a meeting with the complainant. This should be done in consultation with the RWG. Once the investigation has been completed and necessary measures been taken, the results will be communicated to the complainant and entered in the register. The complainant will be asked to sign that he/she accepts as the ‘solution’. The action to correct the grievance should be verified by the community liaison officer as appropriate to the complainant. If the complainant disagrees with the decided course of action, further corrective actions should be agreed and carried out by MIOL, or the complainant should be advised of the next step in logging his/ her grievance e.g. elevating the complaint to local or central government. If a complainant decides to open a legal case against the company, MIOL should not obstruct this decision. 8 COMPANY RESPONSIBILITIES In addition to the RWG and CRC, the Company has specific responsibilities for ensuring the RAP is developed and executed in line with Sierra Leone national law and international best practice. MIOL is responsible for all financial responsibilities, managerial and technical resources and expertise. The Company should develop a Resettlement Unit which should be managed by the Social Manager who is responsible for reporting to the General Manager. MIOL may decide to contract out their resettlement responsibilities to an external contractor with specific expertise in the area, in which case the steps listed below will be undertaken by the contractor, who will report to the Social Manager. During development of the RAP, MIOL (or the contractor) will: • develop a Terms of Reference for resettlement; • identify PAP who qualify for compensation; • develop an entitlement framework; • arrange for a cut-off date for compensation; • conduct the census and develop an assets register; • develop and execute a stakeholder engagement plan for the resettlement planning; • identify any specific vulnerable groups within the Project area (see 7.73); U3823_Marampa_Resettlement_Final.docx September, 2012 Page 24 of 28 SRK Consulting Marampa RF – Main Report • coordinate the selection of alternative resettlement sites; • Project manage the development of the land-use plan for any host resettlement areas; • present, discuss and obtain approval for any developed land-use plans with relevant government authorities; • ensure the RWG remains in operation after the RAP is finalised and until the Project is implemented; • provide a representative to be part of the RWG meetings, and • provide administrative, managerial and technical support as required by the PAPs, RWG or CRC. During the implementation of the RAP, MIOL (or the selected contractor) will be responsible for: • developing offer documents and discussing the terms and conditions with each individual affected household; • planning and monitoring the replacement of communal social infrastructure; • planning and supervising the compensation activities; • providing transportation and assistance for moving people and belongings into new houses; • design and implement community development and monitoring programmes to ensure affected households are not worse off once they have been resettled; • providing continued assistance and monitoring of vulnerable groups; • establishing a monitoring programme to ensure PAPs are not worse off post resettlement; • monitoring and reporting on the construction of replacement structures; and • managing of the grievance mechanism. 9 MONITORING Monitoring of the resettlement process, which is an IFC PS5 requirement, enables the Company to assess whether the procedures and objectives laid out in the RAP are being accomplished. Monitoring should be both internal and external to ensure it meets international standards. 9.1 Internal Monitoring Internal monitoring should be implemented to allow the company (or contractor) to measure the resettlement process against goals set out in the RAP. Internal monitoring will include interviews with PAPs and MIOL staff involved in resettlement and compensation, review of resettlement and compensation documents, surveys with resettled peoples and host communities and observations in the villages. Internal monitoring will: • ensure that valuation and compensation has been carried out in line with national laws and international best practice; • ensure stakeholders have received adequate notification of Project stages; • confirm all land-acquisition issues are resolved; • ensure the census has been carried out and has covered all PAP; • ensure all grievances are appropriately recorded and resolved; • ensure all agreed resettlement measures are implemented in accordance with the RAP; U3823_Marampa_Resettlement_Final.docx September, 2012 Page 25 of 28 SRK Consulting Marampa RF – Main Report • confirm that the funds required to implement resettlement activities are provided in a timely manner, are sufficient for purpose, and are spent in accordance with the RAP; and • submit monitoring and evaluation reports periodically. Monitoring will take place periodically both during the resettlement period and after resettlement has taken place to ensure resettlement has not left the resettled people, or host communities, worse off than pre resettlement. 9.2 External Independent evaluation /audit In addition to internal monitoring, external monitoring should be conducted by an independent group, the main aim being to assess the impact of resettlement and the resettlement process and to ensure the objectives set out in the RAP have been executed. Monitoring should be conducted twice a year for at least three years after resettlement has taken place. The initial monitoring will evaluate the resettlement process and subsequent monitoring after the first year will monitor conditions against baseline data collected in the census including: • housing - quality of roof, walls, floor; • agricultural yields; • possession of livestock; • land lease rent; • access to safe water; • distance to water source; • ownership of material assets; • patterns of employment and income generation activities; • income/expenditure/debts per household; • improvement in production/income for women/youths; • capacity building, skills / vocational training; • community infrastructure and access to transport routes/ public transport services; • children in school by age and sex; • distance to primary school; • access to sanitation; • incidence of disease; • distance to health centre, and • HIV/AIDS and STD prevalence aggregated by gender and age. Once the external monitoring report has been completed MIOL will need to meet with the RWG to discuss the findings and put in place remedial plans were necessary. 10 BUDGET A resettlement action plan should provide an estimate of the budgetary requirements for implementation of the resettlement measures. This section identifies the components that will form part of the overall budget. The key components of the overall budget should typically be: • the cost of replacement land; • the cost of building replacement housing and community structures such as schools, churches, grain banks, etc; • cash compensation for the crops/ trees and relocation; U3823_Marampa_Resettlement_Final.docx September, 2012 Page 26 of 28 SRK Consulting Marampa RF – Main Report • the cost of implementing a livelihoods restoration programme for the directly affected people; • implementation costs (e.g. salaries, overheads and the cost of stakeholder consultations); • the cost of training for the project implementation team; and • monitoring and evaluation costs. 11 TIMING The resettlement schedule should define timing of the key steps and activities in the process. These should be linked with the Project’s construction schedule to ensure timely availability of land for start of different Project activities. The full schedule will be developed as part of the RAP, however it should at least include the following activities/tasks: • create the RWG; • explore opportunities for minimising resettlement; • conduct census survey; • declare moratorium; • develop entitlement framework; • identify relocation sites; • negotiate entitlements; and • consultations with PAPs (on ongoing basis) 12 CONCLUSION The RF provides an outline, which is in compliance with IFC PS 5 and Sierra Leone requirements on land acquisition and resettlement, to ensure planning for an effective resettlement programme for the affected parties. The RFP provides a basis for a Project specific RAP to be produced. 13 REFERENCES Ajei, M.O (2008). Government of Sierra Leone/World Bank Mining Sector Technical Assistance Project Resettlement Policy Framework Final Draft. Nimba Research & Consulting Co. Ltd. GoS (2008) Environmental Protection Agency Act, Government of Sierra Leone, 2008 GoS (2009), Mines and Minerals Act, Government of Sierra Leone, 2009 IFC (2012) Performance Standards on Social & Environmental Sustainability, International Finance Corporation June 2006 IFC (2007) Guidance Notes: Performance Standards on Social & Environmental Sustainability, International Finance Corporation, 2007 IFC (2007) Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets, International Finance Corporation, 2007 SRK (2012) Socio economic baseline report for the Marampa Iron Ore Project, SRK Consulting (UK) Ltd, April 2012 U3823_Marampa_Resettlement_Final.docx September, 2012 Page 27 of 28 SRK Consulting Marampa RF – Main Report World Bank Operational Policy (OP) 4.124, World Bank, 2004 For and on behalf of SRK Consulting (UK) Limited Lalit Kumar Fiona Cessford Senior Consultant, Social Corporate Consultant, Environment SRK Consulting (UK) Limited SRK Consulting (UK) Limited 4 (www.worldbank.org) and in the World Bank's Resettlement and Rehabilitation Guidebook. U3823_Marampa_Resettlement_Final.docx September, 2012 Page 28 of 28 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix E APPENDIX E E PRELIMINARY PROJECT DESIGN DRAWINGS U3823_Marampa_ESIS_Final.docx September 2012 Page E1 of E1 APPENDIX E1: PRELIMINARY WATER MANAGEMENT PLAN 1 Mining Solutions Consultancy Pty Ltd Phone (+61 8) 9450 3399 ABN 16 082 728 836 Fax (+61 8) 9450 3377 5 Salter Point Parade, Salter Point, Western Australia 6152 www.miningsolutions.com.au INTEROFFICE MEMORANDUM To: Jeff Hamilton Date: 5 April 2011 Co.: Marampa Iron Ore Limited Ref: Cc.: Tony Boucher From: Tamer Dincer Re: Marampa Iron Ore Project – Preliminary Mine Surface Water Management Plan Introduction The Marampa Iron Ore Project (Project) site is situated in a topographically low lying area with numerous streams and swamps located at or close to the location of the proposed open pits and waste dumps. Figure 1 shows the location of the proposed open pits in relation to the streams, swamp areas and topography contours at 5m intervals. The general direction of the surface water natural drainage at the project site is to the south (Figure 1). The is no major drainage routes crossing through the Gafal and Rotret open pits as they are located mostly at the higher ground. No significant flows are expected through the two streams crossing the Matukia pit as the catchment areas feeding these streams are small. The major stream crossing the Mafuri pit at the east (MFE) will be critical in the development of the open pits as the catchment area is significant with limited drainage diversion options due to the alignment of the hills in this area. Although relatively limited flows are expected, the stream crossing the western end of the Mafuri pit (MFW) will also need diverting before the start of mining MAfuri pit first in this area. The flows through the smallest stream at the centre of the Mafuri pit (MFC) will be insignificant due to the small upstream catchment area. Proposed Mining Strategy The plan views of the preliminary mine site layout shown in Figures 2 and 3 summarise the preliminary mining plan in two major phases. After building external waste dumps from the earlier mined pit stages (Figure 2), the proposed mine development strategy facilitates the backfilling of the earlier mined areas with the waste from the later mined pit areas (Figure 3). The strategy will allow approximately 50% of the pit areas backfilled with waste and tailings, significantly reducing the area otherwise required for the external waste dumps. The mining and backfilling sequence can be further summarised as follows: 1 • Development of the western part of the Mafuri pit earlier, which will be available for waste backfilling after 2020 from the development of eastern pit areas (first concentrate shipment planned for early 2015), • Completion of Rotret ultimate pit by 2025, which will be available for waste backfilling from later pit stages developed in the Gafal West and Mafuri East areas, • Completion of Matukia ultimate pit by 2024, which will be available for tailings storage for the rest of mine life, and • Completion of Mafuri eastern and Gafal western pit boundaries (joining boundaries) latest will delay the MFE stream diversion towards the end of mine life. In terms of surface water drainage, the timing and staging of the pit development in the Mafuri central and eastern areas will be critical through mine life. The development of Mafuri pit stages from west to east and Gafal pit stages generally from east to west will allow flexibility in planning and construction of the major MFE stream diversion. As indicated by the preliminary economic analyses, this strategy also provides favourable cash flow profile for the project from an economic point of view. The proposed external waste dumps for the open pits will not be affect the natural surface water drainage generally as the waste dumps are generally located at the higher ground. Surface Water Management Plan The flat lying topography, the orientation of the hills and the general topographic inclination at the site require that any diversion of surface water should also directed to the south while preventing any significant rise of the accumulated water level in the catchment. Accumulated water levels above approximately 70mRL will cover a relatively large area, potentially affecting some road crossings and other structures during the rainy season. The major drainage works in the area required for the development of Mafuri pit in stages can be summarised as follows (Figures 2 and 3). 1. Excavation of the drainage channel and bund construction will be required to divert the MFW stream before the start of mining Mafuri oxide pits (2016 Q3). The channel to the west of pit boundary will be generally shallow except a ~200m section cutting thorough a hill. Some sections will require only the construction of bunds to keep water away from the pit. The drainage as shown in Figure 2 is located relatively close to the pit crest considering the limited flows expected and waste backfilling of this section of the pit relatively early in mine life. 2. Excavation of a major drainage channel will be required at the north of the Mafuri pit to divert the water from the largest MFE stream before the development of last stages of Mafuri and Gafal pits (~2023, Q4). The excavation of this channel with a maximum depth of 10-12m and length of 600m will be the largest drainage work for the management of surface water drainage for mining at the site. 3. As the channel excavation at the north of Mafuri (2) is completed, mining and waste backfilling of the Mafuri pit in the central area needs to be finalised to allow diverted water to cross the Mafuri pit area (west of 768,000mE). Although drainage over the backfill material is not ideal, this would be the most feasible option considering the topography constraints. Suitable materials and construction methods will be required to seal the channel as much as possible over the waste backfill. 4. After the construction of the channels in 2 and 3 above, the water flow in the main MFW stream can be diverted with a bund constructed along 959,150mN (~Year 2023, Q4). This will accumulate approximately 3-4m deep water in the lower catchment as the water level rise and flow through the newly excavated channel further north. The approximate areal extent of water accumulation to the north of the proposed bund can be seen in Figure 3. The above is a summary of the major drainage works for scoping purposes based on a review of the available data without undertaking any site visit. Mine water management plan for earlier mine life needs further detailing in the feasibility study (and later during operations), including: • Properties of the ore and waste rocks with respect to exposure to water and drainage may affect the mine design and water management plan. • Further minor drainage channel and bund construction may be required across the pit and waste dump areas as necessary subject to local conditions and detailed mine design. • Planning for water drainage on the waste dump surfaces, direction, treatment and discharge of water flow from the waste dumps will be required as the mining operations advance. • Planning for direction, treatment and discharge of the water dewatered from the pit stages will be required as the mining and backfilling operations advance. • The proposed haul roads will require more detailed planning based on local variations and detailed mine design & mining plan. • Although the topography and the location of the pits are the main factors for major drainage works and a significant change is not expected, there might be social and infrastructure limitations that may need incorporation in the feasibility study plans. Disclaimer This document has been prepared specifically for Marampa Iron Ore Limited by independent consultants. The information contained in this report is based on sources believed to be reliable, and all care has been taken in the preparation of the report. However, Mining Solutions Consultancy, together with its members and employees, gives no warranty that the said sources are correct, and accepts no responsibility for any resultant errors contained herein and any damage or loss, howsoever caused, suffered by any individual or corporation. Figure 1: Marampa Project Site: Major Streams, Swamps and Pit Areas 4 Figure 2: Site Layout before Waste Backfilling Rotret and Mafuri West 5 Figure 3: Site Layout after Rotret and Mafuri West Covered with Waste Dumps 6 APPENDIX E2: PRELIMINARY PROCESS FLOW DIAGRAMS 7                                                          !           !"              !               !           !"              !             !             !             !             !             !           !"                                                                                                          !         !" APPENDIX E3: TAILINGS STORAGE FACILITY DRAWINGS 8 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F APPENDIX F F ENVIRONMENTAL MANAGEMENT PROGRAMME U3823_Marampa_ESIS_Final.docx September 2012 Page F1 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Appendix F: Preliminary Environmental Management Programme The tables below list the management measures identified in the ESIA. The first table presents the commitments arising from the biophysical impact assessment process and relate directly to the identified impacts in Chapter 7 of the ESIA. The second table presents the commitments arising from the social impact assessment (Chapter 8), and the third table presents those arising from the community health, safety and security impact assessment (Chapter 9). The fourth table is a table of general commitments, which are not specific to any individual impact but represent good industry practice. These programmes have been developed as outlined in Section 11.1.4. The column headings are explained below. • Impact reference – this specifies the impacts the proposed management measure influences (Tables 1 to 3 only). • Objective - statement of the objective of the management action/s, which generally addresses the impact/s. • Reference number - a unique reference for the management measure. • Type – an abbreviation indicating the type of the management measure (IH = inherent design or management described in Chapter 4, MM = mitigation measure, EM = enhancement measure, GP = good practice measure). • Management measure - a description of the measure or action, which will be clear, concise and specific enough to enable execution of the action. Where relevant, the appropriate targets, indicators, trigger points and/or threshold levels will be incorporated into the management measure. If a set of management actions is required to meet the objective, the ESMP will be simplified by making a commitment to develop an appropriate supporting document in which the detail will be provided. Where the management measure cross references to another measure under a different impact it is shown in italics. • Project phase – an abbreviation indicating the project phase/s when the management measure is applicable (DD= Detailed design, C = Construction, O = Operation, D = Decommissioning, PC = Post Closure). • Timing – the time when the management action should be implemented and/or completed, and if relevant, how frequently it should be undertaken. • Achievement criteria – an indication of how achievement of the management measure will be assessed, which will be used to develop the monitoring, inspection or audit programmes. U3823_Marampa_ESIS_Final.docx September 2012 Page F2 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Table F1: Management programme to address identified biophysical impacts Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase Progressive Closure and Rehabilitation Plan rehabilitation ongoing developed in consultation with 1 IH Rehabilitate the land and make it available for use by communities post- O, D, Land handed to communities; rehabilitated site closure PC communities after signed off by environmental decommissioning officer and if necessary regulatory authorities Refer to mitigation measures listed for impact RL1 Minimise limits Develop a Construction Management Plan that includes requirements to: on land use by • Minimise the footprint disturbed during construction, operation and Develop the plan prior Plan in place with evidence of LT1 local decommissioning of the Project. to construction implementation. Compliance with communities 2 GP • Minimise the duration of the disturbance by starting rehabilitation as DD, C commencing; the plan included in the contract due to land soon as possible and progressively rehabilitating disturbed areas that implement it during documentation of contractors modification are no longer being used for the Project, and making them available for construction appointed communities to use. Prohibit unnecessary off road driving, and use planned and designated No visual evidence of Project 3 GP access routes and lay-down areas only. C, O, D Ongoing related use of non-designated access routes or lay-down areas. Review and update the Closure and Rehabilitation Plan periodically to At least every three Plan in place with record of 4 GP address current site conditions; community expectations; and the results of O, D years review outcomes ongoing routine monitoring. Minimise LT2 disruption to Refer to measures under RL2 community access routes Open prior to Waste management plan 5 IH Develop a waste landfill site to handle non-mining waste generated by the C, O commencement of implemented; no visible Project- Project. construction and close related waste or waste-related on decommissioning complaints. Minimise visual As soon as Records of consultation with intrusion 6 MM At closure, remove mine infrastructure that does not have a continued use. D infrastructure is no communities and government; associated with longer needed inventory of infrastructure left on LT3 mine activities site, listing its post-closure use and Visual inspection; Rehabilitation infrastructure Phased rehabilitation measures signed off by Revegetate and landscape the site on closure, to reflect the surrounding as operation tails off Environmental Officer in 7 MM topography and vegetation as much as possible. O, D and certain areas are accordance with assessment no longer in use. criteria stipulated in the final closure plan U3823_Marampa_ESIS_Final.docx September 2012 Page F3 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase Signed off by appropriately 8 MM Consider the use of screening tools such as dense vegetation where DD Prior to finalisation of qualified engineer; visual practical and appropriate to the surroundings. design inspection; no community complaints Clear vegetation in phases so that only those areas required for immediate Clear sections shortly Schedule for clearing of areas 9 MM development are cleared. C prior to construction in corresponding to construction that area schedule Develop plan prior to Develop and implement a waste management plan that includes provision DD, C, construction; Completed Waste Management 10 MM for waste resulting from secondary developments and domestic waste O, D implement it from Plan; no visible waste on mine linked to the Project. construction to site and surrounding areas decommissioning 11 GP Paint buildings and structures or use materials with colours that reflect and DD Finalisation of building Visual inspection complement the natural colour and textures of the surrounding landscape. design Rehabilitation measures signed In accordance with a closure plan, the slopes of the WRF and any other When off by Environmental Officer in 12 GP visually intrusive stockpiles will be reduced during closure to be more D decommissioning the accordance with assessment consistent with the surrounding natural topography. site criteria stipulated in the final closure plan Signed off by appropriately 13 GP Use directional lighting in areas operating at night, if communities are C, O Ongoing qualified engineer; Visual affected by lighting. inspection; no community complaints GP Refer to dust control measures under Impact AQ1. 14 MM Avoid disturbance of slopes or sensitive areas such as drainage areas, C, D Ongoing, especially Visual inspection; signed off by where possible. during site clearing Environmental Officer Implement erosion control measures where steep slopes or large Vegetation clearing Visual inspection; ; signed off by 15 MM unvegetated areas are created, or where sensitive areas such as river C, D and earth movement Environmental Officer banks are disturbed. Minimise Inspect disturbed, rehabilitated, and sensitive areas such as river banks Regular inspections, at Visual inspection and decrease in 16 MM affected by project infrastructure for visual signs of erosion and/or C, O, D least on a 3-monthly maintenance of photographic LT4 land capacity deposition affecting either the Project’s or community’s use of the land. If basis records. No community through loss of problems are identified, initiate remedial action. complaints topsoil. Clearing of vegetation Soil Management Plan in place; 17 MM Clear and stockpile topsoil separately from subsoil / fill material, for use C and earthmoving for visual inspection; signed off by during rehabilitation. construction or Environmental Officer rehabilitation Implement rehabilitation and establishment of vegetation cover as soon as As soon as an area is Progressive rehabilitation 18 MM possible. C, O, D no longer in use strategy; signed off by Environmental Officer U3823_Marampa_ESIS_Final.docx September 2012 Page F4 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase Maintain topsoil stockpiles to prevent their erosion or contamination with Soil Management Plan in place; 19 GP subsoil or other materials. C, O Ongoing visual inspection; signed off by Environmental Officer Ensure stockpiled topsoil is used within two years and is not excessively Ongoing, as and when Soil Management Plan in place; 20 GP compacted to preserve a viable seed bank. C, O, D topsoil is cleared visual inspection; signed off by Environmental Officer 21 GP Avoid driving over or otherwise compacting or disturbing topsoil. C, O, D Ongoing Visual inspection Map showing detailed design 22 GP Design roads, pipeline routes and landscape features to minimise disruption DD Prior to construction relative to drainage lines; signed of natural drainage patterns. off by Environmental Officer and engineer 23 IH Maintain a pond on the TSF O Ongoing Visual inspection; signed off by Environmental Officer Implement dust control measures, such as wetting down and maintaining a Ongoing, especially in Plan in place with evidence of 24 MM pond at the tailings storage areas. O dry windy conditions implementation; no complaints about dust Progressive Closure and Rehabilitation Plan in Minimise 25 MM On closure, put in place measures (such as revegetation) to ensure D, PC rehabilitation as parts place; dust monitoring results; effects of wind- continued erosion control of the tailings material. of the TSF are no signed off by Environmental LT5 blown dust on longer in active use Officer soil chemistry Using data collected during the monitoring programme, develop a Soils and land Management Plan to evaluate the effects of blowing tailings dust on soils capability and determine whether further management measures may be required to mitigate impacts from windblown tailings. During early part of Plan in place with evidence of 26 GP The plan should determine: O operations implementation • expected incremental increases in metals and effects of dilution; • extent and effects of remobilisation; • potential eco-toxicological effects; and • removal standards if needed. Prior to construction of RAP developed and resettlement 27 IH Relocate villages directly impacted by mining. DD, C pits implemented in accordance with RAP; RAP close out audit Minimise If monitoring shows effects of pit Provide affected villages with adequate water supply (including for irrigation C, O, D, villages impacted then Monitoring of village water WR1 dewatering on 28 MM of crops). PC ongoing until ground availability; no complaints in this local water supply has regard communities recovered Consider installation of new wells / maintenance or repairs to existing Records of community 29 MM village wells. C Prior to pit dewatering consultation and evidence of well installed or repaired if required U3823_Marampa_ESIS_Final.docx September 2012 Page F5 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase If monitoring shows 30 MM If necessary, make alternative wetland areas available for rice cultivation. DD, C existing cultivated Monitoring changes to extent of wetlands impacted, as cultivated wetland areas and when necessary 31 IH Re-use of water from tailings and other process waters to minimise O Ongoing Evidenced by water balance abstracted amount Minimise Water conservation methods effects of 32 GP Minimise the abstracted volume, as far as practicable. O Ongoing included in Water Management WR2 surface water Plan; signed off by Environmental abstraction Officer Monitor either river stage or flow for the life of the mine to detect any Ongoing as specified in Records of monitoring results, 33 GP negative impacts to river flow. O monitoring programme and investigation of any negative impacts observed Scheduling of stream diversions only when required for pit infrastructure, As required during pit Water Management Plan 34 IH and reinstatement of natural stream drainage lines post-closure where C, O, D excavation indicating scheduling; signed off practicable. by Environmental Officer See measure 27 regarding relocation of affected villages. Implement erosion control measures listed in LT4 Minimise Design surface water diversion channels to mimic the natural instream Construction of Construction signed off by effects on 35 MM habitat as closely as possible, and rehabilitate using indigenous DD, C infrastructure appropriately qualified engineer instream vegetation.  WR3 ecology 36 MM Include key instream habitat features, such as deeper pools, to maintain DD, C During construction Construction signed off by resulting from fish populations during the dry season in stream diversion channels. Environment Officer stream See measure 22 on routing of roads etc to avoid drainage lines diversion Use semi-permeable materials where possible in preference to Detailed design and Design signed off by appropriately 37 GP impermeable materials for surfaces such as roads and paving. DD, C construction qualified engineer As specified in Monthly average flow for each river should be measured for at least a year, monitoring programme, 38 GP and used to determine impacts during non-peak river flow. DD, C with preliminary Monitoring data; evaluation report evaluation after one year Implement erosion / sedimentation control measures listed in Impacts LT4 Minimise flood and WR7 in and around diversion channels. risk to local Include flood risk in the Emergency Response and Preparedness Plan Evidence of awareness WR4 communities 39 GP (ER&PP) and raise awareness with potential affected communities of the C, O Ongoing campaigns in local communities; arising from risks and what to do in the event of a flood. inclusion in ER&PP surface water Update the preliminary Water Management Plan. diversions 40 GP DD Prior to construction Updated plan in place U3823_Marampa_ESIS_Final.docx September 2012 Page F6 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase 41 IH Fit the TSF with an under-drainage system to collect any seepage and DD, C Design and Construction signed off by Minimise return it to the processing area construction of TSF appropriately qualified engineer deterioration of 42 IH Groundwater quality and quantities around the TSF will be monitored O, D, C As outlined in Boreholes in place; monitoring groundwater frequently monitoring programme data WR5 quality as a Have the design and operation of the TSF inspected by a qualified result of 43 IH geotechnical engineer at least once per year. O At least once a year Inspection reports seepage from mine wastes 44 GP Undertake further geochemical characterisation of expected waste rock and DD Prior to construction Characterisation data available; tailings material to confirm preliminary findings. revised designs if necessary 45 IH Minimise release of storm water from the site by designing and constructing DD, C Design and Construction signed off by storm water settlement ponds in accordance with Project design criteria. construction of ponds qualified engineer 46 IH Place bunding around the perimeter of the pit to prevent natural surface DD, C Prior to construction Construction signed off by drainage entering the pit. qualified engineer 47 IH Design the TSF such that upslope catchment areas will be small DD Prior to construction Design signed off by qualified engineer Treat sewage effluent from the construction camp, accommodation camp Sewage treatment facilities in 48 IH and office/admin area at the beneficiation plant using containerised sewage C, O Ongoing place; maintenance records; treatment plants monitoring data 49 IH Construct drainage channels around the waste dump areas and through the C Construction Construction signed off by waste dump slopes, to direct the surface water flow to the settlement ponds. appropriately qualified engineer 50 IH Dispose of oils and other hazardous materials in accordance with the Waste C, O Ongoing Records of waste disposal Management Plan. Minimise Store hazardous materials in a suitably bunded area with an impermeable Construction signed off by WR6 discharge to 51 IH surface, with the size of containment being at least 110% of the contents of C, O Ongoing qualified engineer; visual surface water the largest tank within the facility, or provide facilities to direct excess inspections during operation volume to an alternative spill containment facility. 52 IH Design, construct and operate the TSF to remain stable with no DD, C, Ongoing Visual inspections; No pollution uncontrolled discharges. O incidents reported Store mine site fuel in above ground steel tanks in a bunded facility at the DD, C, Design, construction Construction signed off by 53 IH beneficiation plant. The tanks will be designed to international standards. O and operation of qualified engineer; visual storage tanks inspections during operation Plan and implement a comprehensive erosion control programme, including erosion and dust control measures listed in Impacts LT4 and AQ1. Use sedimentation control techniques such as installation of straw bales DD, C, Prior to clearing of Visual inspection; monitoring data 54 MM buffers in drainage lines downstream of potential sources of increased O, D vegetation and ongoing of watercourses sediment load. Plan produced and implemented; 55 MM Implement a Water Management Plan for the site. O, D Ongoing no stormwater management issues reported U3823_Marampa_ESIS_Final.docx September 2012 Page F7 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase Implement a comprehensive Rehabilitation and Closure Plan, which Initiated during Signed off by environmental 56 MM includes rehabilitation of the backfilled pits, WRD and TSF to prevent post- D, PC decommissioning and officer; site rehabilitated and closure discharge, and revegetation to ensure continued erosion control. ongoing until complete returned to communities for use 57 MM Where practicable, separate clean and “dirty” (i.e. with elevated levels of C, O During construction Visual inspection; monitoring data contaminants) stormwater and handle to two categories differently. of watercourses 58 MM Ensure clean water is piped to the outlet point and not allowed to flow freely C, O Ongoing Visual inspection of release points where it may cause erosion. 59 GP Avoid construction activities in the Bankasoka River catchment area DD, C Design and during Signed off by environmental (northern portion of the TSF area), which is ecologically sensitive construction of TSF officer Implement a water quality monitoring programme (continuing post-closure) O, D, As per monitoring Monitoring programme; 60 GP to detect changes to surface water quality and take the required PC programme monitoring data remediatory actions. 61 GP Implement a surface water biomonitoring programme (as per the specialist O As per monitoring Monitoring programme; recommendations) to monitor effects on aquatic ecosystems. programme monitoring data Implement a Spill Management Plan, which includes preventive measures Plan in place; no spill incidents 62 GP such as secondary containment of pipelines crossing water courses and C, O, D Ongoing reported bunding of hazardous liquids stored on site. Where possible adjust positioning of project infrastructure during planning to Evidence of exploring other 63 MM avoid gallery forest and wetland habitats. DD Prior to construction options when forest or wetland Minimise loss areas are to be impacted EB1 of habitat and Clear vegetation in phases working progressively in one direction so that During clearing of Evidenced by schedule for individuals due 64 MM fauna have an opportunity to move to adjacent areas. C vegetation vegetation clearing to site clearing Stockpile topsoil as per the recommendations listed in Impact LT4, for use during rehabilitation. Completed alien plant control 65 MM Implement an alien plant control management programme, including C, O, D Ongoing management programme and training of personnel to implement the programme. evidence of training and implementation. Minimise Implement rehabilitation as soon as possible, and monitor rehabilitated Evidence of progressive spread of 66 MM areas for growth of invasive species. C, O, D Ongoing rehabilitation; no invasive alien EB2 invasive plants in rehabilitated areas species Implement good practice measures listed in Impact LT1 to minimise the resulting from disturbed area. soil disturbance Implement erosion control measures as listed in Impact LT4. Remove invasive alien plants before they bear seed and dispose of No evidence of alien invasive 67 MM removed plants appropriately. C, O, D Ongoing plants in development footprint U3823_Marampa_ESIS_Final.docx September 2012 Page F8 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase Develop and implement a Wildlife and Habitat Management Plan that: • protects gallery and swamp forest areas from disturbance (see Figure 5.12); Minimise • provides awareness training to staff and contractors on: prevention of disturbance injury of animals; identification of likely species found on site (and those and of conservation concern); identifications of animal hazards (such as Develop during EB3 displacement of 68 GP venomous snakes); and what to do if dangerous animals are C, O, D construction with at Plan in place with evidence of wildlife due to encountered; least annual review implementation and review Project • requires personnel to report kills of species of conservation concern to activities the mine’s Environment Management team, who may investigate the incident; • encourages personnel to report sightings of wildlife of conservation importance to the mine’s Environment Management team; and • allows for the monitoring and, if necessary, eradication of any invasive species occurring on site or in surrounding disturbed areas. Plan developed prior to Completed waste management 69 MM Develop and implement a waste management plan that accommodates all C, O, D construction and plan and evidence of waste types produced on site, particularly food waste. implemented through implementation; no unmanaged to closure waste on site Avoid creating Manage the landfill site in accordance with good practice standards, Reflected in waste management an attractive 70 MM including access control and fencing. O Ongoing plan; no complaints or issues nuisance, relating to the landfill EB4 resulting in Monitor the incidence of drowning in water storage facilities and implement Records of monitoring and impacts on 71 MM preventive measures if required. O Ongoing preventive measures if required indigenous ecosystems If required, a pest control programme should be implemented, and should Monitoring programme for include monitoring of accidental death of non-pest species. Should the use accidental deaths of non-pest 72 MM of rodent control measures be required, the use of natural predators eg C, O, D Ongoing species if required; documented raptors should be considered, and pesticides that bio-accumulate should be pest control programme in place avoided. U3823_Marampa_ESIS_Final.docx September 2012 Page F9 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Table F2: Management programme to address identified social impacts Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase 1 IH Focus recruitment of semi-skilled and unskilled labour to residents of local C, O During recruitment Local content targets met communities. 2 EM Develop a local employment strategy giving preference to local candidates, DD Prior to recruitment Completed Recruitment Plan provided they meet the required eligibility criteria. Definition of local; 3 EM Develop a fair and transparent local recruitment plan DD Prior to recruitment Recruitment Plan; records of engagement with local community Records of tender evaluation 4 EM Require contractors (by means of their contract) to give preference to local C, O, D At tender stage and showing consideration of local employees, provided they meet the required eligibility criteria. ongoing content; Contracts showing Maximise relevant clauses ED1 employment 5 EM Organise training for workers on management of household incomes. O Ongoing Training material and registers benefits to local Evidence of implementation of communities 6 EM Develop a programme for gradual ‘indigenisation’ of the workforce. This O Prior to recruitment the programme and records of includes a general and technical skills training programme. “indigenisation” success. Develop and implement a construction and operational phase stakeholder Prior to construction Completed SEP; records of 7 EM engagement plan (SEP). As part of this SEP document disclose the DD, C, and ongoing through disclosure of recruitment recruitment process to manage community expectations (also related to O to closure process to community Impact SO2). Give preference to people directly affected by land acquisition to reduce the During recruitment of Evidence in tender and 8 GP magnitude of impacts described in Section 8.2. C, O employees and contract documentation; local suppliers employment targets met Develop a programme of training prior to project start up to maximise potential Prior to construction Training programme; 9 GP for local employment. DD, C and operation evidence of training implemented 10 EM Prepare and implement a training and skills development plan for ongoing DD, C, Ongoing Completed plan; Records of Maximise the skills development of the Project workforce including contractors’ personnel. O training / skills development potential for Records of training employee 11 EM Support a ‘vocational training programme’ to assist local people to qualify for C, O Ongoing programme; monitoring of ED2 training and semi-skilled positions. success in achieving skills qualifications and positions development in 12 EM Encourage workers to introduce the learned skills and practices in their C, O Ongoing Include practical examples in the local homes training material. community Continue technical and financial support to educational institutions and 13 GP students. O, D Ongoing Records of support provided. U3823_Marampa_ESIS_Final.docx September 2012 Page F10 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase Encourage 14 GP Disclose information on Project’s payment to government to the local C, O Ongoing Records of disclosure to local government communities and other interested stakeholders as part of the SEP. communities investment in ED3 areas local to Liaise with government to promote the use of revenue from the Project in the DD, C, Records of consultation with the Project to 15 GP Project’s area of influence for local development. O, D Ongoing government maximise their benefit Identify the types of goods and services required and those that can be DD, C, Regular updates Regularly updated database 16 EM sourced from within Sierra Leone. O throughout Project of local suppliers and service providers Maximise Documented procurement opportunities 17 EM Develop a procurement programme to maximise the use of local suppliers. DD Prior to procurement programme with targets for ED4 for local use of local suppliers suppliers and contractors Functional database with 18 GP Develop a supplier and contractor database, along with a process to review, DD, C, Ongoing regular updates; records of monitor and strengthen capabilities of local suppliers and contractors. O performance review and monitoring Records of housing and other Provide relocated households and communities with housing and social infrastructure lost and that 19 IH infrastructure to equal if not better that lost, as per the RAP. DD During relocation provided; records of consultation with relocated communities Prepare a Resettlement Action Plan (RAP) in agreement with affected population, the Paramount Chief and key government and non-government stakeholders as per the RF (Appendix D). The plan should provide details of: • affected people; Completed RAP; records of Minimise 20 MM • entitlements (cash or preferably in the form of replacement land for long DD Prior to relocation or consultations with local impoverishment term sustainability of livelihoods); land acquisition communities and other RL1 of local • cash compensation for loss of any standing crops, plantations and trees; stakeholders communities • assistance for redevelopment of farms and plantations on new land; through loss of • provision of improved replacement residential and community structures land and as per the preference of local communities. resources Records of consultation with Build alternative access routes in consultation with users of affected routes During construction, local communities; map 21 MM (see also Impact LT2). C prior to disruption of showing affected routes and access alternatives created 22 MM Undertake a community development programme for people facing loss of DD Prior to resettlement Completed plan; evidence of livelihood opportunities. and land acquisition implementation Iteratively consult with affected people to identify and resolve their issues in a DD, C, Grievance Mechanism in 23 MM timely manner. O, D Ongoing place; records of consultation with affected communities U3823_Marampa_ESIS_Final.docx September 2012 Page F11 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase Implement a grievance mechanism for identification of resettlement related Grievance Mechanism with 24 MM issues and address them in a timely manner. C, O, D Ongoing record of any complaints and how they were addressed Undertake post resettlement monitoring of affected parties to timeously detect Records of post-resettlement 25 MM issues and take action if necessary. C, O Ongoing monitoring and actions taken if required Records of directly affected 26 GP Preferentially employ eligible members from directly affected families. C, O, D During recruitment families, showing employment status Implement measures under Impact RL1. Facilities and roads will be unfenced except for the beneficiation plant and Design and construction 27 IH accommodation camp, allowing a degree of access by communities. O Ongoing signed off by appropriately qualified engineer Allow use of haul roads and other mine roads by communities, if safety Visual inspection and records 28 IH permits O Ongoing of accidents reported along haul roads After discussion with Provide safe crossing points across or around mine infrastructure where communities No community complaints or Minimise 29 MM existing tracks are affected. DD, C regarding access road safety incidents RL2 vulnerability of routes and prior to communities construction Liaise with the affected communities to determine alternate routes around Prior to construction Record of meetings with 30 MM mine area that cannot be crossed. DD, C and stage 2 agreed route alignments on expansion map 31 MM Maintain the selected bypass roads in the vicinity of the mine operations for C, O, D Ongoing No community complaints or the duration of the life of the operation. road safety incidents Prior to Records of meetings with 32 MM At closure, liaise with communities to determine if previous routes should be O, D decommissioning, communities; maps showing restored. when developing final routes to be restored closure plan U3823_Marampa_ESIS_Final.docx September 2012 Page F12 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase Encourage local recruitment and procurement as per measures for Impact ED1 and ED4. Maintain Encourage local communities to use the grievance procedure (measure 24)for Records of consultation with standard of 33 MM resolving their concerns. C, O, D Ongoing local communities on use of living of local the Grievance Procedure SO1 communities Plan in place with records of affected by in- implementation including migration 34 GP Facilitate joint planning with other industries, local government, Paramount DD, C, Ongoing records of communication/ Chief and other stakeholders to minimise speculative migration. O information sharing. Monitoring of speculative migration 35 MM Undertake awareness and educational campaigns (directly or through existing DD, C, Ongoing Records of campaigns and institutions) for prevention of social ills. O monitoring of success Prevent 36 MM Provide employees and visitors to the site with cultural awareness training. C, O On arriving at site Training material; records of Project-related training attendance SO2 increase in Needs assessment to social ills / 37 MM Provide assistance to the local health department (and NGOs) to strengthen DD, C, Ongoing determine priority areas; problems programmes for control of communicable diseases. O records of assistance provided Implement the management measures given under Impact SO1. DD, C, Evidenced by Recruitment 38 MM Maintain transparency in the recruitment process. O, D Ongoing Policy; Records of disclosure to local communities Minimise social 39 MM Maintain regular communication with local communities and other DD, C, As per SEP Records of communication discord due to stakeholders to minimise tensions. O, D SO3 perceptions of Functional grievance unfair Maintain and monitor the grievance mechanism for timely resolution of DD, C, mechanism with records of distribution of 40 MM community grievances. O, D Ongoing grievances raised and Project benefits resolved Implement measures under Impacts SO1, ED1 and ED4 to minimise population influx. Minimise loss Implement measures in Impact RL1 regarding protection of natural resources. of community Records of stories recorded AC1 access to 41 MM Record mythological stories associated with specific sacred sites as part of DD, C Ongoing made available to cultural their relocation. communities resources U3823_Marampa_ESIS_Final.docx September 2012 Page F13 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase Social impact assessment 42 MM Conduct an independent social impact assessment prior to closure. O Prior to closure including recommendations for mitigation of impacts Develop a social closure plan including the following: Prior to closure, after Completed Social Closure 43 MM • design and implement a retrenchment policy and strategy in consultation O conducting an Plan, based on findings of with workers and other stakeholders; and independent social social impact assessment • plan for post-project sustainability of community development activities. impact assessment Minimise Prior to closure, after Approved budget allocation economic 44 MM Allocate funds (in advance) for implementation of the social closure plan. O development of social for implementation of social DC1 decline closure plan closure plan following Re-train workers for increasing their chances for re-employment elsewhere Prior to closure, as closure 45 MM after Project closure. O, D production tails off Records of training 46 MM Conduct stakeholder consultations on closure issues as part of the ongoing O, D Ongoing Records of consultations stakeholder engagement process. Programme offering business 47 GP Promote and support building the capacity of local suppliers to diversify their O, D Prior to closure development advice to customer base and move beyond the Project area. suppliers affected by mine closure U3823_Marampa_ESIS_Final.docx September 2012 Page F14 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Table F2: Management programme to address identified health, safety and security impacts Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase 1 IH Maintain a pond on the TSF to minimise dust O Ongoing Visual inspection of pond levels; no dust from the TSF Relocate villages close to mine infrastructure (where ambient dust levels are Villages identified relocated in 2 IH predicted to be above guideline levels) (refer also to RL1 in Table F1) DD Prior to construction accordance with RAP; Post RAP audit Visual inspection of dust 3 IH Use water sprays to control dust. C, O, D Ongoing levels; monitoring data complies with standards MM Refer to the erosion control measures listed under Impact LT4. 4 MM Maintain or reduce vehicle speeds on unpaved roads to 40 km/hr, especially C, O Ongoing Visual inspection; random on roads passing near villages. speed checks Implement dust suppression measures in sensitive areas, such as wetting, Ongoing, especially Visual inspection; monitoring Minimise the 5 MM use of chemical dust suppressant and / or paving on roads with high vehicular C, O, D during dry season data complies with standards generation of activity (for example, haul roads). AQ1 dust from the Control dust emissions on ore stockpiles through use of water spraying and/ Ongoing, especially Visual inspection; monitoring construction 6 MM or wind breaks. O during dry season data complies with standards and operation of the mine Use dust suppression measures such as rock cladding or grassing, on the Once TSF has been Visual inspection; monitoring 7 MM side walls of the TSF and other exposed built up areas. C, O built and during any data complies with standards subsequent alterations 8 MM Minimise the dry beach area of the TSF and wet the TSF surface if monitoring O Ongoing Visual inspection; monitoring results indicate dust generation from this source. data complies with standards 9 MM Minimize lengths of access roads and eliminate unnecessary traffic. DD, C, During detailed design Maps showing road O, D and ongoing alignments; visual inspection 10 GP Investigate and respond to any air quality complaints picked up by the C, O, D Ongoing Records of complaints and Grievance Mechanism. how they are addressed. Provide site workers with appropriate Personal Protective Equipment (PPE), Reflect in Health and Safety 11 GP and implement standard international occupational health and safety C, O, D Ongoing Policy and all necessary PPE procedures. provided and used 12 GP Limit vehicle idling and keep vehicles well maintained. C, O Ongoing Vehicle maintenance log 13 IH Conduct blasting in accordance with international good practice standards, by C, O Ongoing Blasting procedures in place Minimise trained personnel disturbance of 14 IH Relocate villages close to mine pits (where air overpressure and vibration DD Prior to construction Villages identified relocated NV1 local levels are predicted to be above guideline levels)(see also RL1 in Table F2) communities 15 GP Re-assess impacts once detail regarding blasting regime is available. DD Prior to blasting Evidence of re-assessment due to blasting Monitor initial blasting to ensure compliance with specified air overpressure On commencement of Records of monitoring and 16 GP and vibration criteria. C blasting regime compliance with criteria U3823_Marampa_ESIS_Final.docx September 2012 Page F15 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase 17 GP Schedule blasting outside of hours when people are most disturbed by noise C, O Ongoing Blasting schedule; no (such as at night). complaints in this regard 18 GP Inform local communities of blasting timetable in advance and provide C, O Prior to blasting Records of informing adequate notice of when blasts are required outside of the planned schedule. communities 19 GP Maintain records of each blast (including location of blast holes, design, C, O For each blast Records kept measured overpressure and vibration) Provide hearing protection for operators to comply with health and safety Protective equipment 20 IH guidelines. C, O, D Ongoing available and staff know how to use 21 IH Relocate villages close to mine infrastructure (where ambient noise levels are DD Prior to construction Villages identified relocated predicted to be above guideline levels) (see also RL1 in Table F2) 22 GP Maintain vehicles and equipment in accordance with manufacturer’s C, O, D Ongoing Maintenance / servicing log; instructions to minimise noise. no faulty equipment 23 GP Avoid unnecessary revving of engines and switch off equipment when it is not C, O, D Ongoing No community complaints required. 24 GP Start up vehicles and plant sequentially rather than simultaneously. O Ongoing No community complaints 25 GP Fit vehicles with broadband reversing alarms. C, O, D Prior to bringing Auditory inspection Minimise vehicle on site increase in Undertake standardised noise measurements on major items of equipment When equipment NV2 background 26 GP upon delivery to provide a noise reference against which regular checks can C, O arrives at site and at Log of measurements noise levels be compared. regular intervals due to the thereafter Project When plant equipment is due for replacement, the replacement equipment During sourcing of Records of sound power level 27 GP should have a sound power level equal to or less than the plant that it is C, O replacement of old and replacement replacing. equipment equipment 28 GP Plan for operating times of noisy activities to be outside of hours when people C, O, D Ongoing Schedule for noise generating are most disturbed by increased noise levels (such as at night). activities; no noise complaints 29 GP Promptly investigate and respond to any noise complaints picked up by the C, O, D Ongoing Records of complaints and Grievance Mechanism. how they are addressed 30 GP Routine noise monitoring should be carried out at the surrounding receptors C, O On an annual basis Records of monitoring When constructing Design of haul roads; road 31 GP Keep haul routes well maintained and avoid steep gradients. C, O haul roads; ongoing maintenance schedule maintenance 32 GP Minimize the drop height for materials. C, O, D Ongoing Visual inspection U3823_Marampa_ESIS_Final.docx September 2012 Page F16 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase Underpasses will be constructed where the haul roads cross the Makeni Design and Design drawings; visual 33 IH highway to avoid intersecting with the highway DD, C construction of haul inspection roads Signs erected during 34 MM Appropriately sign-post the site entrance and access to the Makeni highway. C, O construction and Visual inspection maintained through to closure 35 MM Design site roads to a standard suitable for mine and construction traffic, and DD, C, Design of roads; Signed off by suitably qualified Minimise maintain the roads to this standard. O ongoing maintenance engineer. project-related Assess the condition of local roads and their capacity to accommodate the Detailed design of Assessed by suitably qualified TS1 safety risks to 36 MM mine-specific traffic and if necessary upgrade the roads prior to mine DD roads engineer. other road construction users Consultation prior to Records of consultation in this 37 MM In conjunction with the Government of Sierra Leone, devise and implement a DD, C, construction; ongoing regard and documented road road maintenance programme for roads affected by the Project. O implementation maintenance programme and schedule 38 GP Design and implement sheeting and correct positioning and securing of loads C, O, D Ongoing Signed off by qualified Health on vehicles in line with international health and safety procedures. and Safety officer 39 GP Control delivery of oversize loads to site during times of minimal highway C, O, D Ongoing Schedule for deliveries of traffic as far as possible, and minimise travel outside daylight hours. oversize loads 40 GP Minimise travel by heavy vehicles during heavy rains. C, O, D Ongoing Records of travel times Refer to measure 8 (LT2) in Table F1 Training and disciplinary 41 MM Enforce speed limits and safe diving practice. C, O, D Ongoing procedures; random speed Minimise checks safety risks to Records of community TS2 local 42 MM Educate local communities on traffic safety. C, O, D Ongoing awareness programme on communities traffic safety using mine site roads Refer to measure 6 above (Table F3) on dust suppression Consider providing and maintaining access paths alongside roads for key DD, C, Design of roads; Maps showing road and 43 MM access areas. O ongoing maintenance access path layouts; maintenance schedule Minimise risk Provide training to MIOL security staff and local police on the Voluntary DD, C, On recruiting security Records of training provided; of human 44 MM Principles on Security and Human Rights. O staff and prior to no community complaints in rights abuses relocation of villages this regard SR1 due to conflict Grievance procedure in place; with 45 MM Maintain the grievance procedure, and encourage and facilitate stakeholders C, O, D Ongoing records of informing communities to use the mechanism to express concerns. stakeholders on use of the procedure U3823_Marampa_ESIS_Final.docx September 2012 Page F17 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase Prior to Clinic operational; records 46 IH Establish a clinic for mine employees to address health concerns C commencement of kept of visits and diagnoses operation Develop and implement management policies for HIV/AIDS, tuberculosis and Prior to recruitment of HIV/AIDS Management policy 49 MM other potential communicable diseases focusing on prevention, control, DD staff for construction in place diagnosis and treatment in coordination with NGOs and local government. or operation Minimise risk Documented health SR2 of exposure to Provide health awareness programmes and counselling services to awareness programme; communicable 50 MM employees. O Ongoing counselling service diseases operational 51 MM Promote use and availability of condoms at the workers camp. C, O Ongoing Condoms available; records of awareness of use of condoms Undertake routine health screening of employees to detect and treat diseases On recruitment and Records of health screening 52 MM early. C, O annual screening and treatment provided if thereafter necessary Conduct blasting using standard mining industry practices and procedures. Minimise risk This includes the development and implementation of standard operating Procedure in place Blasting procedure and safety OH1 of injury from 53 IH procedures, blasting rules and a safety management plan that: C, O prior to blasting and management plan; signed off blasting • Delineates the danger zone associated with each blast of at least 400m implemented prior to by qualified Health and Safety and clear workers from this zone before, during and after each blast; and each blast officer • Provides an audible warning at least three minutes before a blast is fired. Refer to mitigation measures listed under Impact EB4 for management of the landfill site Design hazardous material containment structures taking into consideration Design of hazardous Signed off by appropriately 54 GP natural hazards and the implications of these on structural integrity of the DD liquid storage areas qualified engineer containment facilities. Size containment areas to contain 110% of the contents of the largest tank Design of hazardous Signed off by appropriately Minimise risk 55 GP within the facility or provide facilities to direct excess volume to an alternative DD liquid storage areas qualified engineer of community spill containment facility. OH2 exposure to Pave (with an impermeable surface such as concrete) mine site fuel delivery Design of fuel storage Signed off by appropriately toxic or 56 GP and dispensing pump areas and design these areas to drain into the adjacent DD areas qualified engineer hazardous storage tank containment areas. substances Prohibit construction of hazardous material facilities (including temporary and 57 GP permanent refuelling areas) within drainage lines or the 1 on 100 year flood DD Design of such Signed off by appropriately lines of watercourses. facilities qualified engineer Treat (for example with an oil separator), evaporate or dispose of as a Records of appropriate 58 GP hazardous material any polluted water collected in hazardous material C, O, D Ongoing treatment and disposal of containment facilities. polluted water U3823_Marampa_ESIS_Final.docx September 2012 Page F18 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Impact Objective Ref Type Management measure Proj. Timing Achievement criteria Ref. no. Phase Designated workshop for Require vehicle maintenance to be undertaken in the designated workshops vehicle maintenance; visual 59 GP where appropriate pollution control measures are provided to prevent leaks or C, O, D Ongoing inspection of pollution control spills of fuel or lubricants reaching the environment. measures and signed off by environmental officer Develop plan prior to Spill prevention system; 60 GP Develop and implement a spill prevention and control system as part of the C, O, D construction, and appropriate management of Emergency Preparedness and Response Plan for the mine site implement on an spills ongoing basis Make fire extinguishers available at storage areas for flammable substances, Installed prior to Signed off by qualified Health 61 IH and install a fire water system servicing the beneficiation plant and C, O operation and in use and Safety officer accommodation areas. through operation Minimise risk 62 IH Follow standard international good practice with regard to storage and C, O Ongoing Signed off by qualified Health OH3 of fire or handling of combustible materials. and Safety officer explosions PPE provided and used when 63 IH Adhere to occupational health and safety guidelines with regard to safe C, O, D Ongoing required; signed off by working conditions and the use of PPE. qualified Health and Safety officer OH4 Minimise risk 64 IH Design TSF to be appropriate for the seismicity of the area and in accordance DD Design of TSF Signed off by appropriately of TSF failure with international good practice qualified engineer U3823_Marampa_ESIS_Final.docx September 2012 Page F19 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Table F4: General management controls representing good practice Objective Ref Management measure Proj. Timing Achievement criteria no. Phase Provide spill prevention and response training to staff , contractors and visitors, including: 1 • an explanation of good house-keeping practices; C, O, On arrival at Training/induction logs • identification and use of equipment and engineering controls designed to prevent spills; DC Project sites • description of proper spill response procedures; and • indication of possible health, safety and environmental risks potentially occurring as a result of a spill. Spill In association with the incident reporting requirements (Section 11.3.2), record and report information on prevention spills including: and • location of spill; management • material type (hazard potential) and quantity released; 2 • quantity of material recovered; C, O, When spills occur Records of spills showing • media affected (soils, water, air); DC lessons learnt • actions taken to contain, recover and remove material released; • methods and location of disposal of recovered material or affected media (refer to waste management plan); • cause of the spill; and • how future spills could be avoided. Develop and implement a Hazardous Material Management Plan including procedures for transport, handling and storage of hazardous substances to minimise risk of accidental exposure. Hazardous materials include explosives, fuel, lubricants, laboratory chemicals, hazardous waste etc. The plan will: When • include clear instructions on what to do should exposure occur; C, O, transporting, Plan in place, with Hazardous 3 • prohibit construction of hazardous material facilities including temporary and permanent refuelling areas DC handling or storing evidence of implementation material within drainages or the expected flood zones of ephemeral watercourses; hazardous management • require that any polluted water collected in hazardous material containment facilities is treated, materials evaporated or dispose d of as a hazardous material; • require vehicle maintenance be performed in designated workshops where appropriate pollution control measures are provided. 4 Design mine waste, concentrate and hazardous material containment facilities with consideration of natural DD During detailed Record of design hazards. design considerations U3823_Marampa_ESIS_Final.docx September 2012 Page F20 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Objective Ref Management measure Proj. Timing Achievement criteria no. Phase Prepare construction and operation waste management plans and implement these consistent with Sierra Leone regulations and international standards to the extent practicable. Include in the waste management plans the following: • a commitment to a waste hierarchy comprising a) waste avoidance, source reduction, prevention or minimisation; b) waste recovery for materials that can be re-used; c) waste treatment to avoid potential impacts to human health and the environment or to reduce the waste to a manageable volume; and d) safe and responsible waste disposal; • inventory of wastes identifying the source/s, characteristics and expected volumes; • waste segregation requirements; Developed during • location and type of waste collection points, which are conveniently located, have adequate capacity, are DD, C, detailed design Plan in place with evidence 13 frequently serviced and clearly labelled; O with at least of review • storage requirements; annual review • opportunities for source reduction, re-use or recycling; • targets for waste re-use, recycling and incineration; • opportunities to minimise bulk or render waste non-hazardous; • procedures for operating waste storage, treatment and disposal facilities; • labelling requirements for waste disposed of offsite; • method of tracking waste recovered, incinerated or disposed of to the site’s landfill; Prevent • method of tracking quantity, date, transporter and fate of waste disposed of offsite; Project waste • a contingency plan should waste disposal facilities be unavailable for a time; and causing harm • training requirements for waste management staff and other employees and contractors. to local 14 Recycle, compost or incinerate non-hazardous waste to the extent practicable. C, O Ongoing Records of waste recycled, communities composed or incinerated or ecological Preferably return hazardous waste to the associated supplier or transport to other appropriately licensed Records of waste returned systems 15 facilities off-site to the extent practicable and permitted. C, O, D Ongoing to supplier Provisionally store hazardous waste not transported off site in appropriate storage facilities on-site until their 16 final disposal is determined. Include a roofed enclosure over a concrete pad with a low concrete wall to C, O, D Ongoing Visual inspection provide containment to hold 110% of the volume of stored hazardous liquids. Also include a fenced open area of storage of empty containers. Restrict access to this area to qualified personnel only. 17 Provide an open air non-hazardous waste transfer site on a pad with containment. C Construction of Built according to design infrastructure Design and 18 Provide a 30 m peripheral buffer around the landfill area. DD, C construction of Built according to design waste facility Design and 19 Establish a tire dump close to the landfill and progressively cap as tires are deposited. DD, C construction of Built according to design waste facility Establish a bio-remediation area with graded base and perimeter embankment close to the landfill to treat Design and 20 soils contaminated with hydrocarbons. Determine if treated soil can be used as an interim cover at the DD, C construction of Built according to design landfill site. waste facility U3823_Marampa_ESIS_Final.docx September 2012 Page F21 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix F Objective Ref Management measure Proj. Timing Achievement criteria no. Phase Design and 21 Establish a solid and liquid waste incinerator at the mine site. DD, C construction of Built according to design waste facility 22 Dispose of sludge from the sewage treatment facilities to the landfill or use in rehabilitation if appropriate. C, O Ongoing Records of sludge disposed of Maintain sewage treatment facilities according to manufacturers’ specifications and Sierra Leone According to 23 requirements. C, O manufacturer’s Maintenance logs instructions 24 Fit cooking areas with grease traps, and maintain these, to prevent excess oils and fats reporting to the C Construction of Visual inspection sanitation facilities. infrastructure Developed during 25 Develop health and safety policy and plan to cover identified health and safety risks likely to occur during C, O detailed design Policy and plan in place construction, start up, operation, closure and rehabilitation phases of the project. with at least with evidence of review annual review 26 Systematically and continuously identify, assess and respond to health and safety risks throughout the C, O, D Ongoing Record of risk identification Project life cycle in accordance with the plan. and management Restrict the noise levels emitted from equipment or provide suitable personal protection devices if this limit Noise levels known and 27 cannot be achieved. C, O Ongoing equipment provided where Prevent or necessary minimise Systems in place and occupational 28 Provide fire protection systems to comply with the applicable national and international regulations. C, O Ongoing tested health and safety risks 29 Facilitate interaction between the health and safety and Environment teams. C, O Annual review Records of meetings between teams Provide personnel with appropriate personal protection equipment (PPE) if they are obliged to work in areas C, O, PPE available and staff 30 where occupation health and safety standards are exceeded. Provide staff and visitors with training on how DC Ongoing know how to use it and when to use the PPE. High hazard areas 31 Prevent access to areas with high hazard potential and clearly mark such areas with suitable warning signs C, O, Ongoing identified on a plan and showing written and visual representation of the hazard. DC, PC barriers in place with suitable warning signs U3823_Marampa_ESIS_Final.docx September 2012 Page F22 of F22 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix G APPENDIX G G PRELIMINARY ENVIRONMENTAL AND SOCIAL MONITORING PROGRAMMES U3823_Marampa_ESIS_Final.docx September 2012 Page G1 of G11 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix G Appendix G: Preliminary monitoring programmes ‘Project facilities’ refer to the different Project related installations. ‘Project area’ refers to the areas outside Project facilities but where Project personnel are likely to be working. Table G1: Preliminary environmental monitoring programme Aspect Impact Type of monitoring Units Frequency Location/s Records Internal reporting reference Monthly during Monthly report during LT1, LT4, Extent of footprint area disturbed and/or construction and then Within footprint of all construction and 2 Log rehabilitation EB1 rehabilitated m as needed when land disturbed areas, including disturbed or along pipelines and roads Annual report during rehabilitated operation Land LT1, LT4, Construction sites, Annual report (non- disturbance LT5, WR6, Visual inspections for signs of erosion or wind None Quarterly or on receipt rehabilitated areas, road/ Log conformances handled EC1 deposition of grievance pipeline culverts and water as per Section 11.3.2) release points Quarterly or on receipt Haul roads and any bypass Annual report (non- LT2 Visual inspection of road condition None of grievance roads developed around Log conformances handled project infrastructure as per Section 11.3.2) Volume and rate of water pumped from the Daily when pit Monthly report of max 3 WR1 pits (pump ratings can be used) m/d and L/s dewatering occurring Pit sump pumps Database and min rate and daily volume Groundwater levels in village wells within m below Continuously using Monitoring boreholes as Quarterly report of levels WR1, WR2 drawdown cone ground level transducers or monthly shown on Figure 1 Database and long term trends (mbgl) using dip meters 2 Cultivated wetland areas WR1, Cultivated wetland surface area and type of m and type Start and end of each downstream of mine Database Annual report WR2, WR3 crop grown of crop rainy season footprint areas Rate and volume of water abstracted from 3 Continuous during Monthly report of max Water WR2 Rokel River L/s and m /d abstraction Point of abstraction Database and min rate and daily volume Accommodation camp, beneficiation plant, power Monthly water balance Rate and volume of water used and recycled 3 plant, TSF, storm water Database WR2 at the mine site m/d and L/s Continuous ponds, water spray trucks showing daily/monthly and any other key water volumes off-take points Groundwater quality at the mine site and in ug/L, mg/L Quarterly for full New holes installed around Quarterly report of nearby communities for at least the following or other parameter suite, with the TSF, landfill and WR5 parameters(a): pH, Eh, TDS, alkalinity, units as field pH, EC and hazardous materials Database results and long term temperature, dissolved oxygen, nitrate, appropriate temperature collected storage areas; monitoring trends chloride, fluoride, sulfate, phosphate, Na, K, monthly when water boreholes shown on Figure U3823_Marampa_ESIS_Final.docx September 2012 Page G2 of G11 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix G Aspect Impact Type of monitoring Units Frequency Location/s Records Internal reporting reference Ca, Mg, Al, Cr, Fe, Mn, B, Cu, Zn, As, Se, Mo, levels recorded 1 (subject to review during V and U (U at the mine site only) construction) Surface water quality in water holding facilities Quarterly for full Storm water settlement for at least the following parameters(a): pH, Eh, ug/L, mg/L WR4, TDS, TSS, alkalinity, temperature, dissolved or other parameter suite, with ponds (following rain Quarterly report of WR5, EB3, oxygen, nitrate, chloride, fluoride, sulfate, units as monthly field pH, EC, events), tailings Database results and long term EB4 phosphate, Na, K, Ca, Mg, Al, Cr, Fe, Mn, B, appropriate DO, turbidity, TSS and supernatant pond, pit trends Cu, Zn, As, Se, Mo, V and U temperature sumps Flow rate and stage measurement for streams Monthly flow rate; daily Monitoring points shown on 3 WR3 in sub-catchments influenced by Project m/s and m stage data Figure 2 Database Quarterly report of flows infrastructure Stream water quality for at least the following Quarterly for full parameters(a): pH, Eh, TDS, TSS, alkalinity, ug/L, mg/L Surface water monitoring temperature, dissolved oxygen, nitrate, or other parameter suite, with points shown on Figure 1 Quarterly report of WR6 chloride, fluoride, sulfate, phosphate, Na, K, units as monthly field pH, EC, (subject to review during Database results and long term Ca, Mg, Al, Cr, Fe, Mn, B, Cu, Zn, As, Se, Mo, appropriate DO, turbidity, TSS and construction) trends V and U temperature Record upset conditions when storm water ug/L, mg/L settlement ponds are full and discharges or other When upset conditions Log and Annual report (non- WR4, WR6 occur. Sample the water released for the units as occur At the point of release database conformances handled same parameters as above. If possible, appropriate as per Section 11.3.3) record estimated volume of water released Inspection of storage facilities to determine Annual report (non- WR6 need for sediment removal None Quarterly Water holding facilities Log conformances handled as per Section 11.3.3) Weather conditions on site (wind, rainfall, Quarterly report of AQ1 temperatures) various Monthly Onsite weather station Database results and long term trends Bucket monitoring stations Quarterly report of 3 shown on Figure 3subject Database results and long term AQ1 Dust fallout over a monthly period µg/m Monthly to review during construction) trends Air and At monitoring stations Quarterly report of climate 3 shown on Figure 3 (subject Database results and long term AQ1 PM and PM (24 hour reading) µg/m Monthly 10 2.5 to review during trends construction) Monitoring stations as Ambient NO and SO 24-hour concentrations shown on Figure 3 (subject Quarterly report of 2 2 µg/m3 to review during Database results and long term AQ1 (using Radiello Badges) Quarterly construction) trends U3823_Marampa_ESIS_Final.docx September 2012 Page G3 of G11 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix G Aspect Impact Type of monitoring Units Frequency Location/s Records Internal reporting reference Date and When upset conditions Annual report (non- AQ1 Times and duration of upset conditions time occur HFO plant Log conformances handled as per Section 11.3.3) Air overpressure (from blasting) dBL Initial 3 blasts and on Closest villages or at Log Annual report NV1 receipt of complaint location of complainant Noise and Blasting-related vibrations (measured as Peak Mm/s Initial 3 blasts and on Closest villages or at Log Annual report vibrations Particle Velocity) receipt of complaint location of complainant NV2 Ambient noise levels over 24 hour period dB(A) Monthly or upon receipt As shown on Figure 3 or at Log Annual report (intermittent between weekday and weekend) of complaint location of complainant WR3, Category (A- Annually (dry season) WR5, WR6 Aquatic biomonitoring programme - diatoms F) during construction and As shown on Figure 4 Database Annual report operation WR3, Number of Annually (dry season) WR5, WR6 Aquatic biomonitoring programme - Fish species during construction and As shown on Figure 4 Database Annual report operation WR1, Spatial extent of wetland areas m2 Start and end of rainy Wetland areas downstream WR3, EB1 seasons of project areas Database Annual report Ecological EB2 Visual inspections of presence of invasive None Quarterly Disturbed and rehabilitated Log Annual report on findings plant species areas, and adjacent areas and remedial measures Records of wildlife kills by equipment, vehicles, Monthly report on EB3, EB4 drowning or poisoning None On occurrence Within Project areas Log fatalities and remedial measures EB3 Records of major wildlife sightings None On occurrence Within or near the Project Log Annual report on area observations EB4 Records of prevalence of nuisance animal None On occurrence Within or near the Project Log Annual report on species area observations AQ1, EB3, Once every two weeks Annual report (non- TS1, TS2 Random speed checks km/hr at different locations Access and haul roads Log conformances handled and times as per Section 11.3.3) Vehicles and Records of vehicle and equipment As per manufacturer’s Mine truck shop and equipment NV2 maintenance None instructions equipment workshop Log None NV2 Baseline noise emissions of new equipment dB On commissioning of Within 100m of equipment Log None new equipment 3 Records of hazardous materials acquired and m or kg of On arrival at site and Warehouse or storage General used each type of during construction/ facility Log Quarterly report Hazardous material operation materials Inspections of hazardous substances At least monthly for Hazardous material Annual report (non- General containment facilities, instrumentation and None containment facilities containment facilities Log conformances handled detection systems. with instrumentation as as per Section 11.3.3) U3823_Marampa_ESIS_Final.docx September 2012 Page G4 of G11 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix G Aspect Impact Type of monitoring Units Frequency Location/s Records Internal reporting reference per manufacturer’s instructions General Volume of different wastes types disposed of kg or tonnes Daily Waste disposal sites Log Quarterly report to landfill or removed to hazardous waste site Waste General Volume of different waste types recycled or kg or tonnes Daily Waste disposal sites Log Quarterly report reused General Volume of soil bio-remediated kg or tonnes When soil arrives at bio- Waste management site at Log Quarterly report remediation site mine U3823_Marampa_ESIS_Final.docx September 2012 Page G5 of G11 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix G Table G2: Socio economic monitoring programme Aspect Impact Type of monitoring Units Frequency Location/s Records Reporting reference Economic ED1, ED2, Source of employees (for MIOL and its Percentage of Ongoing throughout Project facilities Employee database Quarterly human development RL1, SO1, contractors) categorised by: employees in the life of the project for MIOL and for its resources report SO2, SO3, • skill level; each category contractors • whether they are local, provincial, national and/or international; • ethnicity • gender; • from a vulnerable group (for example disabled). ED1, SO1, Unemployment Percentage Yearly Lunsar and affected Government records; Yearly social SO2 villages Primary survey data performance report ED3 Government revenue used in areas Percentage Yearly Port Loko District Government revenue Yearly social affected by the Project and budget records performance report ED4, SO1, Origin of contractors and suppliers Percentage Quarterly Project facilities Contracts register Quarterly report from SO2, SO3 (Local, provincial, national and/or contractors/suppliers international) Resettlement RL1, RL2 Provision of improved replacement Percentage Quarterly Project affected Resettlement Quarterly community and loss of land housing, replacement farmland and villages monitoring reports relations report and social and access to natural resources natural RL2, RL3 Access to social infrastructure such as Percentage Yearly Project affected Resettlement Quarterly community resources schools, health centre, grain banks, villages monitoring reports relations report markets for selling and buying, credit facilities, religious centres, water supply and sanitation RL1 Restoration of livelihoods to the level Percentage Yearly Project affected Resettlement Quarterly community of pre-resettlement villages monitoring reports relations report RL1 Food security (post resettlement) Percentage Yearly Project affected Resettlement Quarterly community villages monitoring reports relations report RL2 Access to social support networks Percentage Yearly Project affected Resettlement Quarterly community villages monitoring reports relations report RL1, RL2, Initiatives for promotion of alternative Number and Quarterly Project affected Reports on initiatives; Quarterly community RL3, SO3 livelihoods (focus on affected people type of initiatives villages Meeting minutes relations report and vulnerable members) RL1, RL2, Community grievances or complaints Number and Monthly Project affected Grievance register; Monthly community RL3, SO1, type of villages Community meetings; relations report SO2, SO3, complaints Letters; Media reports AC1, DC1 U3823_Marampa_ESIS_Final.docx September 2012 Page G6 of G11 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix G Aspect Impact Type of monitoring Units Frequency Location/s Records Reporting reference Social order SO1, SO2 Population Population; Rate Every three to five Lunsar and affected Primary sample Yearly social of growth years villages survey; Government performance report statistics SO2, SR2 Prevalence of communicable Incidence of Quarterly Lunsar and affected Reports from health Quarterly social diseases: diseases villages centres; Employee performance report • STIs health screening • Tuberculosis and respiratory track records infections • Malaria • Diarrhoea SO2, SR2 Prevalence of crime Percentage Yearly Project affected Community meetings; Quarterly social increase villages Police records; media performance report reports SO2, SR2 Prevalence of commercial sex workers Percentage Yearly Project affected Community meetings; Yearly social increase villages Police records; media performance report reports SO2, SR2 Prevalence of alcohol and drug abuse Number of Yearly Project affected Community meetings; Yearly social incidences villages Police records; media performance report reports SO3 Disputes between residents of affected Number of Monthly Project affected Community meetings Monthly community villages and outsiders incidences villages records relations report Archaeology AC1 Relocation of sacred bushes and Percentage of Quarterly Project affected Community meetings Quarterly social and cultural cemeteries to the satisfaction of sacred bushes villages records performance report heritage affected people and cemeteries Decommis- DC1 Number of retrenched workers re- Percentage Quarterly (during Project affected Placement records • Employee sioning and employed in other mining projects or decommissioning villages newsletters; closure alternative occupations phase) • Yearly human resources report DC1 Persons provided with pre- Number of Quarterly (prior to and Project affected Training records Quarterly human retrenchment training and type of persons and during villages resources report training provided type of training decommissioning phase) U3823_Marampa_ESIS_Final.docx September 2012 Page G7 of G11 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix G Figure 1: Locations of surface water and groundwater monitoring points U3823_Marampa_ESIS_Final.docx September 2012 Page G8 of G11 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix G Figure 2: Locations of surface water flow gauging monitoring points U3823_Marampa_ESIS_Final.docx September 2012 Page G9 of G11 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix G Figure 3: Locations of air quality and noise monitoring points U3823_Marampa_ESIS_Final.docx September 2012 Page G10 of G11 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix G Figure 4: Locations of aquatic biomonitoring sampling sites U3823_Marampa_ESIS_Final.docx September 2012 Page G11 of G11 SRK Consulting Marampa Iron Ore Project ESIS – Technical Appendix Error! Reference source not found. APPENDIX H H MIOL POLICIES U3823_Marampa_ESIS_Final.docx September 2012 Page H1 of H1