DRAFT ENVIRONMENTAL AND SOCIAL IMPACT ... Ranobe Mine rpt English...1.1.1 DRAFT ENVIRONMENTAL AND...

1.1.1 DRAFT ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT

1.1.2 VOLUME 5: SYNTHESIS OF THE PROJECT, RESETTLEMENT AND COMPENSATION ACTION PLAN AND ENVIRONMENTAL

AND SOCIAL MANAGEMENT PLAN

Prepared for:

Prepared by:

World Titanium Resources Ltd Coastal & Environmental Services 15 Lovegrove Close,

Mount Claremont Western Australia, 6010

GRAHAMSTOWN P.O. Box 934,

Grahamstown, 6140

January 2014

Volume 5: January 2014

Coastal & Environmental Services Ranobe Mine Project ii

CES Report Revision and Tracking Schedule

Document Title

Draft Environmental and Social Impact Assessment Ranobe Mine Project, Southwest Region, Madagascar

Client Name & Address

World Titanium Resources 15 Lovegrove Close, Mount Claremont Western Australia, 6010

Document Reference

Status

Draft

Issue Date

October 2013

Lead Authors

Dr Chantel Bezuidenhout

Reviewer

Study Leader or Registered Environmental Assessment

Practitioner Approval

Report Distribution Circulated to No. of hard copies

No. electronic copies

Mahen Sookun 1

This document has been prepared in accordance with the scope of Coastal & Environmental Services (CES) appointment and contains intellectual property and proprietary information that is protected by copyright in favour of CES. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of Coastal & Environmental Services. This document is prepared exclusively for use by CES’s client. CES accepts no liability for any use of this document other than by its client and only for the purposes for which it was prepared. No person other than the client may copy (in whole or in part) use or rely on the contents of this document, without the prior written permission of CES. The document is subject to all confidentiality, copyright and trade secrets rules, intellectual property law and practices of South Africa.

Coastal & Environmental Services

Grahamstown 67 African Street

Grahamstown 6039

+27 46 622 2364/7 [email protected] www.cesnet.co.za

Also in East London

mailto:[email protected]

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Coastal & Environmental Services Ranobe Mine Project iii

TABLE OF CONTENTS 1. SYNTHESIS OF THE PROJECT ................................................................................... 1

1.1 Summary of the Proposed project ......................................................................... 1

1.2 Summary of Specialist Studies .............................................................................. 1

....................................................................................... 1 1.2.1 Air Quality Assessment

1.2.1.1 Mining Impacts ................................................................................................ 1

1.2.1.2 Transportation Impacts .................................................................................... 1

1.2.1.3 Port Impacts .................................................................................................... 1

................................................................................. 2 1.2.2 Botanical Specialist Report

............................................................................ 3 1.2.3 Economic Assessment Report

.............................................................................. 4 1.2.4 Faunal Baseline Assessment

1.2.4.1 Haul Road options ........................................................................................... 4

1.2.4.2 Mineral Separation Plant options ..................................................................... 5

..................................................... 6 1.2.5 Ichthyology and Aquatic Habitat Assessment

......................................................................... 7 1.2.6 Land and Natural Resource Use

........................................................ 7 1.2.7 Marine Ecology and Fisheries Assessment

........................................................................................ 8 1.2.8 Radiation Assessment

...................................................................... 10 1.2.9 Sediment Transport Assessment

.............................................................................. 10 1.2.10 Social Impact Assessment

.................................................................. 11 1.2.11 Specialist Study on Noise Impacts

1.2.11.1 Construction Activities ................................................................................. 11

1.2.11.2 Operational Activities ................................................................................... 12

.............................................................................. 12 1.2.12 Visual Impact Assessment

.............................................................. 13 1.2.13 Waste and Wastewater Assessment

......................................................................................... 14 1.2.14 Water Assessment

1.3 Rehabilitation and Biodiversity Offsets Programme .......................................... 27

1.4 The Way Forward .................................................................................................. 41

2. RESETTLEMENT AND COMPENSATION ACTION PLAN (PAR) .............................. 42

2.1 Introduction ........................................................................................................... 42

2.2 Objectives of the Phase 1 Resettlement Action Plan ......................................... 42

2.3 International Guidelines and Frameworks .......................................................... 43

2.4 Key Components of the Resettlement Action Plan ............................................ 45

................. 45 2.4.1 Project Description and Objectives of the Resettlement Action Plan

.............................................................. 45 2.4.2 Physical and Economic Displacement

.......................................................... 45 2.4.3 Legal Framework and Guiding Principles

.................................................................................. 46 2.4.4 Socio-Economic Context

..................................... 46 2.4.5 Consultation, Participation and Grievance Mechanism

.................................................................... 46 2.4.6 Eligibility Criteria and Entitlements


Coastal & Environmental Services Ranobe Mine Project iv

2.4.7 Determination and Negotiation of Entitlement and Compensation Framework ........................................................................................................................ 46 Process

.................................................. 47 2.4.8 Institutional Arrangements for Implementation

.......................................... 47 2.4.9 Measures to Reduce Spatial Resettlement Impacts

.................................................................. 47 2.4.10 Social Services and Infrastructure

................................................................... 48 2.4.11 Monitoring and Evaluation (M&E)

......................................................... 48 2.4.12 Implementation Schedules and Budgets

.................................................. 48 2.4.13 Moratorium and Interim Disputes Committee

......................... 49 2.4.14 Income Restoration and Sustainable Development Initiatives

............................................. 49 2.4.15 In-migration and Population Influx Management

2.5 RAP Roles and Responsibilities .......................................................................... 50

.......................................................................................................... 50 2.5.1 Overview

.................................................................................. 51 2.5.2 Pre-Implementation Role

......................................................................................... 51 2.5.3 Implementation Role

.................................................................. 52 2.5.4 Government of Madagascar (GoM)

2.6 Proposed Phase 1 RAP staffing requirements ................................................... 52

............................................. 53 2.6.1 Corporate Social Responsibility (CSR) Manager:

...................................................................................................... 53 2.6.2 CSR Mentor

........................................................................................ 53 2.6.3 Community Relations

......................................................................... 53 2.6.4 Compensation & Resettlement

....................................................................... 53 2.6.5 Benefits and Social Investments

............................................................. 53 2.6.6 Compliance Monitoring and Evaluation

2.7 Indicative RAP development schedule ................................................................ 54

2.8 Phase 2 Right of Way Compensation Plan .......................................................... 55

3. ENVIRONMENTAL MANAGEMENT PLAN ................................................................ 56

3.1 Environmental & Social Management Plans ....................................................... 56

3.2 Management Structure ......................................................................................... 57

....................................... 57 3.2.1 Toliara Sands Management Structure and Reporting

.............................................. 57 3.2.2 Toliara Sands – Construction Manager (TS-CM)

................................................. 57 3.2.3 Toliara Sands – Technical Managers (TS-TM)

3.2.4 Toliara Sands – Operational Environmental, Health, Safety and Community .................................................................................................... 57 Manager (TS-EHSC)

3.2.5 Engineering, Procurement, Construction Management Contractor (EPCM) Team ............................................................................................... 57 Structure and Reporting

....................................................................... 57 3.2.6 Construction Contractor’s Team

.................................................................... 58 3.2.7 Independent External Audit Team

3.3 Management Reporting Guidelines ..................................................................... 58

3.4 Specific Roles and Responsibilities .................................................................... 58

3.4.1 EPCM Contractor – Environmental, Health, Safety and Community Manager ............................................................................................................. 58 (EPCM-EHSC)

........................ 59 3.4.2 Construction Contractor – Environmental Site Officer (C-ESO)


Coastal & Environmental Services Ranobe Mine Project v

3.4.3 Toliara Sands – Environmental, Health, Safety and Community Manager (TS- ........................................................................................................................ 60 EHSC )

............................................. 61 3.4.4 Construction Contractor – Chief Engineer (C-CE)

3.5 Environment and Health Training and Awareness ............................................. 61

3.6 Performance Objectives and Targets .................................................................. 62

3.7 Compliance Management and Corrective Action ............................................... 63

3.8 Reporting and Review .......................................................................................... 63

3.9 Monitoring ............................................................................................................. 64

3.10 Emergency Preparedness .................................................................................. 65

3.11 Environmental Incident Management ................................................................ 65

3.12 Management Review ........................................................................................... 66

3.13 General Specifications........................................................................................ 66

................................................................................................. 66 3.13.1 Environmental

..................................................................... 66 3.13.2 Occupational Health and Safety

3.14 Preconstruction Environmental Specifications ................................................ 69

3.15 Construction Phase Specifications ................................................................... 76

3.16 Operational Phase Specifications .................................................................... 104

3.17 Closure Phase Specifications .......................................................................... 119

3.18 Implementing the Toliara Sands EMP .............................................................. 121

...................................................................................................... 121 3.18.1 Overview

........................................ 121 3.18.2 Step 1 - HSEC Environmental and Social policies

3.18.3 Step 2 - Planning for negative impact mitigation and positive impact ............................................................................................................. 121 enhancement

......................................................... 122 3.18.4 Step 3 - Implementation and operation

........................................................ 122 3.18.5 Step 4 - Checking and corrective action

........................................................................ 123 3.18.6 Step 5 - Management review

3.19 Community Engagement .................................................................................. 124

................................................................................................... 124 3.19.1 Introduction

.................................................................................. 124 3.19.2 Grievance Mechanism

3.20 Reporting ........................................................................................................... 125

.............................................................................. 125 3.20.1 Continuous Improvement

..................................................................................... 125 3.20.2 Auditing and Review

3.21 Performance Objectives and Targets .............................................................. 125


Coastal & Environmental Services Ranobe Mine Project 1

1. SYNTHESIS OF THE PROJECT 1.1 Summary of the Proposed project The Ranobe deposit is located north of the Port of Toliara in south-west Madagascar, where a large mineral sands resource containing the valuable heavy minerals ilmenite, rutile, zircon and leucoxene has been identified. The mineralised zone in the Ranobe Permit Area is around 16 km long and between 1 and 2 km wide. It comprises three mineralised sand units, which together contain approximately 1 200 to 1 400 million tonnes of sand at an average grade of 4 to 5% total heavy minerals (THM). The Ranobe Mine Project considers the development of 161 million tonnes of THM grading 8.2% over an intial 21 year mine life from one of the three mineralised sand units at Ranobe. The project envisages the development of a dry mine, primary processing plant, mineral separation plant, a road for transport of products to a port for export. 1.2 Summary of Specialist Studies

1.2.1 Air Quality Assessment The air pollution impacts of both gaseous and particulate emissions were investigated by AIRSHED1. Based on these impacts the following conclusions were drawn: 1.2.1.1 Mining Impacts The maximum predicted increase in PM10 (Thoracic Particulate Matter, used to measure dust emissions), NO2 (Nitrogen dioxide), DPM (Diesel Particulate Matter, used to measure diesel engine exhaust fumes) concentration and dust fallout is expected to be over the area being mined and directly over the main haul roads. The predicted impact zone was defined by areas where exceedances of the selected air quality standards, based on the results of mathematical models, are expected. The investigation concluded that PM10, dust fallout, NO2 and DPM are of potential concern if the mine and processing plant are not operated according to design controls (i.e. regular watering of mine haul roads to achieve 75% mitigation). The area of impact, if mitigated, would only be within the mine license area. 1.2.1.2 Transportation Impacts Due to the relatively low transportation requirements, the predicted impacts of gaseous (hourly maxima) and particulate (assessed as 24-hour averages) emissions were predicted to be relatively low when compared to the respective standards. Potential exceedances of air quality standards were predicted along the road itself only. 1.2.1.3 Port Impacts Due to the covered storage facilities at the port, low impacts were predicted for particulates (dust). Similarly, low gaseous emission impacts were predicted.

1 Airshed Planning Professionals (Pty) Ltd: Volume 6: Air Quality Assessment



Based on the conclusions drawn for the mining, transportation and port impacts listed above the following key recommendations were made by the air quality specialists:

The design controls (i.e. regular watering of mine haul roads to achieve 75% mitigation) must be implemented and maintained throughout the life of the mine.

Particulate and gaseous emissions controls as provided by the IFC (Section 4.5 of the air quality specialist report) be implemented.

Continuous emissions monitoring for particulates, sulphur dioxide and oxides of nitrogen be implemented on the dryer flue gas to ensure compliance with the IFC requirements (Section 4.5.1.2 of the air quality specialist report).

Based on predicted impacts and considering the prevalent wind direction recorded in the area, PM10 ambient monitoring is required to the west of the area of activity. The exact location would depend on the mine schedule.

PM10 measurement can be economically carried out by the use of “mini-vol” samplers (Section 9.3 of the air quality specialist report).

1.2.2 Botanical Specialist Report

Current land use has had a significant impact on the vegetation at a sub-regional scale, due largely to utilisation of the vegetation by the local people. Thus, the vegetation of the project area is currently degraded as a result of human-related impacts such as harvesting vegetation for charcoal production, removal of trees to build boats, burning to create new growth for the grazing of domestic cattle and clearing for agriculture. In addition to this, fire plays an important role in current land use for both agricultural clearing as well as for creating grazing for cattle. This has resulted in impacts of high or very high significance on loss of vegetation and on biodiversity, and significant disruptions to ecosystem processes has taken place. There are a few invasive plant species which are not currently a problem but have the potential to become seriously problematic. Where possible it is recommended that areas within the study site be set aside for conservation, thus allowing the vegetation to reach its natural state free from agricultural pressure and alien infestation. The clearing of vegetation within the mine path and for related infrastructure results in a number of impacts, most notably:

The loss of vegetation communities due to vegetation clearing. The significance of the loss is dependent on the distribution, structure, diversity and conservation of the specific communities that will be lost. A total of six plant communities will be impacted, and the significance of the impact after mitigation is moderate to low, but without mitigation impacts of high significance are expected.

A loss or reduction in biodiversity. Removal of the vegetation will result in the loss of existing populations of all plant species within the mine path, areas directly affected by infrastructure (e.g. the MSP) and the road. The area as a whole is exceptionally rich in plant species, especially in the thicket vegetation types that lie primarily outside the Ranobe Exploration Area. As a result these impacts have been rated as low after mitigation.

Impacts on species of concern. These impacts take place at a larger spatial scale for species that have a globally restricted range, or are otherwise in need of protection. The mining process and haul road construction may significantly reduce the area of occupancy of the species and a reduction of the area of occupancy may threaten the chances of survival for these plant species. Impacts have been assessed for three different groups of species, namely 19 Confirmed Species of Concern that definitely occur within the Ranobe Exploration Area; 24 Confirmed



Species of Concern that definitely occur within the project area; and 43 Possible Species of Concern. Impacts have been rated as being of moderate significance after mitigation for the mine area and haul road, but high before mitigation.

Disruption of Ecosystem Function and Process. Habitats are linked and form part of a functional ecosystem where biological and biophysical processes take place. Loss or modification of habitats causes disruption of ecosystem function and threatens the interplay of processes that ensure environmental health and the survival of individual species. Fragmentation is one of the most important impacts on vegetation, especially when this creates breaks in previously continuous vegetation, causing a reduction in the gene pool and other ecosystem processes. The mine will result in impacts on ecosystem disruption of low significance after mitigation, which is primarily the establishment of ecological corridors. However, the linear nature of the haul road results in significantly more ecosystem disruption, especially since options 1 & 2 are located at an ecotone (zone of transition) between the limestone forest and the vegetation types of the sandy plain. These impacts will therefore be high after mitigation.

The key recommendations are to:

1. Refine the overall conceptual rehabilitation plan for the mine site (shown in Figure 5-1 of the Rehabilitation and Offset Strategy Report). This plan provides an overview of the rehabilitation in the long term (the situation at closure of the mine), but may be modified as seen fit during the life of the mine.

2. Develop short-term rehabilitation plans to guide and direct the rehabilitation programme over the next 2 to 5 years. These should include strategies for propagating species for reintroduction to suitably restored areas, as well as the search and rescue of species of concern, as identified in this study.

3. Establish a Biodiversity Offset Strategy with input and support from local agencies. One option would be to assist with the protection of high value areas remaining in the PK32 protected area (see Rehabilitation and Offset Specialist Report) which would involve setting aside key representative portions of the different vegetation types (or communities) within the priority areas already identified within the PK32 conservation area and/or rehabilitate these areas. These priority areas, especially the Ranobe forest area (as identified within the PK32 area) should be actively managed as a conservation area in partnership with Madagascar National Parks (MNP formerly known as ANGAP = Association Nationale pour la Gestion des Aires Protégées). Additional funding and training would allow for the improved and active management of the area and thus facilitate biodiversity conservation.

4. Under the rehabilitation plan it has been proposed that a portion of the mining area is rehabilitated back to woodlots. It is recommended that the area rehabilitated with woodlots (400ha) is offset by rehabilitating and conserving degraded spiny thicket and dry forest outside of the mine area in partnership with MNP and local communities. For the rehabilitation of this area to be effective, it is important to engage local stakeholders in the project. It is recommended that Toliara Sands consider partnering with community reforestation programs that are already in place in the area and offer resources that will aid in the rehabilitation of these areas.

5. According to the IFC Guidance Notes (IFC, 2012) where biodiversity values of importance to conservation are associated with a project site or its area of influence, the preparation of a Biodiversity Action Plan (BAP) provides a useful means to focus a project’s mitigation and management strategy. This is the case for the Ranobe mine project, and hence a BAP should be developed.

1.2.3 Economic Assessment Report



Mining will result in national, regional and local economic benefits. These benefits take place against the backdrop of a country that is heavily dependent on agriculture, has a large foreign debt (US$ 2.32 billion (CIA 2011)), and a large proportion of its population living in poverty. The mining initiative has the potential to increase the regional tax base and to further the region’s claims to a greater proportion of the central fiscus disbursements. It could also provide support for infrastructural development and will, at a local level, provide job opportunities and benefits arising from the multiplier effects associated with these. The economic impact assessment investigated the extent to which the Ranobe Mine Project will provide economic benefits, using economic models that quantify the direct and indirect economic benefits, as well as backward and forward linkages, multiplier effects and real benefits that might arise from employment opportunities. It also examined the impact at a national, regional and local level, in order to discuss the overall benefits of the project to the country of Madagascar. It is recognised that the development could also have some negative economic impacts on other sectors or the economy (i.e. agriculture and tourism). In addition, new job prospects could encourage significant in-migration that may increase slash-and-burn agricultural practices, and increase the demand for the products of other undesirable activities, such as the charcoal industry, which could impact negatively on the natural environment and the management of resource use. The loss of important natural forest/woodland resources may have negative impacts on the existing livelihood strategies of local residents; these potential negative impacts were also assessed in the report.

1.2.4 Faunal Baseline Assessment It is evident that current land use has had a significant impact on faunal (animal) biodiversity and ecological functioning in the area. Although amphibian (e.g. frogs) and reptile (e.g. crocodiles, lizards etc.) diversity remains relatively unaffected by the extensive habitat destruction, significant effects on birds and mammals already exist. The significance of these pre-mining impacts on birds and mammal diversity already range from moderate to high. In the absence of rapid socio-economic upliftment of human communities in the region, it is expected that these impacts will continue to grow. This will lead to further faunal loss and extensive ecological disruption that will not be easily repairable in the long-term. However, due to WTRs social upliftment programmes such as job creation, staff training programme, agricultural program etc. some of these impacts may be alleviated in the long term. The project activities associated with the proposed mine may have an additional low to high environmental impact on faunal biodiversity and ecological functioning in the area. Only amphibian and reptile diversity remains relatively unaffected by the current extensive habitat destruction. Existing impacts on birds and mammal diversity already range from moderate to very high, and will continue to rise in the absence of the mine. The proposed mining activities will result in further faunal losses and ecological disruptions that will range from low to moderate with mitigation measures as suggested by the faunal specialist in place. The various impacts associated with project related infrastructure such as the haul road and the MSP were assessed separately. This was due to the fact that there were various alternatives to these components. These therefore needed to be assessed separately to show which would be the preferred option in terms of faunal impacts. 1.2.4.1 Haul Road options Three alternative routes were being considered for the haul road:

Haul Road Option 1: the old Toliara track, which is an existing route that follows a network of existing tracks and will require substantial upgrading;



Haul Road Option 2: an alternative route very similar to road option 1 but which takes a more direct route to the Fiherenana River; and

Haul Road Option 3: a more coastal route that lies adjacent to settlements and associated fields.

The impacts of greatest significance are associated with the haul road options, particularly Options 1 and 2. This is due to the extensive habitat loss and fragmentation associated with the construction phase and the building of a new haul road through the Ranobe Spiny Forest region. This is expected to have direct consequences for the general loss of biodiversity and rare and/or endangered species, and indirect consequences resulting from the disruption to faunal movements and the increased likelihood of introduction of alien (foreign) fauna. During the operational phase of the mine the heavy road traffic will result in ongoing mortality to fauna and Species of Special Concern. The traffic will also result in increased pollution (dust, chemical and noise) as well as an increased fire risk. Pollution and an increase in fires may result in additional animal mortality. Most of these impacts can only be partially mitigated. The major consideration for Option 3 is that this will limit the amount of disturbance to the spiny forest as it occurs adjacent to settlements and degraded habitats. Options 1 and 2 involve the substantial upgrade of the Toliara track. Although this is already a barrier to migration for animals, its upgrade would create a more substantial barrier through the middle of the spiny forest, with significant loss and increased fragmentation of habitat in a proposed protected area. It would also allow the possibility of greater access to the forest for local people therefore increasing the risk of greater unsustainable resource extraction, particularly the loss of habitat associated with charcoal production. For the haul road, Option 3 is preferred based on the outcome of the faunal study, particularly as it would conserve a greater area of protected habitat if the existing tracks in the central degraded area are closed, public access is prohibited or monitored, and extensive rehabilitation to the disturbed area occurs. 1.2.4.2 Mineral Separation Plant options

Two alternative locations were considered, as follows:

MSP 1: At the mine site. MSP 2: At the Port of Toliara quay.

For MSP 1 the dry mineral products will be trucked from the MSP at the mine to a storage shed at the new jetty on the sand spit north of the existing Port of Toliara, where it will be loaded directly into Handymax or Supramax-size vessels. The rutile/zircon concentrate will be loaded into containers at the storage facility and trucked to the existing port quay near Toliara. In this option products are transported entirely by truck. A new jetty and transport linkages will need to be constructed through the extensive sand dune habitat to the north of the bay. For MSP 2 the HMC from the PCP will be trucked to a transfer station near Belalanda, pumped via a high pressure slurry line across the Fiherenana River, and then onto the MSP at the Port of Toliara. From the MSP the rutile/zircon concentrate will be loaded into containers and trucked a short distance to the existing quay at the Port of Toliara. The ilmenite will be transported by truck or conveyor to a ship loader at the existing quay at the Port of Toliara, where it will be loaded into barges for transhipment to large vessels anchored in the lagoon.

Both options are associated with significant impacts. Location of the MSP at the mine (MSP



Option 1) means less road transport to move the export products extracted from the HMC. However, the additional infrastructure associated with this option lies in a region of sparsely vegetated dunes adjacent to an extensive area of sensitive mangrove habitat and the proposed transport linkages and development of the jetty may negatively impact this area. In MSP Option 2, where the MSP is located further from the mine but closer to the port, HMC will be transported to the Port of Toliara, therefore greater volumes of road traffic between the mine and the transfer station at the Fiherenana River are required. There are also additional risks associated with HMC slurry pipelines traversing mangrove and underwater habitats. Increased faunal mortality will occur during the operational phase in option MSP2, primarily due to the increased need for road transport. For this reason the Mineral Separation Plant Option MSP1 is preferred. The Faunal specialist assessment assessed various impacts associated with current land use, mining and related infrastructure such as the haul road and the MSP. Based upon these impacts the following recommendations were made:

To prevent cumulative environmental impacts, particularly in sensitive habitats, it is preferable that the present project be integrated into regional planning with surrounding projects in association with Madagascan conservation authorities.

Damage to sensitive habitats during ongoing and future survey work and site development must be avoided as far as possible. This is particularly important where new roads are developed as they rapidly lead to strip development and increased resource extraction (e.g. charcoal production).

The development of fire breaks around all project infrastructure.

Short, fire-resistant, indigenous vegetation cover should be established to avoid erosion and siltation into drainage lines.

The chemical control of unwanted vegetation with herbicides, and pests animals with insecticides should be fully controlled and be in accordance with national and international controls of banned substances.

The sale and use of unsustainable extracted resources (e.g. charcoal sourced from areas not cleared for mining) in all mine facilities should be prohibited.

Environmental education of local communities should highlight the negative and unsustainable impacts resulting from large-scale bush clearance, excessive removal of hardwoods for charcoal production and timber, and un-necessary use of fire in the dry season to generate livestock grazing. However, during disclosure of the Draft Scoping Report it was clear that the community understands that current harvesting is not sustainable but due to the lack of alternative livelihoods this will continue to occur.

1.2.5 Ichthyology and Aquatic Habitat Assessment

Although the Fiherenana River is a seasonal system with no surface flow during the dry winter months in the coastal reaches, it does support valuable migratory fish populations which form an important component of the local subsistence fisheries. This pattern of seasonal desiccation common to rivers in south-western Madagascar, is considered responsible for the relatively low numbers of primary freshwater fish species present in these systems, which are dominated by migratory marine spawning species. The main potential impacts of the proposed Ranobe Mine Project on aquatic habitats and biota (living organisms), are related to the proposed location of components of the mine near the Fiherenana River and the new infrastructure (causeway, bridge) required to transport mining products over the river channel to Toliara Port. These potential impacts include



increased sedimentation and pollution of the lower Fiherenana River and the blocking of upstream migrations of marine-spawning fish, eels and crustaceans (prawns and crabs). Without any mitigation, these impacts were assessed as potentially being of high significance. However, it was found that the various identified impacts could be easily reduced to low significance if reasonable and appropriate mitigation measures are implemented during both the construction and operational phases of the proposed mining project.

1.2.6 Land and Natural Resource Use Natural resources, such as wood for the making of charcoal, edible plants and animals, etc. are used extensively by local residents in the forests and woodlands in and around the mine site. These resources are used by local residents to meet their basic needs for shelter, food and medicine. They are also used as important sources of supplementary household income. The clearing of areas of the forests and woodlands to make way for the mine will therefore result in considerable long-term loss of access to valuable resources for local residents. Although the mine is planning to rehabilitate the land, the arid nature of the local climate means that it will take time for the forests to be restored to their current state. It is recommended that:

Mining should be undertaken in a phased manner and progressively rehabilitated.

Consideration should be given to assist the local community with the upgrading of the existing weir to increase water supply in the irrigation canal.

An agricultural programme should be established to teach local residents about sustainable agricultural practices within the general project area.

The mining area should be rehabilitated with various species currently utilised by local residents.

Various species of plants (specifically rare and/or endangered species) should be propagated in the various on-site nurseries and the communities should be encouraged to re-plant what is removed.

It is recommended that villagers have access to the proposed mining area prior to commencement of bush clearing to harvest all available resources.

The overall current significance of pressure on natural resources is high. For example there are very few hardwood tree species left in the forest due to the high demand for charcoal. Mining activities such as job creation and the potential of establishing woodlots and agricultural fields during rehabilitation may alleviate some of these pressures.

1.2.7 Marine Ecology and Fisheries Assessment The marine study assessed the potential impacts arising from the following export infrastructure alternatives based on the available project descriptions:

1. Construction of a new jetty facility at La Batterie beach: a. Longer direct ship loading jetty - open trestle vs alternating causeway/trestle

design; and b. Shorter barging option with transhipment to bulk carriers - open trestle vs

alternating causeway/trestle design; single point mooring and transhipment area. 2. Construction of a pipeline from La Batterie beach to the existing Toliara quay with

reclamation works for an expanded quayside area potentially requiring dredging, increase in quayside capacity and barging to a single point mooring and transhipment area.



Alternative 1 – the new jetty option with an open trestle design accommodating direct ship loading facilities – is preferable to Alternative 2 in terms of their comparative impacts. Alternative 2 is likely to result in more significant impacts for fisher communities by virtue of its proximity to existing villages and much larger volumes of pirogue traffic. It is also likely to result in more significant impacts on existing fishing grounds and general shipping activity in and around the port. It is recommended that the direct ship loading option be adopted for Alternative 1 so as to minimise shipping traffic in general and pose less of a risk to fishers and marine fauna. The overall impact of any of the preferred alternatives on subsistence/artisanal fisheries in the area is likely to be of low significance. Similarly, overall impacts on the prevailing status of marine ecology in Toliara bay and the Grand Récife are predicted to be of low significance if appropriately managed. The crucial issue of restricted beach access and making allowances therefore in the construction and operational phases will require an appropriate solution.

1.2.8 Radiation Assessment The proposed project will establish an extensive heavy minerals sands mining and processing operation, which will include a minerals recovery plant. The project will involve the mining, processing and beneficiation of a heavy minerals sands ore body containing minerals with elevated levels of the radionuclides of the uranium and thorium decay chains. The presence of radioactive materials in such ores has the following major radiological implications:

Occupational exposures of workers.

Possible exposure of members of the public living nearby.

Waste management and long-term radiological environmental impact issues. The main exposure pathways of workers and members of the public living near to the site comprise the following:

External gamma irradiation from the gamma emitting radionuclides.

The inhalation of radioactive radon and thoron gas.

The inhalation of radioactive dusts containing long lived alpha emitters of the uranium and thorium decay chains.

The main conclusions arising out of this specialist report are as follows:

The baseline background annual doses in the project area were significantly higher than the UNSCEAR world average values.

The baseline results indicated that the radon exposure pathway is the dominant pre operational exposure pathway

As the HMC is processed through the MSP process, the uranium and thorium concentrations of several mineral streams are increased.

The data indicates that the majority of the radioactivity in the HMC will eventually be contained within the tails (reject material) from the MSP. The reason for this is that the mineral separation process is designed to separate valuable products (ilmenite, rutile and zircon) from other components of the HMC feed. These other waste components include monazite which is the main source of radioactivity as it contains the radioactive elements, uranium and thorium. Thus, the level of radioactivity of the MSP tails will be significantly enhanced when compared to the natural background



radiation levels of the original sand. In order to control the exposure of workers exposed to these materials administrative and engineered controls will be required.

The majority of the occupational radiation exposure in the PCP and the MSP arises from gamma radiation, provided the dry sections of the plant are equipped with an efficient dust removal system.

Workers are considered to be occupationally exposed to radiation when their annual exposures exceed 1 mSv. This preliminary dose assessment indicates that this will occur from the production of HMC and all process steps onwards.

A major mitigation requirement will be to control the spread of materials from the stockpiles.

The final disposal option will be decided after radiological modelling during the detailed design phase. However, blending of MSP with PCP tails prior to the return to the mine pit is currently regarded as the preferred option. It is the responsibility of the project operator to identify and address the key radiological issues and determine the engineered and administrative controls required to keep the radiation exposures of workers and the public in accordance with the dose limitation system throughout all stages of the project. A variety of radiological issues have been identified in this specialist study, which need to be considered and assessed at an early stage in the project. The following recommendations are made: Prior to the mining and processing operations a detailed prospective safety assessment of the doses to the workers and the public arising from normal mining and plant operations needs to be carried out. In order to carry out the prospective safety assessment the following information needs to be obtained:

A detailed description of the process from mining through to the disposal of tails.

The U, and Th content of the ore, HMC, feed, product and waste materials at all stages of the process.

The quantities of materials processed each year at each stage of the process.

A radioactive material balance for the whole operation.

Occupancy models for workers in controlled areas The above quantitative information can be used to assess the following components of the radiation protection programme:

The estimated annual doses to workers and the public arising from the operations

The required design and engineered controls to limit the radiation doses

The required administrative controls

The finalisation of the plant design

The assessment of the waste management options The specific requirements of the radiation protection programme for the Ranobe Mine Project operations will need to be iteratively determined as the project progresses. The IAEA Basic Safety Standards and associated guide and technical documents on NORM operations will be used to assist in this process. Prior to operation all the radiation protection programmes for workers and the public should be implemented along with the routine monitoring programs at the plants and in the environment.



It is expected that all aspects of the radiation protection programme will be detailed in a “radiation management plan” that will be developed prior to the commencement of operations and progressively updated during the operational stage.

1.2.9 Sediment Transport Assessment The open piled berth and access trestle structures (An open framework used to support an elevated structure such as a bridge) are not expected to have a noticeable impact on the sediment transport mechanics. The rubble mound causeway structure however has the potential of interrupting the natural southward longshore transport, which could result in shoreline accretion (build up or extension) to the north of the structure and shoreline erosion (reduced width) to the south. The extent of the shoreline erosion is dependent on the volume of sediment being delivered via the southern Fiherenana River channel. Furthermore, the rubble mound causeway is likely to interrupt the northward moving wind-blown sediment, resulting in the accumulation against the southern side of the structure. The proposed causeway and laydown area are located close to a highly dynamic shoreline which is currently eroding at 20 m/year. It is recommended that the laydown area and causeway be moved further inland which will reduce their potential impact on the sediment dynamics and avoid the potential failure of these structures due to shoreline erosion. To further minimize the impact of the rubble mound causeway, its length should be minimized, whilst the length of the piled access trestle should be maximized.

1.2.10 Social Impact Assessment The SIA has considered the socio-economic impacts of the Ranobe Mine project at local level. The project will have some positive impacts in terms of creating development and providing employment. However, certain negative impacts may manifest themselves. The loss of access to land and natural resources and at the same time additional pressure on natural resources will, if not well managed, lead to disruptions of people’s livelihoods. The strategies and input of the various local stakeholders need to be carefully worked out in order to optimise fair and widely accepted compensation strategies. Local residents are sensitive to the potential disruption of their tombs. It is recommended that, if possible, these remain intact. In case tombs need to be removed, careful negotiation with the local leaders and families will need to take place in order to ensure that this is conducted in a culturally appropriate manner. Expectations of job opportunities and development projects are high amongst local residents, however only relatively few job opportunities will be available. It is very important to instil realistic expectations with regards to benefits from the mining project and to develop a strategy of equitable distribution of job opportunities amongst the affected parties. The skills base in the area is poor, and in order to optimise local employment opportunities, skills training will be necessary. Particular attention will need to be given to women and youth. The mining project may have several socio-cultural impacts, including tensions within villages (between those employed by the mining company and those who are not), between villages (competing for development projects sponsored by the mining company) and between local residents and outsiders (cultural clashes and HIV/Aids increase). The development of a Stakeholder Engagement Plan (SEP), and the employment of a strong community liaison manager and the development of a representative community liaison working group is important. Post-mining communities often suffer hardship as a result of disruption of their traditional lifestyles which may be exacerbated by a sudden collapse of the temporary support of the mine. Plans should be put in place early on in the mining process for post mining activities.



In terms of land, a rehabilitation forum should be created of all relevant stakeholders, including representatives of local communities, to develop a rehabilitation plan.

1.2.11 Specialist Study on Noise Impacts Noise pollution will be generated during the construction phase as well as the operational phase. 1.2.11.1 Construction Activities The construction phase could generate noise during different activities such as:

Site remediation and earthworks.

Building construction using mobile equipment, cranes, concrete mixing and pile driving equipment (If required).

Vehicle use and movement.

Mobile generators etc. The number and frequency of use of the various types of vehicles has not been finalised but an indication of the type and noise generated is presented in the table below.

Type Description Typical Sound Power Level (dB)

Bus to Transport Workers 60 seater 95

Passenger Vehicle Passenger vehicle or light delivery vehicle such as bakkies

85

Trucks 10 ton capacity 95

Cranes Overhead and mobile 109

Mobile Construction Vehicles Front end loaders 100

Mobile Construction Vehicles Excavators 108

Mobile Construction Vehicles Bull Dozer 111

Mobile Construction Vehicles Dump Truck 107

Mobile Construction Vehicles Grader 98

Mobile Construction Vehicles Water Tanker 95

Stationary Construction Equipment

Concrete mixers 110

Compressor Air compressor 100

Compactor Vibratory compactor 110

The following is recommended for the construction phase:

It is recommended that if pile operations are needed, noise attenuation measures such as an earth berm should be considered. The piling noise will however be of short duration; therefore the overall impact should be low. If impact piling is conducted it is highly recommended that an additional survey be conducted at night to determine the zone of influence as well as the actual efficacy of the attenuation measures.

Construction staff should receive noise sensitivity training to ensure that the construction noise is kept at a minimum.

The use of portable noise attenuation screens is highly recommended. These can be placed as close as possible to the noise source such as mobile compressors, drilling rigs etc.



Conducting periodic noise surveys to determine the efficacy of noise attenuation measures should be undertaken.

1.2.11.2 Operational Activities Safetech conducted a similar noise impact assessment for a heavy minerals project in South Africa. The noise from various existing pieces of equipment was measured and was used as a source of reference information for this project. These are illustrated in the table below:

Description

Sound Pressure Level Leq dB(A)

PCP plant sump level 1 meter away from pumps

84.9

Spiral Building 1 meter away from spiral pumps

84.9

Bell Payloader L 1806C 1 metre away

88.3

Unitrans 38202 1 metre away (Nissan UD460)

88.3

The sand tailing pumps 82

Holding Tanks 85

The following is recommended for the operational phase: Given that it is not possible to eliminate all noise during the operational phase, the following general recommendations are made:

a) The general guidelines for noise reduction in new developments should be implemented. These include:

Selecting equipment with lower sound power levels.

Installing suitable mufflers on engine exhausts and compressor components.

Installing acoustic enclosures for equipment to stop noise at source. Specific noise management measures that should be considered are:

b) Ensuring that staff is given “noise sensitivity” training. This should include the operational techniques to ensure that the mining bench is situated in a manner that will ensure that the noise is screened from nearby residents.

c) The efficacy of the mitigation measures must be measured once the operational phase has commenced. This should be done by conducting an environmental noise survey. In addition to this noise monitoring will be conducted for the baseline situation and will remain ongoing during all phases of the project.

1.2.12 Visual Impact Assessment



An opencast mine in a remote region of Madagascar will have an impact on its sense of place. Proximity to Toliara and the landscape transforming effects of deforestation in the surrounding region reduces this sense of remoteness somewhat, but some of the components of the proposed development will introduce elements that will potentially be highly intrusive such as large, multi-wagon trucks travelling through rural areas where currently oxcarts are still a common form of transport, industrial type buildings and equipment in a rural area and a jetty with large storage sheds and large ships docking where there is currently an empty beach.

The mine site is surrounded by the PK 32 – Ranobe protected area, an area identified as an important site of biodiversity which currently faces pressures from numerous sources (Frontier-Madagascar, 2005). Creating a protected area here is an attempt to slow down deforestation in the region, to provide forests time to recover and to protect remaining forests. It has not been entirely successful up to date and the natural vegetation in the mining area is degraded and disturbed, but in 2010 the area under protection was increased considerably indicating that PK 32 could become a permanent and officially recognised protected area of Madagascar. One of the objectives in regards to protected areas in Madagascar is to promote eco-tourism which means that in future access and facilities will be provided to tourists who are unlikely to be attracted to a region transformed by mining. It is therefore essential that the design, layout and management of the mine take cognisance of the fact that it is surrounded by a protected area where eco-tourism will play some part in its future.

In terms of visual impact it is recommended that Haul Route Option 2 is used for the haul road as it will affect the lowest number of highly sensitive visual receptors. A professional landscape architect with knowledge and experience of the local landscape should be consulted when designing and laying out mine buildings and structures in order to reduce visual intrusion as much as possible. A lighting specialist should be consulted to design a lighting plan for the mine and jetty which will minimise light pollution such as glare, light trespass and sky glow.

1.2.13 Waste and Wastewater Assessment According to the Basel Convention fact sheet of 2011, no registered hazardous waste sites or general waste facilities (including disposal, recovery, recycling or re-use) exist within Madagascar. Also, a national inventory for hazardous wastes is not yet in place and no bilateral, multilateral or regional waste handling agreement exists. Two alternative sites were considered in developing the project concept for locating the Mineral Separation Plant and they include Options 1 and 2, locating the plant at the mine site or at the port, respectively. It is the waste specialists opinion that due to the presence of sensitive receptors such as large water bodies, Option 2 would result in significantly HIGH impacts and, as such, option 1 is considered the preferred option for effective management of the process waste. A total of nine impacts related to waste management were identified and of these, with mitigation, seven were regarded as being low negative significance, one was regarded as moderate while one was regarded as potentially of high positive significance. The enhancement of local waste management infrastructure and awareness of the need for sound waste management practice were regarded as impacts with potentially high positive significance. Due to the potential long-term nature of waste-related impacts, it is essential that the developer adhere to national legislative requirements and international best practice with regards the management of all waste streams. While a number of specific mitigation measures have been included in the document, further detailed guidance on the



management of key waste streams is provided in the documents listed in Reference and Appendixes of the Waste Report included in the Specialist Volume. Due to the local situation with poor waste management and relevant legislations still in the developmental phase, it is recommended that a general waste facility be located on site. As per international trends, all waste streams should be managed according to the waste management hierarchy. This specifies that wherever possible, production of wastes should be prevented or minimised at source. Where prevention or further minimization is not possible, wastes should be re-used, recycled and then disposed of responsibly so as to minimise impacts to the environment.

1.2.14 Water Assessment Water requirements for the dry mining and processing operations are estimated to be 560 m3/hr (a little less than 13 500m3/day), of which about 90% will be abstracted from boreholes and 10% recovered - recycled - from the mined ore. Approximately 90% of the water demand will be returned to the environment through the placement of tailings from the wet processing plant, thereby artificially recharging the underlying Eocene limestone aquifer. The processing plants make significant use of recycled process water, and in the long term the ratio of process water to external freshwater inputs is about 6.5 to 1. Water requirements will remain essentially constant during the 21-year operational lifetime of the mine, but may increase by 10% or so in the final few years of operation. Extensive research and modelling of the hydrology of the area has been carried out since 2003 with several studies being completed. The results of previous work by Hydromad (2004), GCS (2004) and SRK (2007) concluded that the reliable yield of the limestone aquifer was sufficient to supply the previously planned large-scale, 30-year Exxaro dredge mining operation, for which the water requirements were estimated to be 45 000m3/day (about 1 900m3/hr) for the first 11 years of mining, and 68 000m3/day (about 2 900m3/hr) for a 50% increase in production during years 12 to 30. Since the water requirements for dry mining are only 30% of the years 1 to 11 requirements for dredge mining it is clear that there will be sufficient water for the smaller scale Stage 1 dry mining and processing operations without the resource being over-exploited. This water can readily be accessed via a carefully designed system of well-spaced boreholes. There will be no need to consider accessing the surface water resources of the Manombo River to the north of the mining area. Due to the distance between the proposed wells and surface water bodies (coastal marshes and Manombe River), the impacts of groundwater abstraction on surface waters are likely to be low. However, a slight decrease in water levels may exhibit a significant difference due to the highly fragile equilibrium between groundwater and surface water for both local people and natural habitats. Therefore, the impact assessment of water requirements from the new mine design should be supported by updating the simulation model with the new water requirement for the mine (including any potential dewatering and any losses from the tailings to the groundwater), as well as recently collected data on site, which was not used or not available for previous studies. The simulation should take into account current uses by local communities and commercial activities (hotels), as well as potential increases in the future. According to the Water Assessment undertaken by Aquaterre, additional information is needed as gaps in the information where identified. This data would include the following:



Quantify evaporation and rainfall with more accuracy for the entire recharge area, based upon local measurements.

Quantify the recharge rate of the limestone aquifer with more accuracy, and verify the recharge area of this aquifer.

Better characterise the lower Eocene aquifer characteristics east of the Toliara fault (limestone plateau), which will require additional drilling in this area.

Additional data points (drilling) are also needed across the mine site and coastal area to improve the resolution across the entire study area.

Better understand the interactions between groundwater and surface water, specifically for the Manombo river (and associated irrigation canals), springs and coastal marshes/lakes; this would require additional surface water data (flows and water levels; river bed characteristics).

Quantify current water uses by local communities and hotels, as well as predict future uses (including induced effect linked to the mine development).

Better understand the macro-chemistry and isotopes of rain water, surface water and groundwater in order to better understand groundwater recharge as well as surface and groundwater interactions.

Finally, if the proposed water abstraction has impacts on water table in the vicinity of the coastal wetlands, additional work should be conducted by ecologists to establish the significance of these impacts upon wetland ecology. Additional data and analysis (numerical modelling) are required prior to implementation of the project’s design phase purposes. As mentioned by SRK, a detailed geophysical survey would be necessary to select the optimal position of production wells. Following drilling, pump tests will be necessary, under ANDEA’s supervision, in order to obtain the water abstraction authorisation. During these pump tests, water levels will have to be monitored at the production wells, surrounding observation/monitoring wells (drilled by the project), and local community/hotel and/or other private users’ wells to demonstrate that the proposed abstractions will not have any adverse effects upon these existing users. Long term monitoring is required to confirm the results of model, insure that the project does not have any unexpected impacts upon local users and the surrounding environment, and support corrective measures, where and if necessary. However, it is not designed to be a surrogate for lacunas in or lack of information/data for project design and used in the ESIA. Current recommendations are preliminary as they need to be reviewed following when re-modelling has been completed and the impacts of the current project are quantified. Long term monitoring (during and after project implementation) of the following:

Weather monitoring (specifically rainfall and evapotranspiration);

Piezometric levels at observation wells located near and downward from the mine area and well fields, and also near sensitive areas (villages, Manombo River, coastal wetlands);

Water levels within the surface water bodies (Manombo River, coastal wetlands) as well as flows on the Manombo River;

Local water supplies (hand-dug wells, private (hotel) wells, irrigation channels);

Inspection of the surrounding of the well fields to insure that no sinkholes are developing;

Water chemistry (salinity) at observation wells were there could be a potential risk of salt intrusion; and



Ecological monitoring of coastal wetlands. It will be important to include monitoring sites which are not affected by the mine and water abstraction processes, as comparative sites, to assess potential background changes which are not associated with the mine development.



Table 1.1: Residual Impacts

Without Mitigation With Mitigation

Impact Temporal scale Spatial scale Severity Significance Severity Significance

MINE SITE

CONSTRUCTION PHASE

IMPACT ON GEOMORPHOLOGY, GEOLOGY AND SOILS

Changes to topography Long Term Local Slight LOW - Slight LOW -

Removal of topsoil and soil erosion Long Term Study Area Severe HIGH - Moderate MODERATE -

IMPACTS ON SURFACE AND GROUNDWATER RESOURCES

Pollution of groundwater resources Long Term Local / Study Area Severe HIGH - Moderate MODERATE -

IMPACTS ON THE AIR QUALITY

Generation of dust Short Term Local Slight LOW - Slight LOW -

Vehicle emissions Short Term Local Slight LOW - Slight LOW -

NOISE IMPACTS

Noise pollution Long Term Local Slight LOW - Slight LOW -

IMPACTS ON FLORA

Loss of Colvillea-Tamarindus forest patches (Community A)

Permanent Regional Moderate HIGH - Slight MODERATE -

Loss of limestone forest (Community B)

Permanent Study Area Moderate MODERATE - Slight MODERATE -

Loss of Dry Forest (Community C)

Permanent Study Area / Local Severe HIGH - Moderate MODERATE -

Loss of Bushclump / Open area mosaic (Communities E & F)

Permanent Study Area / Local Slight MODERATE - Slight MODERATE -

Loss of Intermediate Forest (Community G)

Permanent Study Area Slight MODERATE - Slight MODERATE -

Loss of Biodiversity Permanent / Medium Term

Study Area / Local Moderate MODERATE - Slight LOW -

Reduction of Area of Occupancy of Confirmed Species of Concern in the Permit Area (CSC-PA)

Permanent / Medium Term

Study Area Severe HIGH - Moderate MODERATE -





Reduction of Area of Occupancy of Confirmed Species of Concern in the Project area (CSC-PA)


International Severe HIGH - Moderate MODERATE -

Reduction of Area of Occupancy of Species of Concern (PSC)

Permanent International Moderate HIGH - Slight MODERATE -

Fragmentation of vegetation and edge effects

Permanent Local Moderate MODERATE - Slight MODERATE -

Invasion of alien species Permanent Local Moderate MODERATE - Slight MODERATE -

IMPACTS ON FAUNA

Loss of Faunal Diversity Short to Medium

Term Regional Moderate MODERATE - Moderate MODERATE -

Loss of Species of Special Concern Short to Medium


Introduction of Alien Fauna Medium to Long

Term Study Area Slight MODERATE - Slight MODERATE -

Habitat Loss Medium to Long

Term Regional Severe HIGH - Moderate MODERATE -

Habitat Fragmentation Medium to Long

Term Study Area Moderate MODERATE - Moderate MODERATE -

IMPACTS ON PK 32









Loss of Intermediate Forest (Community G)


Loss of Biodiversity Permanent / Medium Term



























IMPACTS ON THE SOCIAL ENVIRONMENT

Increase in employment opportunities and related economic benefits

Medium Term Study Area Slight LOW + Moderate MODERATE +

The in-migration of large numbers of economic migrants and job seekers

Medium Term National Severe HIGH - Moderate MODERATE -

The physical and economic displacement of structures and fields located in the mine lease area

Permanent Study Area / Local Very Severe VERY HIGH - Moderate MODERATE -

IMPACTS ON LAND USE

Loss of natural resources Short Term Study Area Moderate MODERATE - Slight LOW -

Clearing virgin land for small scale farming as a result of agricultural displacement

Long Term Study Area Severe HIGH - Slight MODERATE -

Increasing demand for natural resources

Long Term Study Area Severe HIGH - Moderate MODERATE -





Capacity of institutions to manage use of natural resources

Long Term Regional Severe HIGH - Moderate MODERATE -

ECONOMIC IMPACTS ON THE REGIONAL ECONOMY

Increase in income and expenditure due to direct employment

Long Term Regional Moderate Beneficial

HIGH + Beneficial HIGH +

Indirect and induced impacts Long Term Regional Moderate Beneficial


Leakage of employment and business opportunities

Medium Term Regional Severe HIGH - Moderate MODERATE -

Impacts on Toliara Town Long Term Regional Moderate Beneficial

MODERATE + Beneficial HIGH +

ECONOMIC IMPACTS ON THE LOCAL ECONOMY

Increased income associated with increased direct employment opportunities

Long Term Study Area Moderate Beneficial


Increased income earning opportunities linked to indirect and induced effects and job creation

Long Term Study Area Beneficial HIGH + Beneficial HIGH +

Leakage of employment and income earning opportunities to outsiders

Medium Term Regional Moderate MODERATE - Slight MODERATE -

Leakage of employment and income earning opportunities due to opportunistic in-migration


Loss of forest and grazing land Long Term Study Area Severe HIGH - Slight MODERATE -

ECONOMIC IMPACTS ON THE LOCAL TOURISM SECTOR

Impact on tourism sector associated with increased demand

Long Term Local Moderate Beneficial






MINE SITE

OPERATIONAL PHASE

IMPACT ON GEOLOGY, SOIL AND TOPOGRAPHY

Changes to topography Long Term Study Area Moderate MODERATE - Slight LOW -

Loss of topsoil Long Term to Permanent

Study Area Severe HIGH - Slight MODERATE -

Change to soil’s physical, chemical and biological properties

Long Term to Permanent


Cumulative effect on soil potential Long Term to Permanent


Contamination from storage facilities, fuel tanks, service areas, etc

Long Term to Permanent

Study Area Moderate to

Severe HIGH - Moderate MODERATE -

Decrease in plant available water Short Term Study Area Severe MODERATE - Slight LOW -

Salinity and sodicity Long Term Study Area Severe HIGH - Slight MODERATE -

Loss of vegetation and/or crops Short Term Study Area Severe MODERATE - Slight LOW -


Reduced groundwater resources available to communities

Short to Medium Term

Local / Study Area Slight to

Moderate MODERATE - Slight LOW -

Reduced surface water resources available to communities


Study Area Moderate MODERATE - Slight LOW -

Reduced groundwater resources available to commercial facilities on the coastline


Local Moderate MODERATE - Slight LOW -

Loss of functionality in the Tsiake salt marsh and salt works


Local Severe MODERATE - Slight LOW -

Loss of crops due to drying of sub-surface soils


Local Severe MODERATE - Slight LOW -

Loss of vegetation due to drying of sub-surface soils


Local Moderate LOW - - N/A

Development of sinkholes Medium Term Local Severe MODERATE - Slight LOW -





Loss of aquatic freshwater habitat in the south-central coastal plains (Ranobe and surrounds)


Local Moderate MODERATE - Slight LOW -

Loss of aquatic saline habitat in the south-central coastal plains (Ambolomailaka hinterland)

Medium Term Local Moderate MODERATE - - UNKNOWN

Surface water ponding and increase due to mining activities

Short Term Local Moderate MODERATE - Slight LOW -

Effect of decreased flow in seeps and springs on the coastline on local communities and aquatic habitats

Short Term Local Slight LOW - Slight LOW -

Increased salt load to the aquifer from tailings disposal

Long Term Study Area Moderate MODERATE - Slight MODERATE -

Contamination due to spillages from mining facilities

Long term Study Area Severe HIGH - Slight MODERATE -


Vehicle emissions Short Term Local Slight MODERATE - Slight LOW -

NOISE IMPACTS


RADIATION IMPACTS

Impact on Public Radiation Exposure by the disposal of Homogenous Solid Wastes from the PCP and MSP Process

Permanent / Long Term

Regional / Local Severe HIGH - Slight LOW -

Impact on Public Radiation Exposure by the Disposal of Slightly Contaminated Equipment from the PCP and MSP

Long Term Regional / Local Moderate MODERATE - Slight LOW -

Impact on Public Radiation Exposure by the release of Radioactive Materials into the Air and Water from the MSP and PCP Operations and During Transport to the Mine Void

Long Term Regional / Local Moderate MODERATE - Slight LOW -





Occupational Exposure of Workers to Radioactive Materials and Ionising Radiation at the Toliara Operations

Long Term Regional / Local Severe HIGH - Slight MODERATE -

The Contamination of the Operational Areas with NORM Residues over the Life of the Mine

Long Term Local Moderate MODERATE - Slight LOW -

IMPACTS ON FLORA









Reduction of Species Richness and Diversity














IMPACTS ON FAUNA















Increased Dust Levels Medium Term Study Area Moderate MODERATE - Slight LOW -

Increased Fire Risk Medium Term Study Area Moderate MODERATE - Slight LOW -

Chemical Pollution Medium Term Study Area Moderate MODERATE - Slight LOW -

Noise Pollution Medium Term Study Area Moderate MODERATE - Slight LOW -

IMPACTS ON PK 32









Reduction of Species Richness and Diversity

































The expansion of infrastructure and service provision

Medium Term / Permanent

Study Area Moderate MODERATE + Beneficial HIGH +

Increased competition and conflict between communities

Medium Term Local Moderate MODERATE - Slight LOW -

An increase in social pathologies Long Term Study Area Severe HIGH - Moderate MODERATE -

Loss of productive land and natural resources due to mining

Permanent Study Area Very Severe VERY HIGH - Moderate HIGH -

Loss of sacred and culturally important heritage sites

Permanent Study Area Severe HIGH - Moderate MODERATE -

Relocation of tombs and graveyards Permanent / Medium

Term Study Area Very Severe VERY HIGH - Moderate HIGH -

IMPACTS ON LAND USE












ECONOMIC IMPACTS ON THE NATIONAL ECONOMY


Long Term National Slight

Beneficial MODERATE + Beneficial HIGH +

ECONOMIC IMPACTS ON THE REGIONAL ECONOMY


Long Term Regional Moderate Beneficial


Indirect and induced impacts Long Term Regional Moderate Beneficial


Leakage of employment and business opportunities

Medium Term Regional Severe HIGH - Moderate MODERATE -

Impacts on Toliara Town Long Term Regional Moderate Beneficial


ECONOMIC IMPACTS ON THE LOCAL ECONOMY

Increased income associated with increased direct employment opportunities

Long Term Study Area Moderate Beneficial


Increased income earning opportunities linked to indirect and induced effects and job creation

Long Term Study Area Moderate HIGH + Beneficial HIGH +

Additional income from lease and royalty payments to local authorities and residents and from community development

Long Term Local Moderate MODERATE + Beneficial MODERATE +

Leakage of employment and income earning opportunities to outsiders


Leakage of employment and income earning opportunities due to opportunistic in-migration


Loss of forest and grazing land Long Term Study Area Severe HIGH - Slight MODERATE -

ECONOMIC IMPACTS ON THE LOCAL TOURISM SECTOR

Impact on tourism sector associated with increased demand


Local Moderately

Severe MODERATE - Slight LOW -





MINE SITE

DECOMMISSIONING PHASE


Pollution of surface and groundwater sources

Long Term Local / Study Area Severe HIGH - Moderate MODERATE -



NOISE IMPACTS

Noise Pollution Long Term Local Slight LOW - Slight LOW -

IMPACTS ON FAUNA




IMPACTS ON PK 32





Loss of social services Permanent Study Area Severe MODERATE - Severe MODERATE -

Retrenchment Permanent Study Area Very Severe VERY HIGH - Moderate MODERATE -





ROAD AND QUARRY SITE

CONSTRUCTION PHASE


Changes to topography Long Term Local Slight LOW - N/A N/A


IMPACTS ON SURFACE WATER RESOURCES

General pollution Long Term Study Area / Local Severe HIGH - Moderate MODERATE -

Increased sedimentation and elevated turbidity in the Fiherenana and downstream

Medium / Short Term Regional / Study

Area plus downstream

Severe HIGH - Slight LOW -

Hazardous material contamination Short Term Study Area plus

downstream Severe MODERATE - Slight LOW -




NOISE IMPACTS


IMPACTS ON FLORA

Loss of Dry Forest (Community C) Haul Road Option 1




Loss of Spiny Thicket (Community D) Haul Road Option 1






Loss of Intermediate Forest (Community G) Haul Road Options 1 and 2






Reduction of Species Richness and Diversity - Haul Road Options 1, 2 and 3



Reduction of Area of Occupancy of Confirmed Species of Concern in the Project area (CSC-PA) - Haul Road Options 1, 2 and 3



Reduction of Area of Occupancy of Species of Concern (PSC) – Haul Road Options 1, 2 and 3


Fragmentation of vegetation and edge effects - Haul Road Options 1 and 2

Permanent Study Area Severe HIGH - Moderate HIGH -

Fragmentation of vegetation and edge effects - Haul Road Options 3


Invasion of alien species – Haul Road Options 1, 2 and 3

Permanent Study Area Severe HIGH - Slight MODERATE -

IMPACTS ON FAUNA

Loss of general biodiversity - Haul Road Options 1 and 2

Long Term Local and Regional Very Severe VERY HIGH - Severe HIGH -

Loss of general biodiversity - Haul Road Options 3

Long Term Local and Regional Severe HIGH - Moderate HIGH -

Loss of Species of Special Concern Haul Road Options 1 and 2

Long Term Regional and

National Very Severe VERY HIGH - Severe HIGH -

Loss of Species of Special Concern Haul Road Options 3


National Severe HIGH - Moderate HIGH -

Threats to Animal Movements Haul Road Options 1 and 2

Long Term Local Very Severe VERY HIGH - Severe HIGH -

Threats to Animal Movements Haul Road Options 3

Long Term Local Severe HIGH - Moderate MODERATE -

Introduction of Alien fauna Haul Road Options 1, 2 and 3

Medium to Long Term

Local Slight MODERATE - Slight MODERATE -





Biodiversity loss due to habitat fragmentation and habitat loss Haul Road Options 1 and 2

Long Term National and

Regional Very Severe VERY HIGH - Severe HIGH -

Biodiversity loss due to habitat fragmentation and habitat loss Haul Road Options 3


Regional Severe HIGH - Moderate HIGH -

Ecological impacts from dust Haul Road Options 1 and 2

Medium to Long Term

Local Severe HIGH - Severe HIGH -

Ecological impacts from dust Haul Road Options 3

Medium to Long Term

Local Severe HIGH - Moderate MODERATE -

Ecological impacts from unnatural fires - Haul Road Options 1, 2 and 3

Medium to Long Term


Disruption to ecosystem processes due to pollution - Haul Road Options 1, 2 and 3

Long Term Local Moderate MODERATE - Slight MODERATE -

Disruption to fauna from increased noise levels - Haul Road Options 1, 2 and 3


IMPACTS ON PK 32











Loss of Intermediate Forest (Community G) Haul Road Options 1 and 2


Reduction of Species Richness and Diversity - Haul Road Options 1, 2 and 3







Reduction of Area of Occupancy of Confirmed Species of Concern in the Project area (CSC-PA) - Haul Road Options 1, 2 and 3



Reduction of Area of Occupancy of Species of Concern (PSC) – Haul Road Options 1, 2 and 3


Fragmentation of vegetation and edge effects - Haul Road Options 1 and 2

Permanent Study Area Severe HIGH - Moderate HIGH -

Fragmentation of vegetation and edge effects - Haul Road Options 3


Invasion of alien species – Haul Road Options 1, 2 and 3

Permanent Study Area Severe HIGH - Slight MODERATE -

Loss of general biodiversity - Haul Road Options 1 and 2

Long Term Local and Regional Very Severe VERY HIGH - Severe HIGH -

Loss of general biodiversity - Haul Road Options 3

Long Term Local and Regional Severe HIGH - Moderate HIGH -

Loss of Species of Special Concern Haul Road Options 1 and 2


National Very Severe VERY HIGH - Severe HIGH -

Loss of Species of Special Concern Haul Road Options 3


National Severe HIGH - Moderate HIGH -

Threats to Animal Movements Haul Road Options 1 and 2


Threats to Animal Movements Haul Road Options 3


Introduction of Alien fauna Haul Road Options 1, 2 and 3

Medium to Long Term

Local Slight MODERATE - Slight MODERATE -

Biodiversity loss due to habitat fragmentation and habitat loss Haul Road Options 1 and 2


Regional Very Severe VERY HIGH - Severe HIGH -

Biodiversity loss due to habitat fragmentation and habitat loss Haul Road Options 3


Regional Severe HIGH - Moderate HIGH -





Ecological impacts from dust Haul Road Options 1 and 2

Medium to Long Term

Local Severe HIGH - Severe HIGH -

Ecological impacts from dust Haul Road Options 3

Medium to Long Term


Ecological impacts from unnatural fires - Haul Road Options 1, 2 and 3

Medium to Long Term


Disruption to ecosystem processes due to pollution - Haul Road Options 1, 2 and 3

Long Term Local Moderate MODERATE - Slight MODERATE -

Disruption to fauna from increased noise levels - Haul Road Options 1, 2 and 3



Loss of land and access to natural resources


An increase in employment and related economic benefits

Medium Term Study Area Slight LOW + Very

Beneficial HIGH +

The physical and economic displacement of structures and fields located along the haul road

Permanent Study Area Very Severe VERY HIGH - Moderate HIGH -

IMPACTS ON THE USE OF LAND AND NATURAL RESOURCES













OPERATIONAL PHASE


Increased sedimentation and elevated turbidity in the Fiherenana and downstream

Medium / Short Term Regional / Study

area plus downstream

Severe HIGH - Slight LOW -

Heavy Mineral Concentrate (HMC) contamination

Medium Term Study area plus

downstream Slight LOW - Slight LOW -

Instream structures blocking natural migrations in Fiherenana River

Long Term Study Area plus

upstream reaches Very Severe HIGH - Slight MODERATE -


Vehicle emissions Short Term Local Slight MODERATE - Slight LOW -

NOISE IMPACTS

Noise pollution Short Term (due to progressive mining)

Local Slight LOW - Slight LOW -

IMPACTS ON FLORA

Increased Access along the Haul Road - Haul Road Options 1, 2 and 3


IMPACTS ON FAUNA





Threats to Animal Movements – Haul Road Options 1 and 2


Threats to Animal Movements – Haul Road Options 3


IMPACTS ON PK 32

Increased Access along the Haul Road - Haul Road Options 1, 2 and 3










Threats to Animal Movements – Haul Road Options 1 and 2


Threats to Animal Movements – Haul Road Options 3



Increased road accidents and safety risks

Medium Term Regional Very Severe VERY HIGH - Moderate MODERATE -

Decrease the illegal use of natural resources

Short Term Local Slight

Beneficial LOW + Beneficial LOW +

IMPACTS ON THE USE OF LAND AND NATURAL RESOURCES













DECOMMISSIONING PHASE

IMPACTS ON FLORA

Vegetation Degradation due to Increased Access along the Haul Road

Permanent Study Area Severe HIGH - Severe HIGH -

IMPACTS ON FAUNA

Loss of Fauna due to Increased Access along the Haul Road


IMPACTS ON PK 32

Vegetation Degradation due to Increased Access along the Haul Road


Loss of Fauna due to Increased Access along the Haul Road






PORT AND JETTY SITE

CONSTRUCTION PHASE


Changes to topography Long Term Local Slight LOW - N/A N/A


IMPACTS ON MARINE WATER RESOURCES

Pollution events - fuel or hydrocarbon spill impacts on marine ecology

Long Term Regional / Study

area Severe HIGH - Moderate MODERATE -

Turbidity – suspension of particulates in the water column

Short Term Local Slight LOW - Slight LOW -




NOISE IMPACTS


IMPACTS ON MARINE FLORA AND FAUNA

Collision with marine fauna Medium Term Regional Severe MODERATE - Moderate MODERATE -

Collision with barrier reef Long Term Regional / Study

area Severe HIGH - Severe MODERATE -

Pollution events - fuel or hydrocarbon spill impacts on marine ecology

Long Term Regional / Study

area Severe HIGH - Moderate MODERATE -

Waste disposal Medium Term Study area Moderate MODERATE - Slight LOW -

Antifoulant paint toxicity Long Term Study area Moderate MODERATE - Slight LOW -

Physical disturbance or destruction of marine fauna and flora


Noise and vibration impacts on marine fauna

Short Term Study area Moderate LOW - Moderate LOW -






An increase in employment and related economic benefits

Medium Term Study area Moderate MODERATE + Beneficial MODERATE +

The in-migration of large numbers of economic migrants and job seekers

Medium Term National Severe HIGH - Moderate MODERATE -

Increased economic displacement resulting from the loss of land

Long Term Study area Very Severe VERY HIGH - Severe HIGH -

Reduced access to local fishing grounds

Long Term Study area Very Severe VERY HIGH - Severe HIGH -


Subsistence fisher safety Short Term Local Very Severe HIGH - Severe MODERATE -

Pollution events - fuel or hydrocarbon spills from vessels and the impacts on food security/fishing activity

Medium Term Study area Severe MODERATE - Moderate LOW -

Noise and safety impacts on beach users – fishers and community






PORT AND JETTY SITE

OPERATIONAL PHASE

IMPACT ON THE CLIMATE

Change in longshore sedimentation patterns



Ballast water disposal Medium Term Study area Moderate MODERATE - Slight LOW -

Pollution of the beach and nearshore region around the jetty

Medium Term Local Severe MODERATE - Moderate LOW -

Mineral loss Medium Term Study area / Local Moderate MODERATE - Slight LOW -

Turbidity Short Term Local Slight LOW - Slight LOW -


Vehicle emissions Long Term Local Slight MODERATE - Slight LOW -

NOISE IMPACTS

Noise pollution Short Term (due to progressive mining)

Local Slight LOW - Slight LOW -

IMPACTS ON MARINE FLORA AND FAUNA

Fuel or oil spillage impacts Long Term Regional / Study

Area Severe HIGH - Moderate MODERATE -

Episodic storms and shipwreck Long Term Study Area Very Severe HIGH - Very

Severe HIGH -

Collisions with marine fauna during transhipment

Medium Term Study Area Moderate MODERATE - Slight LOW -

IMPACTS ON SOCIAL ENVIRONMENT

The expansion of infrastructure and service provision

Medium Term Study area Moderate Beneficial

LOW - Very

Beneficial HIGH -

Loss of recreational facilities Long Term Study area Very Severe VERY HIGH - Severe HIGH -

Loss of mooring facilities for fishing boats

Long Term Study area Very Severe VERY HIGH - Moderate MODERATE -

IMPACTS ON THE USE OF NATURAL RESOURCES

Danger to shipping traffic Long Term Study area Severe MODERATE - Moderate MODERATE -





Noise impacts on beach/landing area users

Medium Term Study area Moderate MODERATE - Slight LOW -



1.3 Rehabilitation and Biodiversity Offsets Programme Toliara Sands will implement an alternative rehabilitation strategy (such as providing woodlots and agricultural land with ecological corridors linking one side of the mine to the other) in conjunction with biodiversity offsets that include the improved management and rehabilitation of priority areas within the PK32 conservation area. In addition mitigation measures, such as working with the communities to improve existing farm practices and improving the distribution of irrigated water from the canal. For the offsets and rehabilitation strategies to be effective in the long term, it is important that these are done in concert with a range of mitigation measures, since the mitigation measures will reduce the impact that the local communities are having on the surrounding natural vegetation. This combined strategy has the advantage of combining sustainable land uses with the conservation of priority areas, thereby providing a more meaningful contribution to the preservation of the area. Since the ecological assessment defined this area as a “critical habitat” it is important to bear in mind that the IFC standards require a net gain for biodiversity. Table 16.4 summarises the benefits and challenges associated with rehabilitating the area back to natural vegetation, using the offset strategy and using a combined approach. Table 1.2: Summary of benefits and challenges associated with rehabilitation, biodiversity offsets and a combined strategy

Impact Rehabilitation (to natural vegetation)

Offsets (conservation)

Combined Strategy (Rehabilitation,

biodiversity offsets and mitigation measures)

Loss of biodiversity, habitat fragmentation and edge effects.

Small-scale, likely to be lost again due to current land use impacts.

Allow for preservation of a section of biodiversity protected from current land use and potential future mining. Partnership with MNP. Could result in islands of biodiversity.

Actively conserves areas of high biodiversity and alleviates pressure on indigenous patches outside of the conserved areas.

Influx of people and increased pressures on natural resources

Small-scale, likely to be lost again as land use pressures increase.

Prevents harvesting of resources in the protected area through improved management. Areas of indigenous vegetation outside of conserved area likely to be lost with increasing land use pressures resulting in islands of biodiversity.

Addresses the needs of the community through the provision of sustainable land practices, actively conserves areas of high biodiversity and alleviates pressure on areas of high biodiversity outside of conserved areas.

Harvesting of natural resources

Small-scale, likely to be lost again due to the current land use.

Prevents harvesting of resources in the protected area through improved management.

As above.

Clearing of land for farming activities

Small-scale, likely to be converted to farming practices after vegetation has been harvested

Prevents actively conserved areas being transformed into agricultural land.

Educates the local communities in sustainable land use, alleviating the pressure on areas of high biodiversity

The use of either the rehabilitation or biodiversity offset strategies independently will not provide a long-term sustainable solution to the current land-use pressures facing the project area and immediate surrounds. Rehabilitating the mine to indigenous vegetation will only



“fix” the footprint of the exact mining area and this vegetation is likely to be harvested for charcoal and building materials at a later date. Conserving an area without addressing the current land use practices will result in areas outside of the conservation area being harvested until all natural resources are depleted, leaving an “island” of biodiversity within the conservation area. This in itself has implications for ecosystem services. It is therefore important that a combined strategy (Offsets and Rehabilitation) be considered. This combined strategy will not only aid in the conservation of biodiversity in a protected area but will also address the needs of local stakeholders through the implementation of sustainable land use practices such as woodlots. This will have the added benefit of alleviating pressure on the intact vegetation that occurs outside of the conserved area. 1.4 The Way Forward Once ONE has received the ESIA, the document is checked for completeness, a Technical Evaluation Committee (TEC) is established to review the ESIAR and public disclosure of the ESIAR is initiated (Figure 1.1). Within fifteen working days from the receipt of the EIA report, the report of public review and the technical opinion of the Technical Evaluation Committee (CTE) by the authorities, according to Article 27 of Section III (Environmental Review), Number C – “Granting of the Environmental Permit”, the Minister responsible for the environment must pronounce in favour of, or against, the granting of the environmental permit. This permit shall accompany each request for authorization of a listed activity.

Figure 1.1: Environmental Impact Assessment Program in Madagascar

WE ARE HERE

Determine if an EIA or an ECP is required

Compile EIA

Submit EIA to ONE

EIA review undertaken by ONE

Public Disclosure

Technical Evaluation Committee

Authorization

Environmental Permit issued by ONE

ONE ensures monitoring and control of ESMP

Environmental Audit

Closure Certificate



2. RESETTLEMENT AND COMPENSATION ACTION PLAN (PAR) 2.1 Introduction This chapter presents the provisional and indicative Phase 1 Resettlement Action Plan (RAP) process requirements applicable to the Ranobe Project. This section serves to detail the process and resourcing requirements for the RAP, and provides a phasing and deliverable framework for the process. It further describes the RAP processes and requirements for both resettling one community in the mine area, as well as those communities potentially affected by the proposed haul route to Toliara, and the La Batterie beach project infrastructure. Physical resettlement and economic displacement are to be experienced by one Project Affected Community (PAC) in the mining area. The village of Antsilo, comprising 15 households, and 90 Project Affected Persons (PAP) is located within the mine lease area within close proximity to the proposed construction camp and Mineral Separation Plant. Some of the Antsilo households also lie within the anticipated mine path and this will require their physical resettlement, those falling outside the mine path would also require resettlement for health and safety reasons due to their proximity to the proposed mine infrastructure and also to preserve the social integrity of this community (families, livelihoods and other social connectors) wherever it is relocated As per the findings of the Social Impact Assessment (SIA) conducted in 2012 as part of the ESIA process it was determined that the standard of living in Antsilo is low, with the overwhelming majority of homes constructed from mud and wattle, or grass and Typha. The majority of the household members are farmers, with all households interviewed practicing agricultural production - cropping for personal consumption and for sale - with maize and cassava as the primary crops, followed by beans and sesame. Rudimentary cropping practices are employed – the use of hoes or draught-animals and reliance on rain-fed agriculture. Although these households have been described as temporary households by their inhabitants, most households have occupied the area for well over a decade, and some have inherited the land they now reside on and farm. The PAC and individual households that require physical resettlement will be subject to the Phase 1 RAP compensation process, the principles of which are detailed in the sections that follow. A Phase 2 Right of Way / Jetty Compensation Plan for landowners or users affected by project infrastructure (haul roads and new jetty facilities), will also be developed as a separate document and implementation process, however, this will follow the requirements and objectives of the general RAP frameworks and guidelines presented in this chapter. A brief discussion on both the Phase 1 and Phase 2 implementation requirements concludes this chapter. 2.2 Objectives of the Phase 1 Resettlement Action Plan Physical resettlement or economic displacement can result in fundamental risks to individuals and communities such as landlessness, marginalisation, food insecurity and even social dislocation. Many past resettlement practices have ignored the rights of the displaced population, and left many having to deal with these fundamental risks. Resettlement guidelines and frameworks have been developed by various institutions where involuntary resettlement is applicable, and best practice implies that affected communities and persons should be:

Compensated for any attendant loss of livelihood;

Compensated for loss of assets at replacement costs;



Provided with the opportunities to share project benefits through direct employment and community based development initiatives sponsored by the project proponent; and

Be assisted in case of relocation or resettlement. The paramount purpose is to restore (or maintain) the income-earning capacity of these communities. The aim is to improve or, at the very least, maintain the living conditions of these persons prior to project operations or resettlement. Ultimately, affected persons must be no worse off than prior to resettlement. The following section provides an overview of the most important international guidelines and frameworks that will be considered in the RAP process to be conducted. 2.3 International Guidelines and Frameworks Some of the most important objectives of a RAP are to identify the full range of people who are affected by the project and to justify their displacement, after alternatives have been considered to minimise or avoid displacement. Inherent in the RAP is public consultation and disclosure of the RAP. In other words, it is a requirement that TS, prior to any commencement of construction activities, complete any involuntary resettlement-related measures through detailed and planned stakeholder and public consultation. The World Bank established its OP (4.12) on Involuntary Resettlement in 2001 (revised in 2011) with the objective of providing clear guidelines for projects to deal with involuntary resettlement in such a manner as to avoid possible negative social and environmental consequences (World Bank, 2011). The primary guidelines of the World Bank policy are to avoid involuntary resettlement where feasible, or at least to minimise such resettlement where possible, whilst exploring all viable alternative project designs. Involuntary resettlement guidelines provided by the bank include the directive that displaced people be assisted to improve their livelihoods and standards, or at least restore it. It calls for resettlement programmes to be executed in a sustainable manner so as to provide benefits to the affected communities and people. These need to be implemented in a manner that allows for affected people and communities to be consulted and engaged with, ensuring their participation in the planning and implementation phases of the resettlement programme. The International Finance Corporation (FC) is a member of the World Bank Group, and is one of the largest development financing institutions focussing exclusively on the private sector in developing countries (IFC, 2012a). It was established in 1956 and works in developing countries to foster economic development and employment opportunities, generate tax revenue and improves corporate governance. Importantly, it has a strong emphasis on ensuring that projects contribute to the upliftment of its countries’ local communities, without resulting in significant environmental and social impacts. The IFC published its Performance Standards (PS) on Environmental and Social Sustainability in April 2006, and published comprehensive Guidance Notes in July 2007. The PS and Guidance Notes have been revised in 2012. The following land acquisition and involuntary resettlement guidelines of the IFC PS 5 are applicable:

Assistance and compensation shall be provided for all assets lost at full replacement costs for project-affected persons to restore or improve their previous living conditions. For losses that cannot be valued, in-kind compensation may be appropriate;

Land-based livelihoods will also be compensated for, where feasible, or compensated with replacement land with qualities at least equivalent to their previous land;

All efforts should be made to compensate replacements for houses/structures with an



area similar or better. Costs included need to be for labour and transaction costs (registration, transfer of taxes, moving etc.);

All efforts should be made to facilitate continuous access to natural resources. If cash compensation is inevitable, this should be of market value;

Acquired land will only be taken after: o Compensation has been offered; o (If applicable) resettlement sites provided; and o (If applicable) resettlement assistance provided.

Displaced people will derive development benefits from the project. For land-based livelihoods, recommendations could include: o Assistance with access replacement land; o Physical preparation of farmland; o Fencing for pasture or cropland; o Small-scale credits; o Veterinary care; and/or o Access to markets.

Affected and host communities will be extensively consulted through the development and implementation of a Stakeholder Engagement Plan (SEP);

Vulnerable groups should be identified and incorporated in resettlement or technical working group committees;

Livelihood restoration and resettlement shall include options and alternatives;

Disclosure of information and participation with the affected communities will be continuous throughout the project’s lifecycle;

A Grievance Mechanism will be established as early as possible;

Where involuntary resettlement is unavoidable, a census shall be conducted to: o Collect socio-economic baseline data; o Identify persons who will be displaced; and o Determine compensation and assistance eligibility2.

A cut-off date for compensation eligibility will be set and will be well-documented throughout the project area;

Procedures will be established for a RAP/Livelihoods Restoration Plan to be monitored and evaluated with consultation of the affected persons;

If applicable, resettlement and location option choices will be offered and relocation assistance provided;

Full replacement costs will be offered to economically displaced persons who will lose assets or access to such assets;

Where business structures are economically affected, the owners shall be compensated for re-establishing the business elsewhere, transitional lost net income during the establishment and costs for the transfer/reinstallation of structures/equipment etc.;

Economically displaced persons without formal rights to land will be compensated for lost assets other than land (crops, infrastructure/improvements to the land etc.); and

For natural resource-based livelihoods, continuous access to natural resources shall be ensured or access to alternative resources with equivalent income-earning potential shall be provided.

Also relevant to the project are the prescriptions of IFC PS 8: Cultural Heritage. PS 8 recognises the importance of cultural heritage for current and future generations. Consistent with the Convention Concerning the Protection of the World Cultural and Natural Heritage, this PS aims to protect irreplaceable cultural heritage and to guide clients on protecting cultural heritage in the course of their business operations. The main objectives of PS 8 are

2 This census was conducted during June and November 2012 and all PAPs potentially subject to

resettlement have been identified.



therefore to:

Protect cultural heritage from adverse impacts of project activities and support its preservation; and

Promote the equitable sharing of benefits from the use of cultural heritage in business activities.

The project does not intend to utilise any features of heritage value or significance, however, features of heritage significance will be affected by the project. Accordingly, this PS is considered relevant to this project, and a comprehensive Heritage Management Plan that must be developed to mitigate and mange any future potential discoveries of features of heritage significance on site. The implementation of the actions necessary to meet the requirements of this PS is managed through the client’s Environmental and Social Management System (ESMS), of which the required Heritage Management Plan will be an integral component. This management plan requires the establishment of a Chance Find Procedure that dictates the process to be followed, and mitigation actions to be implemented, if any cultural or heritage artefacts of significance are identified on site. What is important to note is that the required community and stakeholder engagement process conducted in the RAP preparation and implementation phases will serve to develop what are socially and culturally accepted mechanisms for dealing with these heritage artefacts and sites. The management actions, and if necessary, relocation protocols for these sites and artefacts will have to be developed in conjunction with the affected communities and relevant government role players. 2.4 Key Components of the Resettlement Action Plan The following key aspects and components will form the key chapters and management commitments to be contained in the Phase 1 RAP:

2.4.1 Project Description and Objectives of the Resettlement Action Plan

In this section of the RAP report, the project and its components will be clearly defined, as well as the boundaries of the area to be included. Moreover, the objectives of the RAP will be outlined.

2.4.2 Physical and Economic Displacement

As part of the introduction sections of the document, the forecasted physical and/or economic displacement issues will be introduced. For example, physical resettlement of the Antsilo community, graves or tombs and culturally significant sites (cultural heritage), possible economic displacement of surrounding farms and farmers, as well as affected productive tree species (such as fruit trees) will be listed in table formats. This data can be used by TS to develop alternative construction and operational schedules to minimise involuntary resettlement and/or economic displacement where possible. The data for the physically affected households has already been obtained.

2.4.3 Legal Framework and Guiding Principles

This section of the RAP will describe all the relevant laws, policies and regulations that are relevant to the resettlement and/or compensation activities associated with the project. For this purposes, TS will work closely with the Government of Madagascar (GoM) and local stakeholders to ensure that all the national laws are adhered. In addition, the core principles of resettlement as defined by contemporary standards will be outlined.



2.4.4 Socio-Economic Context The socio-economic context of the PACs have already been obtained through a Social and Economic Baseline Survey (SEBS) conducted for the specialist social impact assessment report for the ESIA process (household surveys conducted for the Social Impact Assessment in June 2012). This has been supplemented by additional agricultural and asset inventory surveys conducted by TS over Q4 2012 and Q1-2 2013 for both the mine site communities, as well as those whose land or existing use rights may be impacted on by the proposed haul road and jetty infrastructure in the Toliara area.

2.4.5 Consultation, Participation and Grievance Mechanism As part of the consultation and public participation process, two stakeholder engagement processes will be conducted as part of the Phase I RAP, namely RAP-related workshops and meetings as part of a Resettlement Working Group (RWG), as well as the establishment of a Grievance Mechanism (both explained below). A RWG will be established at RAP initiation, comprised of TS, local government and leadership, supporting third-parties as well as PAP/PAC nominated representatives.

2.4.6 Eligibility Criteria and Entitlements By means of the RWG and associated workshops, the affected persons who might choose to be resettled, or who will be affected by economic displacement (i.e. losing assets, investment, land, natural and/or economic resources) will be identified. Based upon these discussions, an entitlement matrix will be included in the RAP which describes the affected population in terms of categories, compensation entitlement and additional support needed (such as assistance or disturbance allowances). The following possible items need to be listed in this matrix:

All losses associated with particular categories, such as the loss of physical assets, loss of public assets or culturally significant sites; and

All types of compensation and assistance to which each PAP is entitled to, which include compensation for or replacement of land and natural resources, compensation for structures etc.

Specific attention will be paid to vulnerable groups, such as the elderly, women (particularly female-headed households) and youth. For example, the entitlement framework will have to ensure that compensation entitlements are issued in the name of both spouses. A range of other methods can be implemented to also reduce the workload of women and vulnerable groups (especially the disabled), such as the provision of wells and hand pumps, or improving healthcare services.

2.4.7 Determination and Negotiation of Entitlement and Compensation Framework

Process This section of the report will detail compensation that affected parties are entitled to for different categories of displacement. Much of this information will be obtained through the RWG workshops. The agricultural and asset valuation surveys already undertaken by TS, along with the household surveys conducted for the Social Impact Assessment (2012) will also be used as the inventory basis. Based upon such a valuation, the payment of compensation will be the responsibility of TS in collaboration with the Government of Madagascar (GoM) at district and local levels. The nature of the entitlement will vary between each individual and household, and will be based upon specific entitlement criteria. These criteria need to be defined early in the resettlement process and should be agreed to by all stakeholders. Affected households, individuals and communities are entitled to



compensation based upon agreed values. Multiple compensation options should be discussed with affected parties via the RWG in order to obtain agreement on the adequacy and acceptability of the compensation package. Compensation valuations should focus on the following:

Compensation options in terms of replacement of homesteads and structures;

Land compensation; and

Options for the relocation of graves and sites of cultural, historical or religious importance.

One of the fundamental aspects of involuntary resettlement is that, where feasible and desirable by the PACs, land-based resettlement options should be provided to displaced people whose livelihoods are reliant on the use of the land (such as subsistence farmers). Consequently, the client may wish to engage in land-to-land compensation measures with the affected villages (a preference of the IFC); land which should be equivalent or superior in productive potential to the land from which the people are displaced. If cash compensation is preferred (particularly for the possible loss of cash crops), such compensation rates will be calculated in consultation with PAC representatives (and local leadership structures), as well as the GoM, and will cover full replacement cost.

2.4.8 Institutional Arrangements for Implementation

The RAP will delineate all the institutional and organisational responsibilities assigned to compensation related matters relevant to the RAP. The institutional arrangements within TS and the provision of adequate resources should be discussed and all inter-agency coordination described. The capacity and commitment of the GoM and other key stakeholders to participate in the development and implementation of the RAP should also be evaluated. If necessary, strengthening of these institutions should be considered and the steps that will be taken, together with a timetable and budget, should be described in the RAP. There should be considerable scope for involving local communities and NGOs in planning, implementing and monitoring resettlement.

2.4.9 Measures to Reduce Spatial Resettlement Impacts The RAP needs to illustrate that the project considered various planting schemes and alternatives in order to avoid having to resettle villages or affect their livelihoods. In many cases, compensation alone does not guarantee the restoration or improvement of affected villages’ living standards. An important aspect of the RWG will therefore be to develop initiatives and opportunities that the villagers are confident will meet their expectations as far as possible.

2.4.10 Social Services and Infrastructure Closely tied to the previous component, it is ideal for projects to restore or improve the livelihoods of its PACs, as resettlement or economic displacement may, in some cases, provide additional opportunities for PAPs to improve their houses, public infrastructure and social services. Various Development Financing Institutions (DFIs), such as the IFC, encourage projects to undertake resettlement as a sustainable development initiative, whereby affected villages can also benefit from the project. It is recommended that the project proponent also outlines its programme in the RAP to provide social services and/or services to the PACs, on the understanding that these will be developed over time in consultation with affected communities as priorities and viable projects are identified.



2.4.11 Monitoring and Evaluation (M&E) As part of any resettlement work and related compensation measures, DFIs require projects to continuously monitor and evaluate the RAP process. The sponsor needs to be provided with feedback on the RAP implementation process, for which purposes this RAP will need to provide a coherent monitoring plan that can identify the relevant TS and government responsibilities, the methodology used for compensation, and schedule for this monitoring and reporting. Additionally, the RAP performance milestones need to be communicated to the PACs, stakeholders and relevant government officials through public meetings. A monitoring plan will thus be included in the RAP, designed to be undertaken at two levels. These include internal monitoring, as well as external independent monitoring. Internal monitoring will be an internal management function of TS, which will allow TS to measure its physical progress against the milestones set-out in the RAP. External monitoring also needs to be conducted by an independent consultant in the form of regular audits.

2.4.12 Implementation Schedules and Budgets An implementation schedule, which includes a timeline for compensation payment and delivery of entitlement to each category of eligible people, will be included in the RAP. Moreover, a budget needs to be included which can be based upon an estimation. It is foreseen that this budget will primarily include estimated allowances for farmland acquisition, crop and food tree prices (as established by the GoM and consultation with PAPs and other key stakeholders). According to the IFC Handbook for Preparing a RAP, resettlement costs need to be itemised by categories of impact, entitlement, and other expenditures including training and monitoring. The RAP budget will be linked to a detailed implementation schedule for all the activities proposed by the RAP. Some additional key factors that need to be included are:

Resettlement Planning: Define overall strategy in terms of resettlement, likely phasing and means of compensation. Further consideration will be needed in terms of construction of any resettlement structures, labour and other issues;

Scheduling: Define timing for resettlement in terms of the physical resettlement, payment of any cash compensation and ensure it aligns with any civil engineering required by the project;

Budget: Resettlement costs are often underestimated and thus detailed budgeting/costs for the implementation of the resettlement should be provided; and

Role and Responsibilities: Organisational structures and responsibilities must be clarified prior to resettlement. This includes all actions that must be adopted by relevant stakeholders including, amongst others, the proponent and government departments.

2.4.13 Moratorium and Interim Disputes Committee

Once the results of the asset valuation exercise have been disclosed to the PAPs, a

moratorium will be declared (on a mutually agreed date – the “cut-off date”) that restricts the

construction of new buildings/structures in the project displacement areas (apart from

routine maintenance activities). Experience shows that the moratorium needs to be

supported by the asset holders (PACs/PAPs), and the appropriate cut-off date agreed to by

them. Further, agreement will be reached with the client and the local authorities (especially the

local and district leadership) 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. This

process will have to be aligned with the anticipated ‘stage by stage’ nature of the

resettlement. However, the following process, allied to the RWG and Grievance Mechanism,

is suggested:



Individuals or groups that wish to lodge a complaint, dispute or grievance will be allowed to lodge their complaint with the RWG.

The RWG will have a set time (possibly 15 days) from receipt of the dispute or grievance to act upon it.

The group will be provided with the appropriate level of training by TS, with the supervision of an external RAP specialist.

All grievances lodged, and corrective actions implemented, will be documented and be publically available. The efficacy and efficiency on the Grievance Mechanism will be subject to on-going monitoring and evaluation throughout the RAP implementation.

2.4.14 Income Restoration and Sustainable Development Initiatives Economic displacement and the disruption of livelihoods are often ‘invisible’ impacts of resettlement. In essence, resettlement may lead to the disruption of income-earning capacity or livelihood strategies such as subsistence farming. Often, the restoration of income streams and livelihoods lost during the resettlement are difficult to value and thus often overlooked. To the extent which TS resettles or acquires farmland, the resettlement process will need to be undertaken as a sustainable development initiative, i.e. an initiative that improves the standard of living of PAPs. This will act as a means of restoring and, if possible, improving economic opportunities and promoting long-term development. The overall aim of any initiative is to ensure that the affected people’s livelihoods and living standards are restored as closely as possible or they are better-off than they were prior to resettlement.

2.4.15 In-migration and Population Influx Management

The influx of job seekers is always likely to be an issue in projects like the Ranobe mine.

While the mine can exercise control over who it employs and how it communicates the

recruitment process, it generally can do nothing about the secondary employment that

springs up alongside the formal employment opportunities. In some cases these

opportunities are both welcome, while in other instances they are less desirable. Large scale

in-migration, particularly in rural areas, can lead to significant social and economic change.

This growth can place a strain on already limited social infrastructure, services, land

availability and natural resources. This can potentially lead to the inflation of prices of fresh

produce, fish, and other commodities, which although could be construed as a positive

impact for those selling such food products and commodities, is a significantly negative

effect for those who cannot afford the increase in prices. In summary, in-migration on a large

scale may:

Create housing and/or land markets and disrupt traditional land tenure systems;

Create tension and conflicts between locals and migrants concerning natural resources and employment opportunities;

Increase the incidence of so-called social ills, including prostitution, alcohol abuse, and crime;

Result in increasing inequalities in terms of income and wealth accumulation between locals and migrants; and

Disrupt social dynamics, for example, gender and age relations.

Currently there is no Madagascan legislation that defines the mechanisms that project

developers need to put in place to control an influx into areas adjacent to their operations.

This is more explicitly a requirement of the IFC Performance Standards that require

mitigation of this risk, namely:



PS 1: Social and Environmental Assessment and Management System: Influx management requires that the objective of minimising project or project-induced impacts on workers and affected communities be observed

PS 2: Labour and Working Conditions: Influx management should address access to jobs and procurement, ensuring non-discrimination and equal access. It should also uphold company commitment to local recruitment.

PS4: Community Health, Safety and Security: Influx management should contribute to the reduction of influx-related threats to community health and safety.

PS5: Land Acquisition and Involuntary Resettlement: Using the tools of resettlement planning, influx management should address the risk of opportunistic land invasion and / or un-entitled access to compensation.

As such while the mine may be a catalyst for influx it is restricted in terms of the mechanism

that it can employ to respond. TS cannot restrict the free movement or association of

Malagasy citizens who can exercise a right to migrate and settle where they please. While it

may be argued that population influx is an unavoidable consequence of project development

and that it is thus beyond the control of developers, the IFC guidelines on project-induced in-

migration point out that there are a number of factors that companies need to take heed of in

such circumstances.

In addition, TS need to recognise that the national or local governments are not likely to play

a significant role in managing this potential population influx, and will therefore need to

decide on a strategic response to this concern in the form of an influx management plan that

will be developed as part of the overall RAP process. In summary, the plan will have to:

Coordinate a response to the influx of people into the project area (defined as the

mine and immediate surrounding villages) so that the quality of life of those residents

in the villages is not compromised and that the risks identified in the ESIA are dealt

with in a responsible and pro-active manner.

Determine and delineate responsibilities for influx management so as to ascribe roles

that are an appropriate reflection of the borders between the activities of a) local and

national government, and b) Toliara Sands.

Satisfy the parameters of the IFC PS 1 that requires that the objective of minimising

project or project-induced impacts on workers and affected communities be

observed through appropriate Influx management

Satisfy the parameters of IFC PS 2 in ensuring that influx management should

address access to jobs and procurement, ensuring non-discrimination and equal

access and uphold company commitment to local recruitment.

Satisfy the parameters of IFC PS4 in contributing to the reduction of influx-related

threats to community health and safety.

Satisfy the parameters of IFC PS5: by addressing the risk of opportunistic land

invasion and / or un-entitled access to compensation.

The framework influx management plan will be presented to all stakeholders for

consideration as part of the final RAP disclosure process.

2.5 RAP Roles and Responsibilities

2.5.1 Overview TS must provide the financial resources necessary for the resettlement and compensation process, and will also provide additional managerial and technical expertise during its



implementation and evaluation phases. The role of TS may be broken down into two distinct phases, namely: i) pre-implementation; and ii) implementation. This is conceptual and will be further refined during the resettlement planning phase.

2.5.2 Pre-Implementation Role Should the unforeseeable need arise to initiate compensation packages, during pre-implementation, TS will:

Collect all the asset valuation data required (as explained above);

Draw-up the Terms of Reference (ToR) and contract all major planning services needed to effect the resettlement;

Present, discuss and obtain approval for any developed land-use plans;

Ensure that, as necessary, the RWG remains functional in the period following the finalisation of the Phase I RAP and leading up to project implementation; and

Attend RWG meetings, and provide administrative support and ad hoc managerial and technical support as required.

The need for pre-implementation compensation will be established within the first 2 meetings of the RWG. However, as noted it is not expected to be required during pre-implementation activities, as these should not impact on the Antsilo communities existing lifestyle and livelihood strategies.

2.5.3 Implementation Role

In the implementation phase, TS will finance the implementation of the RAP. This will be done via the establishment of a dedicated RAP team. The team will have as its primary responsibilities the following:

Drawing up offer documents for each household/individual affected;

Discussing terms and conditions of resettlement with each affected household/individual;

Managing compensation and resettlement payments;

Providing technical and managerial input to RAP implementation;

Establishing a socio-economic monitoring program for the affected households;

Identifying households/individuals that are suffering post compensation or assistance as a result of the resettlement impacts of the project and, together with the RWG, defining and implementing appropriate corrective action;

Attending RWG meetings and providing support and input as and when required;

Addressing compensation and resettlement grievances through the Grievance Mechanism;

Establishing and managing a local employment committee to ensure the maximisation of employment opportunities for the local community and particularly for those households directly affected; and

Defining and implementing community development and monitoring programs to ensure that affected households/individuals are not worse off in the post-implementation phase. Such a monitoring program should be undertaken by the same fieldworkers who administered the SEBS, as these fieldworkers are familiar with the project area and social survey process.

Ensuring compliance with the resettlement and social commitments contained in the ESIA, and ultimately, the RAP reporting will be the responsibility of TS’s Corporate Social Responsibility (CSR) Manager, who will be responsible for securing and maintaining TS’s social license to operate, that will entail the following areas of oversight and responsibility:



Recruit and manage the TS community and social team members for the following functional areas: o Resettlement planning; o Community relations and liaison; and o Community development.

Develop and administer budgets for all RAP and community liaison activities;

Implement social aspects of recruitment and procurement policies; and

Develop and execute additional needed policies for all operational areas of responsibility.

The CSR Manager will be responsible for overseeing all resettlement initiatives. The CSR Manager will be supported by team leaders (to be appointed by TS) in the primary functional areas of resettlement planning, community development and community relations, each of whom will have the requisite staff and material support to achieve their mission. Over the above, a CSR Mentor based in TS’s office in Toliara will provide strategic oversight and assistance to the CSR Manager who will also be based locally in Toliara. Additional roles and responsibilities applicable to all relevant personnel will be outlined in the Phase I RAP, however, a brief description of the staffing and personnel resource requirements is provided in the following section.

2.5.4 Government of Madagascar (GoM) TS need to work in close collaboration with the local authorities (regional, district, commune and fokontany level) and traditional leaders, as well as any other ministries or departments who will, or should, represent the GoM. It is envisaged that nominated GoM representatives will constitute some the RWG representatives, and will have the following key responsibilities:

Act as the primary government representatives;

Assume a mandated function within the RWG. This is necessary as the government will act as a regulator to ensure that the peoples’ rights are not violated;

Ensure that the GoM supports TS in providing assistance to relocated households/individuals as and when required;

Ensure that the moratorium on settlement within the project area, once it is formally announced, is observed; and

Ensure compatibility of the resettlement process with overall development visions for the area.

At this time it is foreseen that one District level government representative will be included in the RWG, as well as the Commune Mayor and local leadership representatives of the Antsilo community. It is expected that the Regional level government will be kept informed of all developments and processes associated with the RAP, but will not be represented on the RWG. 2.6 Proposed Phase 1 RAP staffing requirements This section briefly describes the resourcing requirements for TS to effectively implement the RAP (phase 1 resettlement, as well as the Phase 2 Right of Way Compensation Plan). Aside from the two key senior positions, that of CSR Manager and CSR Mentor, a description of the various units responsible for the various RAP functions is also presented (refer to Figure 2.1).



2.6.1 Corporate Social Responsibility (CSR) Manager: As noted above, the TS CSR Manager (based in Toliara) will assume overall responsibility for the RAP development, implementation and monitoring thereof.

2.6.2 CSR Mentor The CSR Mentor will be Toliara based and will provide the necessary strategic input and advice on a needs basis throughout the RAP implementation lifecycle. The external RAP consultants will similarly assist in providing guidance as and when this is required.

2.6.3 Community Relations There will be eight Community Liaison and Relations Officers (CLO’s) housed in the Community Relations unit, who will be responsible for individual aspects or components of the overall project. As reflected in Figure 6-1, there will be two CLO’s dedicated to the mine site, haul road, jetty (La Batterie) area, as well as Toliara town itself. They will be responsible for daily engagement with stakeholders and PACs, as well as serve as the first point of contact for any grievance identification and resolution.

2.6.4 Compensation & Resettlement The Compensation and Resettlement unit will be tasked with the bulk of the Phase 1 and Phase 2 compensation activities. Four personnel will deal with the land and crops compensation aspect which is of greater relevance to the haul route and La Batterie communities, with two personnel dedicated solely to the Phase 1 RAP requirements dealing with the resettlement of the Antsilo community.

2.6.5 Benefits and Social Investments This unit will be responsible for the sustainable development and CSR initiatives to be developed and implemented by TS.

2.6.6 Compliance Monitoring and Evaluation This unit will be responsible for overall monitoring and evaluation of the RAP implementation. Personnel will be expected to conduct ongoing monitoring of the RAP in accordance with the overall project monitoring programme requirements, but also those specific to the RAP implementation.



Figure 2.1: TS Corporate Social Responsibility staff organogram

The final staffing designations and detailed responsibilities will be presented in the Phase 1 RAP. 2.7 Indicative RAP development schedule It is estimated that the Phase 1 RAP will be developed within a five month period from its initiation. At this time it is unclear whether the options of resettling the Antsilo community prior to the commencement of construction activities, or in the period before actual mining operations commence will be more suitable, but will be one of the primary issues for initial discussion and consideration by the RWG. Reflected in Table 2.1 below is the estimated timeline and activities associated with each core component and requirement of the Phase 1 RAP. Table 2.1: Anticipated Phase 1 RAP development schedule Meeting Number

Month Actions Outcomes

1 1

RAP inception/initiation meeting with resettler community.

Establish RWG functions and explain need for election of RWG representatives.

Explain RAP process and need for entitlement matrix (who is compensated and how) and cut-off date (up until when are people eligible for compensation).

PAPs/PAC introduction to the RAP process and requirements.

Identification of potentially entitled PAPs/PACs

Request for consideration of an appropriate cut-off date

Request for RWG to be finalised at next meeting (Meeting 2)

2 1 Confirmation of elected RWG

members.

Presentation of PAC agricultural and

Confirmation of entitlement matrix and cut-off date (or at Meeting 3).



Meeting Number

Month Actions Outcomes

asset inventory surveys.

Presentation and finalisation of preliminary entitlement matrix.

Preliminary discussions on what compensation strategies are to be considered at next meeting for discussion.

Discard compensation options that are deemed to be unsuitable or least preferred by RWG/PAC (Antsilo).

3 1

Present draft Stakeholder Engagement Plan (SEP) & Grievance Mechanism.

Present preferred compensation strategy alternatives for further detailed discussion to assess the opportunities and constraints associated with each option.

Confirmation of entitlement matrix and cut-off date (if not concluded in Meeting 2).

Identification of preferred compensation options for full analysis and preliminary development.

4 2

Present final Stakeholder Engagement Plan (SEP) & Grievance Mechanism.

Ongoing discussions and consideration of preferred compensation options.

Approval of SEP and Grievance Mechanism.

5 3

Present draft monitoring and evaluation (M&E) programme and Key Performance Indicators (KPIs).

Presentation of preferred compensation options and strategies, with a selection of a final compensation mechanism/s as nominated by the RWG/PAC.

Nomination of preferred compensation mechanism for finalisation.

Adjustments to the M&E programme methodology and KPIs as are necessary.

6 4

Present the finalised preferred compensation mechanism, budgets and implementation schedules.

Finalise M&E programme and indicators.

Approval of preferred compensation mechanism.

Approval of M&E programme and KPIs.

7 5 Final RAP disclosure and discussion. Final RAP approval by RWG.

Depending on the complexity of the various compensation mechanisms to be considered in the process it may be that the time required to develop the RAP can be shortened, but ultimately depends on the ability of the RWG to make informed and timeous decisions on compensation mechanism preferences and other process related requirements. 2.8 Phase 2 Right of Way Compensation Plan As noted above, a two phased approach to the RAP has been proposed; Phase 1 dealing with all communities and dwellings to be found in the Mine Social Footprint, mainly the Antsilo community, while Phase 2 will deal with the compensation strategy and affected communities along the proposed haul route and at La Batterie that will be experiencing economic displacement only. Please note that the above defined staffing and responsibilities will be similarly applicable to the Phase 2 Right of Way Compensation Plan. A local Malagasy service provider will be dealing with the surface rights negotiations and compensation processes for the PACs subject to economic displacement by the haul road and La Batterie beach infrastructure (the Phase 2 Right of Way Compensation Plan). This is a preferable option owing to the in-field time inputs required, customary and local administrative knowledge imperatives, as well as the necessary language capacity that external service providers do not necessarily have. These compensation frameworks will be developed, and initial payments paid over to entitled recipients, during the projects construction phase.



3. ENVIRONMENTAL MANAGEMENT PLAN 3.1 Environmental & Social Management Plans This Environmental Management Plan (ESMP) covers the construction, operation and closure phases of the proposed Toliara Sands Project. All contractors and sub-contractors will be required to adhere to all of the lead contractor’s environmental guidelines and standards as well as Madagascar’s legislation during the lifespan of the project. This ESMP represents the Company’s commitment to address and manage the potential negative and positive impacts associated with the proposed Toliara Sands Project, and defines the standards and guidelines to be achieved in terms of environmental legislation, policy and standards. It also outlines Toliara Sands’ management structures for the proposed project that will be implemented, and management actions or design interventions that may be required to allow significant negative impacts to be “designed out”. This ESMP therefore outlines the Company’s commitment to addressing and managing potential negative and positive impacts. Implementing the ESMP and all associated recommendations is the responsibility of the developer. The ESMP is designed to ensure that Toliara Sands and their contractors are aware of their social and environmental responsibilities, and that there is a clear record of the standards and intentions against which various parties can be held accountable. The objectives of this ESMP are to:

Ensure the project is compliant with applicable national environmental and social legal requirements.

Identify the required mitigation measures that are needed in order to reduce negative impacts and enhance positive ones.

Ensure that all mitigation measures and recommendations identified during the EIA are incorporated into documents that are referenced and expanded if necessary during the various phases of the project.

Outline the mitigating/enhancing, monitoring, consultative and institutional measures required to prevent, minimize, mitigate or compensate for adverse environmental and social impacts and/or to enhance project related beneficial impacts.

Address human resource requirements to ensure implementation of the ESMP is possible.

Develop relevant documents that will facilitate the implementation of the ESMP. To achieve the above the ESMP ensures that:

During project planning and design, all mitigation measures identified in the EIA that can be incorporated into the planning and design of the project are considered during the detailed planning and design phase.

During construction all constraints, restrictions and actions required to minimize construction related impacts are implemented.

During commissioning and operation, detailed operating procedures are developed so that all constraints, restrictions and actions required to minimize impacts caused by commissioning and operation are developed, implemented and monitored for all aspects of the project.

During the life of the project continue to enhance positive impacts and ensure mitigation for negative impacts. An important component of this is monitoring, evaluation and communication of findings, and adherence to the principle of continued improvement.



During decommissioning, detailed procedures are developed to ensure that the project area is rehabilitated to an acceptable and previously agreed-to level.

3.2 Management Structure

3.2.1 Toliara Sands Management Structure and Reporting The generic key management positions to manage the ESMP are discussed below. The actual titles used for each position and the precise responsibilities may change during the final design phase. Any changes required by ONE as a condition of environmental authorisation for the Ranobe Mine Project will be reflected in the final ESMP.

3.2.2 Toliara Sands – Construction Manager (TS-CM) The role of the TS-CM will be to ensure that all personnel on site abide by the requirements of the ESMP and that all areas of the project are constructed and operated in such a manner that they meet all specified legal and contractual environmental requirements. The TS-CM is the most senior figure on site.

3.2.3 Toliara Sands – Technical Managers (TS-TM) The role of the Technical Managers will be to ensure that all areas of the project are designed, constructed and operated to meet the specified contractual and legal requirements. The TS-TMs will report directly to the TS-CM.

3.2.4 Toliara Sands – Operational Environmental, Health, Safety and Community Manager (TS-EHSC)

The Toliara Sands operational EHSC Manager will also assume the construction phase oversight role. The TS-EHSC is based on site and will report directly to the TS-CM. This manager will specifically manage the EHSC issues during the construction phase and ensure that the EPCM contractor and construction contractor are meeting all the necessary requirements defined in both the Design and Construction ESMP. Both the EPCM-EHSC and EPCM-ECO (see below) will report to the TS-EHSC.

3.2.5 Engineering, Procurement, Construction Management Contractor (EPCM) Team Structure and Reporting

EPCM –Environmental, Health, Safety and Community Manager (EPCM-EHSC) The EPCM contractor will appoint an EHSC Manager. The EPCM -EHSC will be based on site and will report directly to the TS-EHSC. The EPCM-EHSC will specifically manage the EHSC issues during the construction phase and ensure that the construction contractor is meeting all the necessary requirements defined in both the Design and Construction ESMP. The EPCM-EHSC will liaise with the TS-EHSC on day to day issues and adhere to all instructions and requests relating to ESMP requirements issued by the latter.

3.2.6 Construction Contractor’s Team Construction Contractor – Environmental Site Officer (C-ESO) The exact composition of the contractor’s team can only be established once the contractor is selected. The contractor will, however, be required to appoint environmental site officers, who shall be responsible for undertaking daily site inspections to monitor compliance with the ESMP environmental specifications and management commitments. The number of officers will be established once the work packages are finalised during the final design phase. The C-ESO will be guided by the EPCM-EHSC on day to day issues, as well as



adhere to all instructions and requests issued by the TS-EHSC relating to ESMP requirements. Construction Contractor – Chief Engineer (C-CE) It is presumed that the contractor will have a chief engineer or nominated contractors senior representative on site, e.g. project manager, construction manager or resident engineer who is responsible for the delivery of the contract according to all engineering, legal, financial and environmental specifications.

3.2.7 Independent External Audit Team An independent and internationally reputable audit team must review all EHSC activities associated with the construction activities yearly. 3.3 Management Reporting Guidelines The reporting structure and in particular work stoppage guidelines will be determined in the final design phase. There must, at least, be a commitment to use commercially reasonable efforts to incorporate the below listed provisions in the contracts, and these should be considered as contractual obligations The following principles will, however, need to be adhered to:

The TS-CM is the most senior staff member on site.

The TS-CM can call a permanent stop to any activity that he deems to be having an adverse impact on the environment.

The TS-EHSC and EPCM-EHSC can call a temporary stop to any activity that they deem to be having an adverse impact on the environment.

The C-ESO can call a temporary stop to any activity that they deem to be having an adverse impact on the environment.

The C-ESO shall report to EPCM-ESO on a daily basis.

The C-ESO and EPCM-EHSC will report to the TS-EHSC on a weekly basis.

The EPCM-EHSC and TS-EHSC will report to the TS-CM and C-CE on a monthly basis in a report format to be determined by the TS-EHSC and TS-CM. Monthly progress meetings between all these parties is required in order to review compliance to the ESMP, as well as to determine the efficacy and adherence to corrective actions and measures that may be stipulated by the EPCM-EHSC, TS-EHSC, TS-CM or C-CE.

A conflict resolution committee constituted by the EPCM contractor, construction contractor and Toliara Sands management will need to be established in the final design period to ensure effective and pragmatic solutions to any environmental specification disputes are achieved. 3.4 Specific Roles and Responsibilities The roles and responsibilities detailed below must be reflected in the EPCM and construction contractor appointment contracts. There must, at least, be a commitment to use commercially reasonable efforts to incorporate the below listed provisions in the contracts, and these should be considered as contractual obligations.

3.4.1 EPCM Contractor – Environmental, Health, Safety and Community Manager (EPCM-EHSC)

The role of the EPCM-EHSC is to:



1. Ensure the implementation of the ESMP and associated activities by:

Developing construction method statements together with the construction contractor;

Monitoring and verifying that the ESMP is adhered to at all times and taking action if the specifications are not followed;

Monitoring and verifying that environmental impacts are kept to a minimum;

Inspecting the site and surrounding areas regularly to ensure compliance with the ESMP;

Assisting the construction contractor and TS-EHSC in finding environmentally responsible solutions to problems;

Reviewing the register of complaints administered by the TS-EHSC and recording and dealing with any community comments or issues that are directly related to construction activities;

Ensure that the existing Toliara Sands Grievance Procedure is appropriately implemented;

Ensure that all EPCM or construction contractor personnel coming on site attend environmental awareness training courses that will be conducted by the C-ESO;

Ordering the removal of, or issuing spot fines for, person(s) and/or equipment not complying with the specifications (done in conjunction with the TS-EHSC and/or TS-CM) - this must be reflected in the EPCM appointment contracts;

Issuing of penalties for contraventions of the ESMP (e.g. damage to “no go” areas) - this must be reflected in the EPCM appointment contracts;

Continuously reviewing the effectiveness of the actions described in the ESMP;

Ensuring that all sites disturbed during the various construction activities are effectively rehabilitated as soon as possible in accordance with the existing Toliara Sands rehabilitation plans in this regard;

Overseeing C-ESO liaison activities with local stakeholders in conjunction with the TS-EHSC and Toliara Sands Community Liaison Officers (TS-CLOs);

Ongoing liaison with appropriate project personnel;

Maintenance and management of the monitoring programme in conjunction with the TS-EHSC;

Ongoing reporting to Toliara Sands line department management; and

Recommending and/or developing corrective actions in conjunction with the TS-EHSC in the event of significant non-compliance.

2. Ensure the successful on-site implementation and supervision of public and community

consultation as it relates to construction contractor activities. Responsibilities will include:

Ensure responses to grievances raised by the community as they relate to construction activities are provided and due process followed;

Hold regular meetings with the affected community in conjunction with the TS-EHSC (as required) and TS-CLOs as part of the ongoing disclosure requirements; and

Ongoing reporting to the TS-EHSC regarding the outcomes of the community consultation processes.

3.4.2 Construction Contractor – Environmental Site Officer (C-ESO)

The C-ESO will be responsible for ensuring compliance of the ESMP on a day-to-day basis. The C-ESO duties in this regard will include the following: 1. Monitoring and verifying that the ESMP is adhered to at all times and taking action if the

specifications are not followed; 2. Monitoring and verifying that environmental impacts are kept to a minimum; 3. Producing and reviewing construction method statements together with the C-CE,

EPCM-EHSC and TS-EHSC;



4. Keeping records of all activities/incidents on site; 5. Giving a report back on the environmental issues at site meetings and other meetings

that may be called regarding environmental matters; 6. Keeping records of all activities/incidents on site in the Site Diary concerning the

environment and reporting these to the EPCM-EHSC; 7. Inspecting the site and surrounding areas regularly with regard to compliance with the

ESMP and reporting these findings to the EPCM-EHSC and TS-EHSC; 8. Ensuring that all new contractor personnel coming onto site attend the environmental

awareness training courses conducted by the C-ESO or other responsible personnel; 9. Completing start-up, weekly, monthly and site closure checklists; and 10. Keeping a photographic record of progress on site from an environmental perspective.

3.4.3 Toliara Sands – Environmental, Health, Safety and Community Manager (TS-

EHSC) 1. Ensure the implementation of the ESMP and associated activities by:

Ensuring necessary environmental authorisations and permits have been obtained;

Ensuring that activities on site comply with other relevant environmental legislation;

Ongoing liaison with National and Provincial Government agencies and regulatory authorities;

Reviewing and approving construction method statements in conjunction with the TS-CM and C-CE;

Continuously reviewing the effectiveness of the actions described in the ESMP as informed by regular review of C-ESO and EPCM-EHSC monitoring reports;

Ensuring that site rehabilitation in accordance with the existing Toliara Sands rehabilitation plans;

Overseeing C-ESO liaison activities with local stakeholders in conjunction with the TS-CLOs;

Ongoing liaison with appropriate project personnel;

Maintenance and management of the monitoring programme in conjunction with the EPCM-EHSC; and

Recommending and/or developing corrective actions in conjunction with the TS-CM and EPCM-EHSC in the event of significant non-compliance.

2. Ensure the successful on-site implementation and supervision of public and community

consultation. Responsibilities will include:

Hold regular meetings with the affected community as part of the ongoing disclosure requirements;

Guiding and supervising the Toliara Sands Community Liaison Officers (CLOs) to ensure ongoing disclosure regarding construction activities;

Provide technical and managerial support for implementation of the existing Toliara Sands Grievance Procedure;

Keeping a register of complaints at the Toliara Sands Administrative Offices and recording and dealing with any community comments or issues and ensure that Toliara Sands CLOs deal with these in the manner required by the established Grievance Procedure;

Overseeing the execution and management of the activities described in the Resettlement Action Plan (RAP) where relevant;

Ensure responses to grievances raised by the community as they relate to construction activities are provided;

Executing specific communication procedures for the different stakeholders;

Assist the Human Resources Manager in managing the Labour Desk (LD);

Assist with the implementation of the mine’s Social Development Plan;

Establish and maintain a socio-economic monitoring programme for the affected



households; and

Ongoing reporting to the TS-CM.

3.4.4 Construction Contractor – Chief Engineer (C-CE) The responsibilities of the contractor’s Chief Engineer are to ensure that all aspects associated with the specifications and intent of the ESMP is adhered to by the construction contractors. These responsibilities include: 1. Monitoring and verifying that the ESMP is adhered to at all times and taking action if the

specifications are not followed; 2. Monitoring and verifying that environmental impacts are kept to a minimum; 3. Reviewing and approving construction method statements; and 4. Ordering the removal of person(s) and/or equipment not complying with the

specifications. 3.5 Environment and Health Training and Awareness The EPCM-EHSC and C-ESO must be conversant with all legislation pertaining to the environment applicable to this contract, must be appropriately trained in environmental management and must possess the skills necessary to impart environmental management skills to all personnel involved in the contract. All personnel involved in the construction of the project must undergo a training and awareness programme on environmental management prior to commencing activities. If necessary, the current Toliara Sands procedures for environmental training must be further developed or refined by the contractor, which will lay out in detail the methodology used to present environmental awareness and induction training. The range of topics that must be covered in environmental training will include:

Toliara Sands’ Environmental policy;

Toliara Sands’ Health and Safety policy;

Toliara Sands’ Community policy;

Toliara Sands’ environmental objectives and targets;

Organisational structure and responsibilities;

Aspects of routine or day-to-day operational activities that can have environmental impacts;

Environmental hazards that could arise from non-routine situations and corrective actions;

The importance of Environmental Hazard Incident reporting and completion of appropriate reports;

Channels of communication for discussing and reporting environmental issues;

Documentation systems so that appropriate records of environmental matters are maintained; and

Responsibilities under the applicable legislation. A training needs analysis will be conducted by the C-ESO and EPCM-EHSC (and approved by the TS-EHSC) to identify the appropriate environmental and health training programmes, and the appropriate target groups amongst the employees of the contractor. The results of the environment and health training needs analysis shall be filed with the environmental records and used to set objectives and targets. Recommended basic environmental education material is provided in Annexure B of this report. The environmental training should, as a minimum, include the following:



The importance of conformance with all environmental policies;

The significant environmental impacts, actual or potential, as a result of their work activities;

The environmental benefits of improved personal performance;

Their roles and responsibilities in achieving conformance with the environmental policy and procedures, and with the requirement of Toliara Sands’ environmental management systems, including emergency preparedness and response requirements;

The potential consequences of departure from specified operating procedures;

The mitigation measures required to be implemented when carrying out their work activities;

The importance of not littering and using the ablution facilities provided;

The need to use water sparingly;

Details of, and encouragement to, minimise the production of waste and re-use, recover and recycle waste where possible;

Details regarding archaeological and/or historical sites which may be unearthed during construction and the procedures to be followed should these be encountered; and

The procedures which should be followed should a grave be encountered, or unearthed during the construction phase.

Information will be transferred in an appropriate manner. Training courses must take language and cultural and education levels into consideration. The site Environmental Handbook must be updated and distributed to all literate personnel, in both the English and French languages. Where possible this must also be translated into the indigenous language (Malagasy) of the area. This handbook must cover some of the information presented in the Environmental Awareness and Induction Training. Handouts must also be available to personnel and posters will be displayed in easily visible venues - in both English and French. Environment and health awareness training programmes should be targeted at three distinct levels of employment, i.e. the executive, middle management and labour. Environmental awareness training programmes should contain the following information:

The names, positions and responsibilities of personnel to be trained;

The framework for appropriate training plans;

The summarised content of each training course; and

A schedule for the presentation of the training courses. The contractor shall ensure that records of all training interventions are kept in accordance with the record keeping and documentation control requirements as set out in this ESMP. The training records shall verify each of the targeted personnel’s training experience. The TS-EHSC shall monitor the records and listed and undertake regular follow ups. 3.6 Performance Objectives and Targets Environmental performance objectives and measurable indicators against which the performance of the project can be measured and monitored must be developed and agreed upon by the TS-CM, TS-EHSC, EPCM-EHSC and C-CE for the construction phase of the project. These objectives and targets must be finalised in the detailed design phase. These objectives and targets must be incorporated in the EPCM and construction contractor appointment contracts and will be considered as contractual obligations that have to be fulfilled. EPCM and construction contractor performance with regard to these objectives and targets must be reviewed on a monthly basis by the TS-CM, TS-EHSC. In cases where targets and objectives are not met, the EPCM-EHSC and C-CE will be required to submit



new or revised method statements indicating proposed corrective measures to the TS-EHSC and TS-CM for approval. 3.7 Compliance Management and Corrective Action Environmental management is concerned not only with the final results of the contractor’s operations to carry out the works but also with the control of how those operations are carried out. Tolerance with respect to environmental matters applies not only to the finished product but also to the standard of the day-to-day operations required to complete the works. Non-compliance with the conditions of the ESMP must constitute a breach of appointment contract for which the EPCM and construction contractors will be held liable. The latter is deemed NOT to have complied with the ESMP if:

There is evidence of contravention of the ESMP, its environmental specifications or the Method Statements to be developed by the contractor within the boundaries of the construction site or areas of contractor responsibility;

Construction related activities take place outside the defined boundaries of the site;

Environmental damage ensues due to negligence;

The contractor fails to comply with corrective or other instructions issued by the TS-CM or TS-EHSC within a specific time;

The contractor fails to respond adequately to complaints from the public or Malagasy authorities.

In order to ensure that the EPCM and construction contractors comply with the ESMP the EPCM contractor will design and implement, and will require the construction contractors to implement, a staff warning and disciplinary system. This warning system must be designed by the EPCM contractor’s team, in conjunction with the TS–EHSC and TS-CM, all of whom can implement this system. This warning system must include the right for the TS-CM at the request of the TS-EHSC to remove from site any person who is in contravention of the ESMP. In addition, the TS-EHSC will have the contractual right (in terms the EPCM Contract and the construction contracts) to call a halt to any activity being undertaken which is deemed to be in conflict with the ESMP. The contractor shall not be entitled to make a claim in respect of any delays or additional costs associated with non-compliance with the ESMP and subsequent punitive action issued by the TS-CM or TS-EHSC. The appointment contracts will make the EPCM and the construction contractors liable for any construction rehabilitation costs associated with their non-compliance with the ESMP. This rehabilitation will be undertaken to the satisfaction of the TS-EHSC and TS-CM. The EPCM and construction contractors shall have the right to appeal any punitive action undertaken by the TS-CM or TS-EHSC. The exact nature (e.g. structure, timing etc.) of this appeal process must be established between Toliara Sands and the selected contractor in the final design period. 3.8 Reporting and Review The ESMP reporting and documentation requirements must be based on best practice principles, e.g. IFC Performance Standards procedures and requirements currently utilised by Toliara Sands that must take the following requirements into account:

Documents associated with the ESMP must be regularly reviewed and updated by all environmental management parties;

Audits of the environmental performance of the construction phase of the project will be undertaken on a quarterly basis by accredited institutions that are vetted by ONE. The purpose of the audits will be to assess compliance with the conditions of the Environmental Licence, and objectives and targets outlined in the ESMP;



The findings of external, internal and informal environmental reviews will be recorded and items requiring action will be identified from the recommendations made; and

The EPCM and construction contractors will be contractually obliged to fulfil any reasonable recommendations, and implementation of these actions will be assessed in the above audit.

There must, at least, be a commitment to use commercially reasonable efforts to incorporate the above listed provisions in the contracts, and these should be considered as contractual obligations. 3.9 Monitoring Construction activities have the potential to impact on a range of biophysical habitats as well as neighbouring communities. The monitoring programme described in Chapter 14 shall be utilised by Toliara Sands’ environmental department and will have to be reviewed by them in terms of its potential suitability and ease of implementation by the contractor. This can be implemented wholly, or as components during the construction phase. The exact requirements will only be available during the detailed design phase but as a minimum, monitoring will need to be undertaken for a range of variables, inter alia:

Water quality;

Air Quality;

Hydrocarbon pollution;

Vegetation clearing;

Rehabilitation success;

Success of local labour employment;

Success of local procurement policies;

Ionizing and non-ionizing radiation levels;

Ambient and workplace noise; and

Health and safety incidents. The relevant variables would need to be measured at the various work sites, receiving water monitoring points, ground water monitoring points, and at the property boundary, as applicable. The results and subsequent trends of the monitoring would then be compared to the baseline data available, the required standards and the objectives and targets set. The contractor would then be required to implement corrective actions to ensure compliance with the ESMP and its standards and specifications. In line with this ESMP, the EPCM contractor must prepare a document, subject to review and approval by Toliara Sands, clearly outlining and demonstrating the environmental responsibilities, accountability and liability of the EPCM contractor’s employees, as well as the construction contractor’s employees. The EPCM contractor should assign responsibilities for the following:

Reporting structures;

Actions to be taken to ensure compliance;

Overall design, development and implementation of the ESMP;

Documenting the environmental policy and strategy;

Implementing the ESMP in all stages/phases of the project; and

All the aspects requiring action under the core elements and sub-elements of the ESMP.

All official communication and reporting lines including instructions, directives and information shall be channelled according to the organisation structure. The EPCM contractor will be responsible for ensuring that all construction contracts contain corresponding provisions.



3.10 Emergency Preparedness The EPCM contractor shall compile and maintain environmental emergency procedures to ensure that there will be an appropriate response to unexpected or accidental actions or incidents that will cause environmental impacts during the construction period. Such activities may include, inter alia:

Accidental discharges to water and land;

Accidental exposure of employees to hazardous substances;

Accidental fires;

Accidental spillage of hazardous substances; and

Specific environmental and ecosystem effects from accidental releases or incidents. These plans should include:

Emergency organisation (manpower) and responsibilities, accountability and liability;

A list of key personnel;

Details of emergency services applicable to the various areas along the route that components will need to be transported and for the site itself (e.g. the fire department, spill clean-up services, etc.);

Internal and external communication plans, including prescribed reporting procedures where required by legislation;

Actions to be taken in the event of different types of emergencies;

Incident recording, progress reporting and remediation measures required to be implemented;

Information on hazardous materials, including the potential impact associated with each, and measures to be taken in the event of accidental release;

Training plans, testing exercises and schedules for effectiveness; and

Coordination with Toliara Sands’ relevant and existing plans and reporting requirements in this regard.

The contractor shall comply with the Toliara Sands emergency preparedness and incident and accident-reporting requirements, as well as all relevant Malagasy legislation. Where necessary, the contractor will prepare Method Statements that details the exact process, resource requirements and responsibilities for ensuring that these emergency procedures are documented and enforceable by the C-ESO, TS-EHSC and TS-CM. 3.11 Environmental Incident Management The EPCM appointment contract will require the EPCM contractor to develop procedures for managing environmental incidents, subject to approval by Toliara Sands, and must follow specific Hazard and Incident Reporting Protocols. A report must be completed for all incidents, and appropriate action taken where necessary to minimise any potential impacts. ONE must be informed of any environmental incident, in accordance with legislative requirements. Notification of an incident or emergency will include the following:

Description of the incident;

The location of the emergency or incident;

The name and telephone number of the designated contact person;

The time of the emergency or incident;

The suspected cause of the emergency or incident;

The environmental harm and/or environmental nuisance caused, or suspected to be



caused, by the emergency or incident; and

The action taken to prevent future occurrence of the incident and mitigate any harm and/or environmental nuisance caused by the emergency or incident.

A procedure for reporting environmental complaints from the affected community and employees must be developed prior to the onset of construction activities. 3.12 Management Review A formal management review needs to be conducted on a regular basis in which the internal audit reports written by the EPCM-EHSC - based on frequent inspections and interactions with the C-ESO and review of the C-ESO periodic reports, including audit reports by the independent external auditor - will be reviewed. The purpose of the review is to critically examine the effectiveness of the ESMP and its implementation and to decide on potential modifications to the ESMP as and when necessary. The process of management review is in keeping with the principle of continual improvement. Management review will take place when the liaison committee consisting of a representative from Toliara Sands, EPCM contractor, construction contractors as appropriate, and other parties deemed necessary by Toliara Sands or by the members of the committee (the “Liaison Committee”) meet every month. The purpose of these monthly meetings will be to review the progress of the EPCM contractor in implementing and complying with its obligations in terms of this ESMP for the duration of the project. Where necessary, management review will take place more frequently than the required monthly meetings. 3.13 General Specifications The management actions listed below will be executed by Toliara Sands so as to minimize negative impacts and enhance positive impacts throughout the lifecycle of the project. Some of the actions will only apply to specific phases (e.g. construction) while others will apply throughout the lifetime of the project. Sections below detail actions required for the construction, operational and closure phases.

3.13.1 Environmental

Implement a community training and awareness programme, focusing particularly on the impacts resulting from: large-scale bush clearance, selective logging of hardwoods for charcoal production, excessive use of fire in the dry season;

Identify training needs and conduct awareness/training to employees and contractors on environmental aspects and impacts; and

Implement an environmental incidences management reporting procedure.

3.13.2 Occupational Health and Safety Toliara Sands will:

Prevent as much as possible, work-related injuries of employees and contractors;

Benchmark the Safety Management System against international standards;

Identify, eliminate or control health and safety risks in the workplace and the environment;

Benchmark operations against international standards with regard to the prevention, treatment and rehabilitation of disability and impairment which may arise in the course of an employee or contractors work;

Prevent or minimize adverse impacts arising from their operations;



Undertake continuous on site monitoring of hazards that are, or could be, harmful to employees’ health and take preventive measures and refer those with occupational health ailments for further management;

Ensure 100% provision and use of appropriate personal protective equipment thus enhancing a positive health culture amongst employees;

Ensure that all identified hazards have a control procedure;

Carry out medical surveillance on all employees through pre-employment, periodical and exit assessments;

Implement the wellness program to all employees through provision of health information, education, counselling services and standard health practices;

Adhere to statutory demands with regard to medical surveillance, hazard identification and control, compensation for those affected and first aid provisions;

Provide first aid training and facilities beyond the mere statutory requirement; and

Identify and implement training needs for occupational health staff and employees to ensure they have the competence to meet their daily task demands.

To achieve the above Toliara Sands will:

Develop guidelines and operating procedures for occupational health & safety issues associated with all construction activities (land clearing, road construction etc.);

Develop hazard and safety identification standards and processes;

Define hazard communication responsibilities and processes;

Develop measures to ensure the health of the work force;

Develop monitoring standards and specifications;

Ensure the OHS OP has adequate capacity for oversight of occupational health and safety matters;

Including regular monitoring and review of safety matters, ambient working environments and other OHS indicators;

Develop procedures to ensure information and corrective measures are applied in a continuous process to improve OHS conditions and management;

Develop guidelines for the handling and storage of hazardous chemicals;

Identify measures to ensure the health of the work force, including aspects such as vaccinations, availability of clinics;

Develop procedures to deal with the issue of HIV/AIDS, TB, malaria and water borne diseases;

Ensure it’s Health and Safety Policy is implemented by all contractors;

Develop guidelines and operating procedures for community safety issues associated with all construction activities (land clearing, road construction etc.);

Develop key tools for health and safety implementation (e.g. integrated health tracking system; baseline site data collection);

Define linkages to other environment and social Operating Procedures (OP);

Relate all OP’s to national legislation and policies;

Liaise with government health agencies and NGO’s that have baseline information;

Define levels of cooperation and responsibilities of each party;

Prepare a community health profile (National and Provincial Overview, and Potentially Affected Communities);

Define community health and safety functions (e.g. programme interventions);

Establish a monitoring program based on specific focussed indicators at relevant sites;

Develop an Integrated Health Tracking System;

Develop reporting procedures and protocols;

Develop and implement a clear HIV/AIDS policy for employees, contractors/suppliers (this will deal with possible relations between expats and local communities);



Run community awareness programmes and workshop on the HIV/Aids policy with local communities; and

Consider engaging specialised NGOs to run ongoing community awareness workshops on safe sex and HIV/Aids (involve employees and all community stakeholder but specifically target local women and youth organisations).

Maritime safety measures as they relate to ship movements and anchoring will be implemented as standard mitigation. Major shipping movement that are potentially a navigational safety risk for fisherman must be communicated well in advance to these groups via the stakeholder engagement forums and processes initiated for the project.

Vessels utilised in the construction activity or material delivery should be of satisfactory standards and equipped with modern, long-range weather-monitoring equipment for the early detection of inclement weather. Operational guidelines must be drafted, restricting vessel movement to traffic ways and prescribing procedures for the early evasion of inclement weather and heavy seas. These guidelines must include the early departure of the barges to permanent moorings adjacent to the Toliara port. The arrangement for the services of a standby tug to assist vessels in distress may be appropriate.



3.14 Preconstruction Environmental Specifications This section of the ESMP outlines the environmental and social specifications which are required to be implemented during preconstruction phase for the Ranobe Mine Project.

Preconstruction Phase Environmental & Social Management Plans

Component All project related facilities

Theme (Impact Category) Labour and Recruitment

Issues / Impacts Employment

Mitigation Measures

Ensure that recruitment, employment and labour conditions are consistent with Malagasy legalisation;

Develop a grievance mechanism and retrenchment strategy;

Develop transparent procedures that allow access to project related jobs in an organized and fair manner;

Establish a Labour Desk/Employment Committee, including Toliara Sands and representatives from the affected communes and villages in the project area to develop an Operating Procedure for employment enhancement. This will detail procedures and practices that maximize opportunities for unskilled labour and minimizes social risks in the areas of influence. Contractors would be expected to abide by the conditions;

Specify commitments to deal with local expectations and risks, especially unskilled job opportunities and local purchasing in the project’s area of influence;

Establish a hiring process that respects local cultural and social norms in order to facilitate local participation and avoid conflicts and other negative social impacts;

Promote fair practices in the hiring of workers that protect against unauthorized third-party job brokers, child and forced labour, and discrimination;

Ensure that as far as possible those involved in the construction phase are incorporated in the permanent staff contingency for the operational phase. Attention will be paid to opportunities for women;

Disclose all procedures to the authorities, local populations and stakeholders through offices opened for this purpose;

Ensure that contractors provide information to the community and local stakeholders through local and regional communication media so the locations of offices where they may learn about job opportunities are known;

Ensure that these offices provide information on jobs; identify the number of available positions and specify application requirements;

Develop a clear policy that no workers will be hired at the construction sites;

Ensure that the contractor’s recruiting strategies identify the methods used for informing candidates that equal priority wil l be given to project affected people for unskilled positions;

Ensure the development and implementation of a compulsory community induction course for all outsiders, contractors and subcontractors entering the local community. This course will detail a code of practice that will include policies concerning interactions with communities and government officials, protection of community assets, STD prevention, etc.;

Develop a policy to ensure that no goods and services are procured from the project gate or stalls by the road;

Develop an Operating Procedure for gradual replacement of expatriates by Malagasy residents;

Engage a community relations officer to monitor the potential problems and to address them in good time through a dedicated community liaison structure;



Maintain regular contact with traditional leaders to ensure transparency of Toliara Sands’ activities.


Theme (Impact Category) Managing Transportation

Mitigation Measures

Develop traffic safety rules which ensure that villagers in the affected areas are made aware of the safety risks of the operation to them (notice boards and information workshops). Safety guards may need to be employed in certain areas and some infrastructure may need to be fenced off;

Develop an OP - Community Emergency Response in conjunction with and disclosed to the neighbouring communities;

Develop clear rules for speed limits, vehicle safety, vehicle maintenance and minimum driver training and impose on both the workforce and contractors; and

To mitigate for the loss of community access routes, routes affected will be assessed and new alternative routes that fulfil the same functions will be created.


Theme (Impact Category) Community Relations

Issues / Impacts Site Clearance

Mitigation Measures

Afford local communities the opportunity to access areas earmarked for de-bushing for the collection of firewood, medicinal plants etc.


Theme (Impact Category) Emergency Preparedness and Response

Issues / Impacts Ensuring Emergency Preparedness and Response

Mitigation Measures

Base management guidelines on the results of the Hazardous Operability Studies (HAZOPS) that identify risks for any hazardous installations within the mining area;

Undertake Emergency Incident Assessments for – mine operations; solid waste dumps; transport of product; radiation emergencies, pipeline and storage tank failures; seismic events, cyclones and other natural disasters; chemical emergencies; runaway fires and explosions;

Develop an Emergency Preparedness and Response Operating Procedure for the above;

Consult with Government emergency and security services during the preparation of the emergency preparedness and response OP and related hazard and risk work;

Develop emergency preparedness strategies to deal with general and hazardous materials spillages;

Identify upset conditions that can cause major environmental impacts, and develop measures to handle these;



Ensure emergency response arrangements, including integration with government security forces / emergency services, are included in the Emergency Preparedness and Response OP for the mine facility and road transport;

Define emergency communications responsibilities and set up an emergency communications process;

Develop an appropriate Evacuation Operating Procedure;

Develop arrangements for practice response;

Ensure internationally recognised Hazchem notices and instructions are displayed where required;

Undertake training needs analyses and develop worker education programmes;

Undertake independent third party audits as part of statutory national legislation; and

Develop an emergency drills schedule and undertake emergency drills and inspections.



Issues / Impacts Resettlement

Mitigation Measures

Prepare a RAP to deal with resettlement and compensation for all areas affected by the mine where economic and/or physical resettlement will be required;

Ensure that the RAP is compliant with Malagasy legislative requirements;

Establish the institutional and legal framework and mechanisms for implementing voluntary and involuntary resettlement;

Provide a detailed, quantitative socio-economic profile of project affected people through the development of an asset register;

Develop appropriate mechanisms, aligned with the Stakeholder Engagement Plan, to ensure the participation of project affected people (PAP’s) in resettlement preparation and planning;

Develop eligibility, evaluation and compensation criteria;

Design and test the implementation of a grievance mechanism applicable to all project activities (not only resettlement);

Where local communities are negatively affected by the project, ensure a fair and transparent compensation process;

Ensure that vulnerable persons are identified and given due consideration with respect to resettlement and resource alienation impacts;

Outline implementation schedules, costs and monitoring and evaluation procedures in the RAP;

Provide the resources to replace any arable land parcels that Toliara Sands displaces from their mining activity;

Develop internal and external monitoring procedures;

Ensure that at the start of the project land acquisition is timed to cause least disruption to the agricultural seasonal calendar;

Provide additional food (or financial compensation) during the period that affected people have no adequate access to crops;

Compensate all local communities that grow crops in the exclusion zones;

Ensure that the OP – Resettlement covers the following:

A list and description of the affected people;

A description of the lost resources of the affected people;



An inventory of affected people’s assets;

Identification of suitable alternative access to resources lost or enhancement of productive value of those that remain;

Compensation for lost dwellings (may be reconstruction of replacement housing);

Accepted compensation rates that reflect replacement value;

A livelihood restitution programme;

Transitional support during resettlement;

A strategy for community engagement during preparation and execution; and

Form a compensation working committee, consisting of representatives of the Province, the communes, the landowners, non-landowners and women in the villages affected, to develop the compensation strategy.

Ensure that access routes that are affected by the project are replaced and fulfil the functions of the routes that were lost;

Consideration should be given in the RAP to the development of a sustainable natural resource management programme for the broader area that should be negotiated in conjunction with the local stakeholders;

Facilitate (including sourcing potential funders) alternative and environmentally sustainable forms of local economic development, such as land based aquaculture etc.;

Consider developing a farmer support programme that aims to improve surrounding agricultural land by fertilizing and providing water in areas which are not affected by the mine. This will increase yields in those areas. Toliara Sands could consider providing farmers with these fertilisers on low interest short term credit to be paid back after the harvesting period; and

Explore opportunities for displaced people to derive development benefits from the project.


Theme (Impact Category) Public Participation

Issues / Impacts Stakeholder Engagement

Mitigation Measures

Outline the objectives and strategy for ongoing stakeholder engagement throughout the life of the project;

Define the principles underpinning stakeholder engagement;

Provide an analysis of stakeholders, building on the considerable body of work already undertaken for the ESIA;

Develop a communication strategy, informed by the stakeholder analysis, including stakeholder engagement structures/mechanisms;

Define communication activities required during different phases of the project;

Determine stakeholder engagement staffing requirements;

Develop job descriptions for staff;

Provide a mechanism for evaluating stakeholder engagement processes and to ensure that communication flow between Toliara Sands and communities takes place;

Provide a mechanism for evaluating stakeholder involvement;

Streamline community interactions with respect to any resettlement activities;



Explain how pollutants are being dealt with and allow communities to comment on the efficacy of this and make suggestions with regard to alternative management actions and mitigation measures;

The results of monitoring programmes allied to the pollution control programmes will be made available to local communities;

Engage with the traditional authorities to ensure that social tensions that may arise due to the project are effectively managed. This will be cross referenced to both the Stakeholder Engagement Plan as well as labour recruitment process; and

Monitor water levels in community water pits regularly and frequently throughout the mining period, and consult the users about the ease with which they are able to draw water compared with the pre-mining level of effort.


Theme (Impact Category) Public Participation

Issues / Impacts In-Migration

Mitigation Measures

Develop an in-migration Operating Procedure;

Develop a local planning framework strategy on Toliara Sands’ surface rights area in conjunction with provincial authorities, the chiefs and village heads, to set out the land that is available for development and the type of development allowed;

Collaborate with the Provincial Council to evaluate the Provincial Development Plan in terms of increased need for social facilities and provision of services;

Develop strategies to minimize local expectations in terms of potential employment;

Develop and implement a fair and transparent labour and recruitment policy (based on Malagasy law); and

Employ a community relations officer to monitor the potential problems and to address them in good time through a dedicated community liaison structure.



Issues / Impacts Cultural Heritage

Mitigation Measures

Develop a Chance Find Operating Procedure that can be used for all activities associated with the establishment of the mine and related infrastructure;

Ensure that the Chance Find OP focuses primarily on mitigation during ground breaking activities, but the protection of known cultural heritage sites near to the development area will also be considered;

Ensure that all cultural heritage is protected during the construction and operation phases;

Disclose the Operating Procedure to affected communities;

Define the responsibilities of all parties, inclusive of traditional owners and construction contractors, in the OP; and



Develop verification and monitoring procedures for Toliara Sands and contractors.


Theme (Impact Category) Safety and Security

Issues / Impacts Security

Mitigation Measures

Provide all environmental and social guidelines and standards that security contractors need to adhere to;

If components of project security are to be out-sourced to third parties, develop verifiable procedures for the selection and hiring of a security firm;

Ensure third party service providers comply with all relevant OP’s and policies established for the project;

Define security hazards by undertaking a security risk assessment and using this to develop the Operating Procedures – Security which will deal with, inter alia, restricted area perimeters; public spaces; restricted zones; site assets; access controls; water and electricity security; inward transport, receipt and storage; shipping, despatch, en route monitoring and storage; theft and diversion; fire; sabotage; IT and cyber security; personnel security; specific threats, vulnerabilities or risks;

Develop protocols for inherently safer options;

Develop reporting procedures for significant security incidents;

Allow for public disclosure of incidence;

Develop monitoring procedures for safety and security;


Issues / Impacts Storm and Process Water

Mitigation Measures

Develop a Storm and Process Water Operating Procedure;

Ensure the OP - Storm and Process Water deals with water quality management;

Plan fuel bays and service bays for vehicles such that these structures include oil traps contained in a bunded area to contain possible spillage;

Install adequate sanitation facilities on site and maintain them in good working order;


Issues / Impacts Pest Management

Mitigation Measures

The management actions listed below will be executed by Toliara Sands to minimize the impact of pests on the surrounding environment:



Develop an Integrated Pest Management OP for Malaria and water borne diseases;

Ensure that the Integrated Pest Management OP sets action thresholds;

Monitor and identify pests and implement prevention and control methods;

Ensure ongoing monitoring and evaluation of the Integrated Pest Management OP;

Where applicable, develop procedures for pest control using biological control agents;

Undertake stakeholder engagement at all stages of the process and involve various local and national stakeholders;

Ensure the Integrated Pest Management OP considers the Government of Madagascar’s Malaria Control Programme (Integrated Vector Management).


Theme (Impact Category) Resource use management

Issues / Impacts Encouraging sustainable resource use

Mitigation Measures

Toliara Sands will encourage sustainable resource use (mine staff and communities) as follows:

Running community workshops that explain sustainable resource use;

Prohibit exploitation of sensitive animals, e.g. chameleons and terrapins by mining staff within the mining area and run community workshops that explain sustainable resource use;

Educate mine staff (induction training) and local villagers (workshops) about the necessity of protecting snakes; and

Ensure ongoing monitoring through the development of monitoring procedures, and will implement a procedure of continual improvement.

It is recommended that villagers have access to the proposed mining area prior to clearing commencing to harvest all available resources.

An agricultural programme should be established to teach local residents about sustainable agricultural practices within the general project area.

Consideration should be given to assist the local community with the upgrading of the existing weir to increase water supply in the irrigation canal.



3.15 Construction Phase Specifications This section of the ESMP outlines the environmental specifications which are required to be implemented in the construction phase for the Ranobe Mine Project.

Construction Phase Environmental & Social Management Plans


Theme (Impact Category) Ecology

Issues / Impacts Site Clearing

Mitigation Measures

Utilise the method of de-bushing most appropriate for the environment and species in question. Favour mechanical rather that chemical methods wherever possible.

Where chemical methods are used, ensure that particular care is taken to avoid environmental damage. Manufacturers’ instructions are to be adhered to.

No material storage or lay down areas are permitted under trees.

Co-ordinate works to limit unnecessarily prolonged exposure of stripped areas and stockpiles. Retain vegetation and soil in position for as long as possible, removing it immediately ahead of construction / earthworks in that area.

Strip and stockpile herbaceous vegetation, overlying grass and other fine organic matter along with the topsoil.

Stockpile topsoil stripped from different sites separately, as reapplication during rehabilitation must preferably be site specific. If necessary keep a stockpile register.

Restrict the activities and movement of construction workers and vehicles to the immediate construction site as far as possible.

Wherever practically possible, carry out most of the vegetation clearance during the dry season;

Keep the size of the area cleared of vegetation to a minimum and re-vegetate as soon as is practically possible;

Minimise site clearing by identifying and marking with danger tape suitable lay-down areas and areas to be disturbed during construction (footprint areas);

Identify no go areas within the site (namely 30 m buffers along river courses and wetlands, no go area within the site);

Avoid activities on the banks of watercourses as far as possible;

Keep clearing of vegetation to a minimum;

Where possible do not permit site clearing activities within environmentally sensitive areas. Conduct activities in previously disturbed areas as much as possible.

When possible, vegetation clearing will occur during the winter months so as not do affect breeding birds;

When clearing of vegetation for construction in sensitive areas is essential, the footprint will be kept as small as possible to avoid un-necessary habitat loss and degradation;

Establish a nursery to cultivate plants that are worthy of protection. Collect plants from the footprint areas of all sites to be cleared, as well as the seed of dominant canopy tree species to propagate for future rehabilitation;

Employ a horticultural specialist and apply industry standards for the management of the nursery.





Issues / Impacts Protection of Fauna and Flora

Mitigation Measures

No wild animal may under any circumstance be handled, removed or be interfered with.

No wild animal may be fed on site.

No wild animal may under any circumstance be hunted, snared, captured, injured or killed. This includes animals perceived to be vermin with the exception of rodent (rat) type species that need to be controlled as general hygiene and sanitation controls.

Ensure that the site is kept clean, tidy and free of rubbish that would attract animal pests.

Ensure that domesticated animals belonging to the local community are kept away and are safe from any unprotected works.

Vegetation clearing and soil tilling must be confined to the construction areas and associated roads.

Do not make use of any pesticides, unless approved by the C-ESO and EPCM-EHSC.

A fire management protocol and prevention measures will benefit the population of small animals in the study area.

Development of all road linkages will employ, where possible, existing tracks and roads;

Roads crossing floodplains require detailed planning and for each a method statement in compliance with ESMP requirements must be prepared;

Limit river and stream crossings as far as possible;

Avoid blockage or diversion of rivers and streams where possible;

Avoid indirect effects of run-off erosion and sedimentation from roads that may lead to loss of riparian habitats;

Initiate a vegetation monitoring programme at the end of the construction phase. This must include alien plant monitoring so that any alien plants can be eradicated as they appear;

More research on new species of any kind, to determine their importance at the local, regional and national level, will be undertaken;

Avoid applying herbicides, and if essential they shall only be applied by approved manufacturers;

Prohibit hunting and killing of animals by mine staff, and the sale of bushmeat in the mine village and to mine staff;

Ensure that the security staff has received environmental training that includes protection of fauna and flora. This must form a component of site security;

Ensure that site environmental personnel regularly inspect all areas of the site;

Strictly enforce speed limits within the project area;

Night driving will be avoided as much as possible to avoid animal deaths, especially that of amphibians and reptiles;

Fences around the concession area that curtail faunal movements will be avoided;

Security fences around the mine complex will, where possible, be permeable to small animals;

To avoid fires which will negatively affect the surrounding vegetation and animal habitats: o Storage of highly flammable material (e.g. fuel) on site will be in adequately protected, secure sites, with facilities for fire fighting available; o Vegetation surrounding the mine complex will be controlled to reduce the risk of fire spread; o All litter, refuse, etc., will be regularly removed from the mine site;



o The cultural practice of slash and burn farming practices every dry season will be discouraged at workshops and subsistence farmers will be educated about the long-term effects of un-natural fire regimes.

To avoid chemical pollution which may negatively impact on the surrounding fauna and flora: o Chemical stores (including fuel, insecticides, etc.) will be bunded and locked at all times; o Access to such stores will be controlled at all times; o Inventories of stored chemicals will be maintained, and their use regulated; o All cautions/recommendations with respect to storage and use of hazardous chemicals will be implemented;

Develop and manage alien species by clearing alien plants as they appear.

Implement an Alien Invasive Species Control Programme to prevent the proliferation of alien invasive vegetation during all phases of the project;

The introduction of alien fauna, including domestic pets such as cats and dogs, will be prohibited to the mine site; and

Develop guidelines to manage indirect effects on aquatic ecological systems such as rivers and wetlands.


Damage to sensitive habitats during ongoing and future survey work and site development be avoided as far as possible. This is particular important where new roads are developed as they rapidly lead to strip development and increased resource extraction (e.g. charcoal production).

Fire breaks be developed around all project infra-structure.

Short, fire-resistant vegetation cover should be established to avoid erosion and siltation into drainage lines.

The chemical control of unwanted vegetation with herbicides, and pest animals with insecticides should be fully controlled and be in accordance with national controls of banned substances.

Access to all mine areas should be controlled, and all resource extraction controlled and documented, and remain in accordance with sustainable off-take.

The sale and use of unsustainable extracted resources (e.g. charcoal) in all mine facilities should be prohibited.

Environmental education of local communities should highlight the negative and unsustainable impacts resulting from large-scale bush clearance, excessive removal of hardwoods for charcoal production and timber, and un-necessary use of fire in the dry season to generate livestock grazing.

While navigating the Toliara bay vessels will be required to move at reduced speeds so as to allow any slow moving marine animals time to move out the ships path, alternatively, for the vessel to take avoiding action. In periods of high animal presence or movement (as confirmed by visual observation, fishermen or other sources) an alert to this effect must be communicated to all relevant vessels. Vessels arriving from open water entering the bay generally use the northern navigation channel of Toliara bay and should also post lookouts on approach to scan for any marine animal presence. This is likely to be limited in effectiveness in that only large species such as whales will be observable (in comparison say to turtles). It is anticipated that low vessel speeds will, in general, allow for the safe movement of these animals out of their path.

Avoid unnecessary dredging, piling or vessels movements.

A ballast-water plan must be adopted, including recommendations and requirements for hold cleaning, oceanic ballast exchange and ballast inspection and testing on arrival at Toliara. The latter should be followed, even if impractical to complete before commencement of ballast discharge, as records can be kept on the performance of the procedures for their improvement. The ballast-water plan must be regularly reviewed and updated to keep up with progress in this field, and be in line with IMO stipulations in this regard.

With respect to managing ecological processes and mitigating for vegetation loss Toliara Sands will:

Active culling programs of problem animals undertaken by conservation authorities and the prohibition of the introduction of alien aquatic and terrestrial species unless a full environmental assessment is undertaken and control methods for escapees detailed.

Protection and where necessary, rehabilitation of adjacent habitats as an environmental offset, particularly wetland and forest habitats



The protection and/or full rehabilitation of sensitive habitats, particularly forest habitats which are home to most of the threatened species.

Future design must avoid the Ranobe Lake and associated wetlands, providing a wide buffer zone around the lake and drainage lines leading into it. All specific project actions associated with construction, access roads, borrow pits and cut-and-fill construction must avoid sensitive habitats. Natural drainage should be maintained and the silt loads into rivers, streams and wetlands must stay within normal limits.

Natural drainage should be maintained and the silt loads into rivers, streams and wetlands must stay within normal limits.


Theme (Impact Category) Natural Resources

Issues / Impacts Protection of Natural Features

Mitigation Measures

The EPCM and construction contractors shall not deface, paint, damage or mark any natural features (e.g. rock formations) situated in or around the site for survey or other purposes unless agreed beforehand with the C-ESO and EPCM-EHSC.

Any features affected by the contractor in contravention of this clause shall be restored or rehabilitated to the satisfaction of the C-ESO and EPCM-EHSC.

The EPCM and construction contractors shall not permit their employees to make use of any natural water sources for the purposes of swimming, personal washing and the washing of machinery or clothes (with the exception of supervised swimming in the ocean that will be permitted in designated areas at designated times).


Theme (Impact Category) Cultural Heritage

Issues / Impacts Protection of Cultural Remains

Responsibilities for Implementation

Mitigation Measures

The C-ESO and EPCM-EHSC shall monitor work areas for the presence of cultural heritage remains – particularly during land clearing, earthworks and excavation activities.

Do not disturb deface, destroy or remove protected features and sites, whether fenced or not, for the duration of the EPCM and construction contractors’ presence on site, unless otherwise specified by the C-ESO and EPCM-EHSC.

If any chance archaeological finds, graves or skeletal material are unearthed, halt works in that area immediately and inform the EPCM-EHSC. The EPCM and construction contractor must ensure that their workforce is aware of the necessity of reporting any possible historical or archaeological finds to the EPCM-EHSC so that appropriate action can be taken.

Should any archaeological sites be uncovered during construction, their existence shall be reported to the EPCM-EHSC, who in turn will inform local authorities.

A list of contact details for the relevant personnel at these institutions must be drawn up and be readily accessible on site.



Any discovered artefacts shall not be removed under any circumstances.

Supervisors, field personnel, and government cultural heritage representatives must be notified; and appropriate treatment strategies developed.

Only after all treatment work is agreed and any required excavations carried out is project activity allowed to resume in the area. A detailed description of the Chance Finds Procedure is provided below and must form the basis of the required method statement:

o Stop work in the immediate area o Inform supervisor/foreman o Inform C-ESO and EPCM-EHSC. o o Install temporary site protection measures (warning tape and stakes, avoidance signs) o Inform all EPCM and construction contractor personnel of the chance find if access along the right-of-way or other work area is restricted o Strictly enforce any no-go area needed to protect the site o Archaeologists will perform a preliminary evaluation to determine whether the Chance Find is cultural heritage and if so, whether it is an isolate

or part of a larger site or feature o Artefacts will be left in place when possible; if materials are collected they will be placed in bags and labelled o Document find through photography, notes, and maps (collect spatial data) as appropriate o If the Chance Find is an isolated or is not a cultural heritage, the archaeologists will authorize the removal of site protection measures and

activity can resume o If the archaeologist confirms the Chance Find is a cultural heritage site he/she will inform the C-ESO and EPCM-EHSC; and initiate

discussions with them about treatment o If a Chance Find is a verified cultural heritage site, the archaeologist will prepare a final Chance Finds report once required treatment has been

completed

Artefacts collected in connection with Chance Finds should be minimized. Those retained because they are accidentally unearthed or broken free of their soil matrix should be retained with precise notation of their original location, and with photographs taken of their original context.

Artefacts photos and site photos may be useful for consultation regarding Chance Finds and should be taken as soon as possible. Artefacts and associated notes and photographs taken by any personnel should be given to the government heritage staff as soon as possible.

Monitoring Measures

Key Performance Index


Theme (Impact Category) Noise

Issues / Impacts Construction noise


Mitigation Measures

Unless otherwise specified by the EPCM-EHSC and C-ESO, normal work hours will apply (i.e. from 06h30 to 18h00, Mondays to Saturdays). Construction



activities generating noise near the villages shall be confined to the hours 07h00 to 17h00.

Noise abatement measures should achieve either the levels presented below, or a maximum increase in background levels of 3 dB(A).

Ensure that employees and staff conduct themselves in an acceptable manner while on site, both during work hours and after hours.

The EPCM and construction contractors shall limit noise levels (e.g. install and maintain silencers on machinery) as far as possible within commercially reasonable and feasible limits.

Appropriate directional and intensity settings are to be maintained on all hooters and sirens.

No amplified music shall be allowed on site. The use of radios, tape recorders, compact disc players, television sets etc. shall not be permitted unless the volume is kept sufficiently low as to avoid any intrusion on members of the public within range.

With regard to unavoidable very noisy construction activities in the vicinity of noise sensitive areas, C-ESO with the assistance of the EPCM-EHSC, should liaise with local residents on how best to minimise impact, and the local population should be kept informed of the nature and duration of intended activities.

Notify adjacent villages of after-hours construction work and of any other activity that could cause a nuisance. At least 24 hours notice must be provided, and this notice must be given by EPCM-EHSC, having first been informed by the C-ESO of the need therefore

Respond to community complaints with regard to noise generation, taking reasonable action to ameliorate the impact.

Construction site yards, workshops, concrete batching plants, and other noisy fixed facilities should be located well away from noise sensitive areas. Once the proposed final layouts are made available by the contractor the sites must be evaluated in detail and specific noise reduction measures designed in to the system within commercially reasonable and feasible limits.

Truck traffic should be routed away from noise sensitive areas, where possible.

Noise suppression measures must be applied to all construction equipment within commercially reasonable and feasible limits. Construction equipment must be kept in good working order and where appropriate fitted with silencers which are kept in good working order. Should the vehicles or equipment not be in good working order, the C-ESO, may be instructed to remove the offending vehicle or machinery from site.

Comply with maximum legal noise limits within the mining area and at the perimeter;

Maintain equipment and vehicles in good condition, serviced regularly, etc.;

Conduct periodic testing and screening to ensure compliance with noise standards;

Have sound proofing and ear protection equipment in areas of the plants where the noise levels are above legal limits for working; and

Where possible blasting will be restricted to daylight hours. The following is recommended:

It is recommended that if pile operations are needed, noise attenuation measures such as an earth berm should be considered. The piling noise will however be of short duration; therefore the overall impact should be low. If impact piling is conducted it is highly recommended that an additional survey be conducted at night to determine the zone of influence as well as the actual efficacy of the attenuation measures.

Construction staff should receive noise sensitivity training to ensure that the construction noise is kept at a minimum.

The use of portable noise attenuation screens is highly recommended. These can be placed as close as possible to the noise source such as mobile compressors, drilling rigs etc.

Conducting periodic noise surveys to determine the efficacy of noise attenuation measures should be undertaken.

Ensuring that staff is given “noise sensitivity” training. This should include the operational techniques to ensure that the mining bench is situated in a manner that will ensure that the noise is screened from nearby residents.



Monitoring Measures



Theme (Impact Category) Air quality

Issues / Impacts Dust


Mitigation Measures

The C-ESO and construction contractors shall take all reasonable measures to minimise the generation of dust as a result of construction activities to the satisfaction of the EPCM-EHSC .

Removal of vegetation shall be avoided until such time as soil stripping is required, and similarly exposed surfaces shall be re-vegetated or stabilised as soon as is practically possible.

Excavation, handling and transport of erodible materials shall be avoided under high wind conditions or when a visible dust plume is present.

During high wind conditions, the EPCM-EHSC and C-ESO will evaluate the situation and make recommendations as to whether dust-damping measures are adequate, or whether working will cease altogether until the wind speed drops to an acceptable level.

Where possible, soil stockpiles shall be located in sheltered areas where they are not exposed to the erosive effects of the wind. Where erosion of stockpiles becomes a problem, erosion control measures shall be implemented at the discretion of the EPCM-EHSC and C-ESO.

Vehicle speeds shall not exceed 30km/h along dirt roads or 20km/h when traversing unconsolidated and non-vegetated areas.

Appropriate dust suppression measures shall be used when dust generation is unavoidable, e.g. damping down of all exposed soil surfaces with a water bowser or sprinklers when necessary to reduce dust dampening with water, particularly during prolonged periods of dry weather. Such measures shall also include the use of temporary stabilising measures (e.g. chemical soil binders, straw, brush packs, chipping etc.).

Excavations and other clearing activities must only be done during agreed working times and permitting weather conditions to avoid sand and dust drifting into neighbouring areas.

Monitoring Measures



Theme (Impact Category)

Issues / Impacts Lighting




Mitigation Measures

The contractor shall ensure that any lighting installed on the site for his activities, and those of the construction contractors, does not interfere with road traffic or cause a reasonably avoidable disturbance to the surrounding community or other users of the area.

Where the EPCM-EHSC and C-ESO has authorised night work, low flux and frequency lighting shall be used.

Monitoring Measures




Issues / Impacts Access to sites


Mitigation Measures

Access to the construction site should be controlled as per the standard procedures currently utilised by World Titanium Resources.

The C-ESO shall ensure that access to the various work sites and associated infrastructure and equipment is off-limits to the public at all times during construction.

Secure the site in order to reduce the opportunity for criminal activity in the locality of the construction site.

It should be noted that access routes for the local villagers between the various work sites must be maintained.

Monitoring Measures




Issues / Impacts Access roads and traffic


Mitigation Measures

Enforce speed limits at all times, both on public roads and on site roads. Unless otherwise specified by the C-ESO and EPCM-EHSC, the speed limit on construction roads is 30km/h. All delivery and construction related vehicle traffic will not exceed 30km/h when passing through, or adjacent to, villages or settlements.



Allow for safe pedestrian and cycling access and crossing where necessary.

Ensure that only authorised roads and access routes are used.

Vehicles may not leave the designated roads and tracks and turnaround points will be limited to specific sites.

Maintain all access routes and roads adequately in order to minimise erosion and undue surface damage. Repair rutting and potholing and maintain stormwater control mechanisms.

Runoff from roads must be managed to avoid erosion and pollution problems.

Regularly remove topsoil (and other material) accumulated in side drains of roadways to keep these open and functional.

Clear up any gravel or cement spillage on roads.

Clean and make good any damage to public or private roads caused by the Contractor during the construction phase.

No off-road driving is permitted, unless authorised by the C-ESO and EPCM-EHSC .

Do not permit vehicular or pedestrian access into natural areas beyond the necessary work site.

Monitoring Measures




Issues / Impacts Storm water control


Mitigation Measures

The construction contractors shall prevent discharge of any pollutants, such as cements, concrete, lime, chemicals and fuels into any water sources, whether surface or groundwater.

Ensure that no stormwater is allowed to enter any drainage installation for the reception, conveyance, storage and / or treatment of sewage.

Runoff from fuel depots/workshops/truck washing areas and concrete batching plants shall be directed into a conservancy tank and disposed off at a site approved by the C-ESO. Any collected run-off, etc. that is disposed of to receiving surface water or ground water should be:

o sampled and analyzed to see if there are any non-compliant contaminants, o if so, treated prior to discharge, and o receiving water (surface or ground water) must be regularly sampled and analysed and action plans established to address any non-

compliances identified.

Prevent the discharge of water containing polluting matter or visible suspended materials directly into drainage lines or wetlands.

Where necessary, turbid water pumped must be passed through a sand filter or settling pond before being released back into any surface water feature. Discharge of this water must be in a controlled manner, and no erosion may result. Water discharged from sand filters or settling ponds must meet effluent standards.

Settling ponds will be cleaned out from time to time to ensure their proper functioning, and sediments recovered from such ponds will be disposed of in an



appropriate manner considering the contents.

Construction contractors or the C-ESO shall notify the EPCM-EHSC immediately of any pollution incidents on site.

Protect all areas susceptible to erosion and ensure that there is no undue soil erosion resultant from activities within and adjacent to the construction camp and work areas.

Retain natural trees, shrubbery and grass species wherever possible.

The site must be managed in order to prevent pollution of drains, downstream watercourses or groundwater, due to suspended solids, silt or chemical pollutants.

Silt fences should be used to prevent any soil entering the stormwater drains.

Temporary cut of drains and berms may be required to capture stormwater and promote infiltration.

The installation of the stormwater system must take place as soon as possible to attenuate stormwater from the construction phase as well as the operational phase.

Earth, stone and rubble is to be properly disposed of so as not to obstruct natural water path ways over the site. I.e. these materials must not be placed in stormwater channels, drainage lines or rivers.

There should be a periodic checking of the site’s drainage system to ensure that the water flow is unobstructed.

Monitoring Measures




Issues / Impacts Workshop, Maintenance and Storage Areas


Mitigation Measures

Vehicles used during construction must have the minimum impact on the environment or other road users. The size, height and weight of the vehicle must be kept in mind.

Day to day parking of vehicles is to be on hard surfacing wherever possible.

Regularly check vehicles, machinery and equipment operating on site to ensure that none have leaks or cause spills of oil, diesel, grease or hydraulic fluid.

No vehicles, machinery or equipment with leaks or causing spills may be allowed to operate on the construction site. These must be sent to the maintenance yard or workshop for repair, or must be removed from site. Only emergency and essential repairs of vehicles and equipment may take place on site.

Ensure that the maintenance of all vehicles and equipment, including oil and lubricant changes, takes place only within properly equipped, bunded maintenance areas or workshops.

Underlay heavy duty maintenance areas and workshops with a concrete slab, enclosed within a bund, which drains into a conservancy tank.

Provide drip pans for generators, or any machinery that will be in position for longer than one day.



Drip trays will be utilised during servicing.

Drip trays are to be watertight, and must be emptied regularly and before rain events. The contents of drip trays are to be treated as hazardous.

Where oil and fuel spills are expected, parking is to be on an impervious surface with adequate pollution control mechanisms in place.

The construction contractor will provide a dished concrete floor slab to prevent infiltration of hydrocarbon products.

The construction contractor shall provide grease and oil separation tanks (as required) at all areas where oil spillage or collection will occur, i.e. workshops, oil storage, vehicle wash areas and fuel points.

The construction contractor shall set up a contaminated water management system, and a Method Statement is required in this regard. The method statement shall state the collection facilities that are to be used to prevent pollution, as well as the method of disposal of the contaminated water, which must not result in violations of the applicable effluent standards.

Drainage from the service area will be channelled into a sump or oil-skimming tank, where it shall be treated to remove old hydrocarbons.

Drainage from the wash bay platform will firstly be channelled into the skimming tank before being released by drain to the sedimentation pond.

The construction contractor shall educate workers on the appropriate methods for workshop maintenance and fuel points to prevent fuel and oil being washed out of containment areas.

Underlay light-duty vehicle workshops with an impermeable PVC lining or thin concrete slab which drains into a conservancy tank.

The EPCM contractor will test effluent discharged from the oil skimming tanks for conformance with relevant effluent standards if requested to do so by the ECO when pollution is suspected.

Toxins and oil must be recovered from the system at least once a week.

All spillage of oil onto concrete surfaces shall be controlled by the use of an accepted absorbent material such as Econosorb or Drizit.

Monitoring Measures




Issues / Impacts Materials Handling


Mitigation Measures

Much of the materials handling infrastructure will be built in previously disturbed areas and the nearshore (beach hard top) area. A hard top area will be built on the beach from the foot of the jetty into the dunes, to receive all equipment and parts transported to the site by ship. The specifications for the construction of the materials handling facilities are:

Good housekeeping must be implemented by the C-ESO at all times i.e. containment of all fuels, chemicals and building material, which could pollute the coastal environment.

Footprints for developments must be kept to a minimum, be clearly set, demarcated, and aggressively policed to protect the sensitive coastal, beach and marine environments. “No go” areas established must be clearly marked.



The established marine “no go” safety area around the existing jetty must be communicated/reiterated to the local fishermen.

Materials shall be appropriately secured to ensure safe passage between destinations. Loads including, but not limited to sand, stone chip, fine vegetation, refuse, paper and cement, shall have appropriate cover to prevent them spilling from the vehicle during transit.

The C-ESO shall ensure that the construction contracts make the construction contractors responsible for any clean-up resulting from the failure by his employees or suppliers to properly secure transported materials.

The hard top must be removed immediately after all barge shipments have been landed and the area must be rehabilitated to the satisfaction of the EHSC.

Safe access routes must be made available to local people along the beach, coastal dunes and wetlands.

All refuse from ships must be transported to shore, stored and taken to suitable waste disposal sites.

Monitoring Measures




Issues / Impacts Cement Storage and Concrete Batching


Mitigation Measures

Do not locate batching plants or associated sludge dams within the 1:100 year flood line, or within a horizontal distance of 100m (whichever is greater) of a watercourse, drainage line or identified wetland.

Concrete shall not be mixed directly on the ground.

The permitted location of the batching plant (including the location of cement stores and sand and aggregate stockpiles) shall be indicated on the site layout plan and approved by the EPCM-EHSC.

The concrete batching activity shall be located in an area of low environmental sensitivity to be identified and approved by the EPCM-EHSC .

The cement/concrete batching works shall be kept neat and clean at all times. No batching activities shall occur on unprotected substratum of any kind.

Unused cement bags are to be stored so as not to be effected by rain or runoff events.

Used bags shall be stored in weatherproof containers to prevent wind blown cement dust and water contamination. Used bags shall be disposed of on a regular basis via the solid waste management system, and shall not be used for any other purpose.

Concrete transportation must not result in spillage.

All wastewater resulting from batching of concrete shall be disposed of via the wastewater management system.

Cleaning of equipment and flushing of mixers shall not result in pollution of the surrounding environment: care shall be taken to collect contaminated wash water from cleaning activities and dispose of it in a manner approved by the EPCM-EHSC.

Suitable screening and containment shall be in place to prevent wind blown contamination associated with loading and batching.

All visible remains of excess concrete shall be physically removed on completion of the concrete pour section and disposed of in the temporary hazardous waste storage facility prior to final disposal in Maputo. Washing the remains into the ground is not acceptable. All excess aggregate shall also be removed.



Carefully control all on-site operations that involve the use of cement and concrete (this applies to areas other than the batching plant).

Limit cement and concrete mixing to single sites where possible.

Dispose of all visible remains of excess cement and concrete after the completion of tasks. Solid waste concrete may be treated as inert construction rubble, but wet cement and liquid slurry, as well as cement powder must be treated as hazardous waste.

Ensure that water usage at batching plants and crusher plants is regulated – maintain the proper moisture content and avoid waste.

Monitoring Measures




Issues / Impacts Pollution Prevention and Abatement


Mitigation Measures

Construction vehicles and equipment will continue to be kept in good working order and oil or fuel leaks shall be fixed immediately upon detection, in a dedicated vehicle maintenance area;

Any spills will be cleaned up immediately;

Spill kits or sorb materials will be kept on hand to clean up spills. Once used, this material shall be treated as hazardous waste and disposed of at a permitted hazardous landfill site;

Adequate sanitation facilities and waste skips will be provided for construction workers;

The fuel storage, transfer and handling facilities on construction barges and vessels (as well as shore based plant that can possibly be an additional point source of hydrocarbon pollution) must be designed and operated to international standards with facilities for containing and handling an oil spill. Contingency plans and equipment must be installed for the management of unconfined oil pollution;

Should a major spill event demonstrably reduce fishing activity, and associated catches consideration should be given to compensating the affected communities appropriately. It is recommended that this compensation mechanism be developed in conjunction with the spill response procedures.

Store and dispose of all chemicals used on site according to Malagasy legislation and international best practice;

Due to the quantities of chemicals required, it is recommended that all hazardous chemicals or chemicals deemed to pose an impact on the environment are stored on impermeable surfaces in secure designated storage areas;

Clean up spills immediately in accordance with an established protocol;

Ensure MSDS are readily available for all chemicals at the point of storage and use;

Chemicals must be stored in secure, bunded designated areas;

Ensure chemicals that may react in a dangerous manner are not stored within the same bunded area, and confirm the compatibility of chemicals prior to storage;

Design and operate any facility for the bulk storage of flammable liquids, including fuels according to international best practice; and



Develop a Chemical Storage Operating Procedure which includes measures to ensure that all chemical wastes and empty chemical containers are managed and disposed of according to the requirements of Malagasy legislation and international best practice.

Monitoring Measures



Theme (Impact Category) Waste Management

Issues / Impacts Solid Waste Management


Mitigation Measures

The EPCM contractor shall set up a construction solid waste control and removal system which all construction contractors and subcontractors will be required to utilize.

Collect all general and domestic waste in adequate numbers of litter bins located as required on the work site and within the construction camp.

Litter bins must be equipped with a closing mechanism to prevent their contents from blowing out. Waste and litter shall be disposed of into scavenger- and weather-proof bins. The EPCM contractor shall then remove the refuse collected from the working areas, from site at least once a week.

Ensure that construction personnel make use of the litter bins provided. Keep all work at sites and at the Contractors camp tidy and litter free at all times.

Where feasible, collect waste paper, glass and metal waste separately and arrange for collection by recycling contractors.

Where necessary, dedicate a storage area on site for the collection of construction waste.

Unless otherwise specified by the C-ESO, remove stored domestic waste to the nearest solid waste disposal facility.

Ensure that solid waste is transported properly, avoiding waste spills en-route.

No solid or liquid waste disposal is to take place on site, and ensure that only non-toxic materials which have no risk of polluting the groundwater are buried at the mine’s designated waste disposal facility.

No solid waste may be burned on the construction sites. Non-hazardous flammable waste may be burned in a properly designed and maintained incinerator. No open burning is permitted.

A register system for hazardous waste disposal (that incorporates a safe disposal certification scheme) must be implemented. It should as a minimum record the weight and volume of hazardous wastes being disposed, disposal contractor details, disposal facility, and dates of disposal, and include third party evidence of safe disposal, for example receipts from the disposal facility.

The EPCM contractor shall make provision for workers to clean up the contractor’s camp and working areas daily.

Monitoring Measures





Theme (Impact Category) Waste Management

Issues / Impacts Hazardous Substances Management


Mitigation Measures

Ensure compliance with all national, regional and local legislation and applicable standards with regard to the storage, transport and use of hydrocarbons, chemicals, solvents, and any other harmful and hazardous substances and materials.

Store all hazardous substances in secure, safe and weatherproof facilities, underlain by a bunded concrete slab to protect against soil and water pollution. Proper storage facilities for the storage of oils, paints, grease, fuels, chemicals and any hazardous materials to be used must be provided to prevent the migration of spillage into the soil, surface and groundwater regime around the temporary storage area(s).

These pollution prevention measures for storage should include a lined and impermeable bund wall high enough to contain at least 110% of any stored volume, and this should be sited in a suitable area away from drainage lines.

Storage areas containing hazardous substances/materials must be clearly signposted.

Designate and construct controlled loading/unloading areas, underlain by an impervious paving or PVC sheeting to protect against soil and water pollution.

Position hazardous substance stores in areas not threatening human life or the environment. This will be strictly within the confines of the construction camp in an area jointly designated by the C-ESO and EPCM-EHSC.

The C-ESO shall keep a register of all hazardous substances stored on site for regular submission to the EPCM EHSC for review. If necessary a separate store for the contractor may be established adjacent to the existing mine store. This must be to the same specifications and access thereto must be controlled by the C-ESO. Construction contractors will have to notify the C-ESO when access is required, with all movements of substances in and out the store recorded in the hazardous substances register.

Material Safety Data Sheets (MSDSs) shall be readily available for all chemicals and hazardous substances to be used on site. Procedures detailed in the MSDS must be followed in the event of an emergency situation. Where possible the available MSDSs should additionally include information on ecological impacts and measures to minimise negative environmental impacts during accidental releases or escapes.

Staff dealing with these materials/substances must be aware of their potential impacts and follow the appropriate safety measures.

The EPCM-EHSC and C-ESO will be responsible for ensuring that all accidental spills must be cleaned immediately, treating the spilled material and used cleaning products as hazardous waste. Contaminated soil not suitable for bioremediation will be treated as hazardous waste.

The EPCM-EHSC will ensure that personnel handling hazardous substances have been educated in terms of the correct handling, use and disposal thereof.

Empty containers in which hazardous substances were kept are to be treated as hazardous waste. Hazardous chemical substances used during construction shall be stored in secondary containers. Collect any hazardous waste in appropriate containers located on a drip tray on site pending disposal.

No paint products may be disposed of on site and brush/roller wash facilities shall be established to the satisfaction of the C-ESO. Oil based paints and chemical additives and cleaners such as thinners and turpentine shall be strictly controlled.

General and hazardous wastes should be separated at source.

Where temporary storage of hazardous wastes is required, this should be undertaken in a secure area protected from the elements and designed and operated according to international best practice.



All waste streams must be handled and disposed of by authorised personnel.

Removal of any waste from site by unauthorised individuals must be prevented.

All staff should be trained in the correct handling, storage and disposal of hazardous wastes;

The integrity and roadworthiness of all vehicles used for the transportation of wastes must be checked regularly.

Retain waste oils and batteries for recycling by the supplier wherever possible.

The EPCM and construction contractors, and the staff of its sub-contractors, must ensure that its staff is made aware of the health risks associated with any hazardous substances used and has been provided with the appropriate protective clothing/equipment in case of spillages or accidents and have received the necessary training.

Ensure all hazardous waste disposal facilities and transportation of hazardous waste is registered with the relevant Malagasy authorities;

Where possible, all hazardous wastes, including hydrocarbon wastes such as oils, are recycled either by a recognised recycling company or returned to the supplier;

All empty and externally dirty tanks that may have contained hazardous materials, including hydrocarbons, are sealed and stored on an area where the ground has been protected;

Oil-water separators / oil traps will be installed on drains in all areas where hydrocarbons may contaminate water, and these traps will be maintained in good working order;

Any fuel spills will be adsorbed onto a suitable absorbent and disposed together with oils and grease;

Characterise (including the quality and quantity) all hazardous waste to ensure wastes are identified, quantified and managed correctly;

Store all hazardous waste temporarily in a dedicated and purpose built facility pending removal from site for final containment. Where possible, empty containers will be returned to suppliers. The facility will be lined (and bunded) with concrete and roofed to stop runoff or surface water contamination;

Develop a Hazardous Chemical Operating Procedure for the facility, including detailed spill response procedures;

Develop SOP’s for hazardous waste segregation, storage, shipping, receiving, usage and disposal;

Store all hazardous chemicals of a volume equal to or greater than 250 litres in a bunded facility that complies with legislative requirements and best practice;

Develop a Hydrocarbon Management OP and implement to provide for the proper storage and handling of hydrocarbons on site and hence to prevent any form of contamination;

Dispose of soil contaminated with hydrocarbons immediately at a soil bioremediation facility on site;

Ensure Material Safety Data Sheets (MSDS) for all hydrocarbons and chemicals are available at all sites where hydrocarbons/chemicals are present and copies will be kept at the environment health and safety department;

Do not dispose of hazardous wastes into drains, as this may impact negatively on the performance of the sewage treatment plant. This, in turn, could result in the discharge of partially-treated sewage to the environment;

Undertake regular maintenance of vehicles and pumps located near water courses;

Vehicles will be serviced only on impermeable surfaces with containment bunds and grease traps. Traps will be regularly serviced;

Temporary storage of hazardous wastes will be in a secure area; and

All staff will be trained in the correct handling, storage and disposal of hazardous wastes. Where possible, all hazardous wastes, including hydrocarbon wastes such as oils, should be recycled either by a recognised recycling company or returned to the supplier;

All waste streams are handled according to international best practice;

Where temporary storage of hazardous wastes is required, this should be in a secure area;



All waste streams must be handled and disposed of by authorised personnel;

Removal of any waste from site by unauthorised individuals must be prevented;

A general waste disposal facility be constructed to enable responsible disposal of general solid waste;

All staff be trained in the correct handling, storage and disposal of hazardous wastes

As soon as final project plans are available, the size of all waste streams should be determined as accurately as possible so as to facilitate the development of an appropriate waste management plan

All construction related ships and vessels must demonstrate that TBT is not used as antifouling on these in accordance with the IMO ban on this substance. Shipping must be restricted to the prescribed traffic ways to prevent their approach to the reefs and exposure of the latter to higher concentrations of antifoulant paint. The barges must be moored outside the construction area when not in use (i.e. in Toliara port). No antifoulant paints are to be applied to vessels on site.

Monitoring Measures




Issues / Impacts Sewage Waste Management


Mitigation Measures

Ensure the provision of appropriate temporary sanitation systems during the construction phase of the project infrastructure and packaged effluent treatment plant be used during the operational phase;

The sewage treatment facility be staffed by well-trained personnel and that there are sufficient spare parts available at all times;

Options for reuse and beneficiation of treated sewage water will be investigated. This may include composting;

Effluent quality must be monitored and must meet Malagasy or the IFC’s guideline values, whichever is more stringent;

Washing, whether of the person or of personal effects, and acts of excretion and urination are strictly prohibited other than at the facilities provided;

Sanitation facilities shall be located within 100 m from any point of work, but not closer than 50 m to any water body;

All sewage treatment plants must be well maintained and operated at all times. To this end, at least one employee on site must be trained to operate and maintain the system(s);

The performance of the sewage treatment systems must be monitored regularly. Where a system is found to be performing poorly, the cause of the poor performance must be investigated and remediation measures put in place to restore performance;

The environmental monitoring programme for the facility must incorporate monitoring points that are able to detect a negative impact on the environment associated with the discharge of treated sewage;

Ensure all toilets on site lead into septic tanks or a package treatment plant;

Ensure that septic tanks are regularly emptied into a series of oxidising ponds. The ponds will be designed according to best practice and will be lined.



Waste water will lead from the ponds into a dedicated wetland where further cleaning of water will occur. Ensure that the septic tanks and oxidising ponds are constructed at the early stages of the construction phase;

During the construction of the oxidation ponds, chemical toilets will be provided. Chemical toilets are provided until the septic tanks and oxidising ponds are ready. The waste from the chemical toilets must be disposed of in an appropriate manner, which is likely to be through burial. The location of the pit into which the waste will be disposed of must be investigated to ensure that the waste will not result in contamination of the ground water through soil percolation tests and a ground water level test;

Mitigation measures aimed at reducing water consumption could include the installation of low or dual-flush toilets if considered socially acceptable; and

Where other toilet types and showers are required, employees will be trained to conserve water.

All wash water and sewage from all sites must be diverted to the appropriate facilities for treatment and must meet the discharge standards of Madagascar or the IFC (2007) prior to release into the process water dam or the environment;

Chemical toilets should not be used during the construction period unless the contents can be disposed of in a manner that does not pose a threat to the environment. Instead, alternatives such as pit latrines, composting toilets or similar should be considered as preferred alternatives;

If pit latrines (VIP) are used, they must be sited, constructed and maintained in a way that minimises the risk of contamination of surface and sub-surface water resources;

All sewage treatment facilities should be well maintained. To this end, at least one employee on site must be trained to maintain the system(s);

The performance of the sewage treatment systems must be monitored regularly. Where a system is found to performing poorly, the cause of the poor performance must be investigated timeously and remediation measures put in place to restore performance;

In the event that sludge must be removed from the system(s), it must be disposed in a manner that minimises potential risk to human health and the environment and should comply with the National legislation;

The environmental monitoring programme for the facility must incorporate monitoring points that are able to detect a negative impact on the environment associated with the discharge of treated sewage.

Investigations be conducted into the most appropriate sanitation system to serve the mine community based on social, biophysical and economic considerations;

Appropriate temporary sanitation systems be employed during the construction phase of a permanent packaged sewage treatment system if this option is considered most appropriate;

The potential for reuse of grey water (from baths) be investigated to reduce the demand for fresh water;

The packaged sewage treatment facility be staffed by well-trained personnel and that there are sufficient spare parts available at all times;

The volume of wastewater being produced should be reduced where possible by implementing measures to reduce water usage.

Monitoring Measures




Issues / Impacts General Waste Management




Mitigation Measures

Ensure all waste disposal facilities and transportation is registered with the relevant Malagasy authorities;

Apply the principles of the waste management hierarchy (prevention at sources, minimisation, reuse, recycling and disposal) to all waste streams;

Ensure that the OP - Integrated Waste Management will cover all aspects of the proposed project and will facilitate correct identification, quantification, management, disposal and monitoring of waste streams. This will involve:

o Conducting an initial audit of general waste management on site to establish status quo; o Complete baseline inventory of general waste produced on site including estimated quantities; o Classify general waste and purchase different coloured bins coding for each class of waste stream identified; o Prepare list showing the number and location of bins and other receptacles for general waste on site; o Conform to National legislative requirements pertaining to the management of general solid waste.

Introduce reasonable measures to minimise contamination where waste streams have the potential to contaminate water or soil. Among others, this will include:

o Fuel, oils and grease will be stored on impermeable surfaces with containment bunds and grease and oil traps; o Traps will be regularly cleaned; o Disposing of waste at the correct waste facility as quickly as is possible; o Avoiding or reducing waste generation at source.

Store all wastes in such a manner so as to minimise potential contamination of stormwater;

Implement water quality monitoring wherever waste streams are to be disposed of; and

Subject waste management procedures and facilities, including landfill sites, to regular audits by suitably trained personnel.

The principles of the waste management hierarchy (prevention at sources, minimisation, reuse, recycling and disposal) must be applied to all waste streams;

An Integrated Waste Management System covering all aspects of the proposed project must be implemented to facilitate correct identification, quantification, management, disposal and monitoring of waste streams;

Where waste streams have the potential to contaminate water or soil, measures should be introduced to minimise contamination (eg. oil traps);

All wastes should be stored in such a manner so as to minimise potential contamination of storm water;

Wherever waste streams are to be disposed of, water quality monitoring should be implemented;

Waste management procedures and facilities should be subjected to regular audits by suitably trained personnel.

Shipboard compression and storage of waste for shore disposal should be mandatory. Education, monitoring and enforcement must be implemented to circumvent the ingrained habit of disposing ships’ waste overboard.

To manage non-process general waste Toliara Sands will:

Ensure all non-process waste disposal facilities and transportation is registered with the appropriate Malagasy authorities;

Ensure all wastes are managed according to the requirements of Malagasy legislation;

Ensure all general wastes that cannot be reused or recycled should be stored temporarily in a fenced, secured, centralised area and then transported regularly to the nearest licensed sanitary landfill facility for responsible disposal;

Ensure all bins for temporary storage of waste that are located outdoors are covered to prevent ingress of water and access by animals;



Develop a comprehensive OP - Integrated Waste Management for the site including Key Performance Indicators (KPIs) against which the management of wastes can be audited;

Inform all employees, contractors and visitors to the site of correct waste management procedures;

All waste streams will be handled according to Malagasy legislative requirements or international best practice, whichever is most stringent;

All waste streams will be handled and disposed of by authorised personnel;

Removal of any waste from site by unauthorised individuals will be prevented;

No on-site burying or dumping of any waste materials, litter or refuse shall occur anywhere other than a licensed land fill;

All solid waste will be transported by serviceable vehicles;

Refuse screens will be installed at runoff concentration points from large wash bays, stormwater outlets, drainage points, ablution and eating areas; and

Contractors will prevent discharge of any pollutants, such as cements, concrete, lime, chemicals and fuels into any water source.

Where possible, all hazardous wastes, including hydrocarbon wastes such as oils, should be recycled either by a recognised recycling company or returned to the supplier;







As soon as final project plans are available, the size of all waste streams should be determined as accurately as possible so as to facilitate the development of an appropriate waste management plan.

Monitoring Measures




Issues / Impacts Installation of Pump Stations


Mitigation Measures

The installation of pumps for water abstraction from surface or groundwater resources must be undertaken in a manner that does not impact on the integrity of these resources. The eventual placement of these abstraction pump stations must be approved by the K-CM and EPCM-EHSC.

Ensure that water abstraction points do not degrade or erode as a result of leaking pipes, spills, muddy conditions or washaways. Rectify problems as soon as they arise.

Pumps shall be placed over a drip tray in order to prevent fuel spills and leaks from contaminating the water in the pumped area.



Contaminated water may not be discharged into existing watercourses or streams.

Monitoring Measures




Issues / Impacts Fire Control


Mitigation Measures

No fires may be lit on site.

Any fires that occur shall be reported to the C-ESO and EPCM-EHSC immediately.

Smoking shall not be permitted in those areas where it is a fire hazard. Such areas shall include the workshop and fuel storage areas and any areas where the vegetation or other material is such as to make liable the rapid spread of an initial flame.

The EPCM contractor shall appoint a Fire Officer who shall be responsible for ensuring immediate and appropriate actions in the event of a fire and shall ensure that employees are aware of the procedure to be followed. The contractor shall forward the name of the Fire Officer to the EPCM-EHSC for his approval.

The EPCM contractor shall ensure that there is basic fire fighting equipment available on site at all times. This shall include rubber beaters and at least one fire extinguisher of the appropriate type when welding or other “hot” activities are undertaken.

All construction staff must be trained in fire hazard control and fire fighting techniques.

All flammable substances must be stored in dry areas which no not pose an ignition risk to the said substances.

A minimum requirement for construction in a high fire risk area is a water truck or cart, with a minimum capacity of 5000 litres, equipped with pump and hose (minimum length 30m) which must be permanently on site.

The EPCM contractor shall supply all Ranobe Mine Project living quarters, site offices, kitchen areas, workshop areas, materials, stores and any other areas identified by the C-ESO and EPCM-EHSC with tested and approved fire fighting equipment.

Do not store gas and liquid fuel in the same storage area.

Take immediate steps to extinguish any fire which may break out on the construction site.

Restrict contained fires for heating and cooking (i.e. in a fire drum) to designated areas on site. Prevent employees from creating fires randomly outside designated areas.

A barbeque facility may be considered at the discretion of the C-ESO and EPCM-EHSC. The area shall be away from flammable stores. All events shall be under management supervision and a fire extinguisher shall be immediately available.

Establish and maintain fire breaks around the site if as and when specified by C-ESO and EPCM-EHSC.

Monitoring Measures






Issues / Impacts Safety and Risk Management


Mitigation Measures

The EPCM contractor shall develop and implement an OHS procedure to ensure that hazards to workers by way of site security, hazards, electrical and welding works etc. are controlled. Adequate training, audits and corrective actions to be implemented based on review of these incidents.

The EPCM contractor shall deploy suitable site security and loss prevention measures, working in coordination with EPCM-EHSC.

The safety of all construction contractor personnel, as well as any member of the public on the site is the responsibility of the EPCM contractor who will only be responsible for safety on the construction sites. Existing mining areas and supporting infrastructure sites (workshops, Plant etc.) remain under the control of World Titanium Resources’s operations personnel. The EPCM contractor will ensure that:

o First aid / emergency facilities / procedures are in place o All personnel are trained in basic site safety procedures o A register with contact numbers of all people employed and one relative for each is developed and maintained o A list of all relevant emergency numbers in an easily accessible location on site o A record of all incidents, accidents and illnesses on site is kept and this information made available at meetings

Personal Protective Equipment (PPE) must be made available to all construction staff and must compulsory. Ensure that employees are issued with and make use of the necessary safety equipment when working in dusty, noisy and / or dangerous situations. Such equipment may include, but is not necessarily limited to hardhats, goggles, masks, earplugs, gloves, safety footwear and safety ropes as required.

Ensure that adequate drinking water, wash water and sanitary facilities are available at all times and on all work sites.

Ensure that personnel are transported legally, and in a safe and responsible manner.

Ensure that all vehicle and machine operators are qualified and licensed to operate their vehicles.

Respect workers’ right to refuse work in unsafe conditions

The EPCM contractor must ensure that all construction workers are well educated about HIV/ AIDS and the risks surrounding this disease. The location of the local clinic where more information and counselling is offered must be indicated to workers.

Material stockpiles or stacks, such as pipes must be stable and well secured to avoid collapse and possible injury to site workers or local residents.

Potentially hazardous areas such as trenches are to be demarcated and clearly marked. Adequate warning signs of hazardous working areas. Demarcate these areas with hazard tape or fencing as required and post the appropriate danger signs.

Labour should be transported to and from the site to discourage loitering in adjacent areas and possible increase in crime or disturbance.

Unsocial activities such as unauthorised consumption or illegal selling of alcohol, drug utilisation or selling and prostitution on site should be banned. Any persons found to be engaged in such activities should receive disciplinary or criminal action taken against them.



Monitoring Measures




Issues / Impacts Erosion and sedimentation control


Mitigation Measures

Design permanent watercourse crossings and construct in a manner that does not alter the flow of water in the watercourses;

Rehabilitate all slopes and degraded areas before the onset of the rainy season. Use topsoil as much as possible in this rehabilitation;

Develop procedures to minimize surface water run-off, soil erosion and sedimentation;

Wherever practically possible, maintain a well vegetated buffer at least 30m wide adjacent to operational sites, all drainage lines and other wetland areas, and areas likely to be a source of fines;

Use mitre drains to spread flows in roadside drains onto adjacent slopes;

Protect footpaths and tracks on steep slopes from runoff related erosion (e.g. use of low berms at short intervals);

Construct sediment retention dams downstream of large sources of fines;

Ensure that culverts are suitably sized to accommodate at least low and moderate flows;

Ensure that substrate continuity is considered during the design of river crossings;

Ensure the provision of suitably designed causeways across rivers in the project area that allow free movement of fish and other aquatic biota.

Side drains will be constructed on slopes leading to water courses to prevent sediment-laden water from entering the watercourses;

River and stream road crossings will be culverted;

Strictly control worker movements near water courses;

Implement containment and stormwater management measures to prevent the loss of topsoil;

Employ soil erosion control measures, such as protection berms, where necessary to minimize soil erosion;

Prevent vehicle access to wet areas by clearly marking these areas as no go with danger tape, where practicably possible; and

Ensure that construction activities do not increase sedimentation, erosion or eutrophication.

Monitoring Measures








Mitigation Measures

Burn fire breaks around the mine site;

Accommodate communal burning by maintaining open channels of communication and vigilant monitoring of fires outbreaks; and

Ensure that appropriate fire-fighting equipment is available to protect Toliara Sands property

Monitoring Measures




Issues / Impacts Soil quality


Mitigation Measures

Topsoil will be stripped and stockpiled separately from the subsoils wherever possible;

Soils removed from the haul roads and access routes must be stored as close as possible to these linear structures and separately managed in stockpiles that can be easily used for rehabilitation of the infrastructure at closure;

Every effort will be made not to disturb or work the soils during the wet months to avoid compaction;

Topsoil will be stored in berms or on a compacted footing as close to the areas where the soils will be needed for rehabilitation purposes;

The slopes of all stockpile facilities and berms will be constructed with slopes of 1:6 or shallower; this will minimise the chances of erosion of the topsoil, and allow for the mechanical management of the soils on the slopes;

Prior to the planting of vegetation, erosion control measures, (construction of gabion benches and cut-off drains) will be included in the stockpile/berm design;

The soil storage facilities and berms will comprise a series of 1.5 m terraces if the height required is >1.5 m, with a maximum elevation above ground level of 15 m if possible;

The topsoil can, if necessary be utilised to top dress the stockpiles;

If used, it is imperative that the topsoils that are used to cap the stockpile structure are well protected from erosion and compaction. These topsoils must be adequately vegetated as soon after construction as possible and maintained throughout the life of the mine. Fertilizer and manure will be added if required;

Areas to be vegetated will be ripped to ensure adequate mixing has occurred. The area can then be seeded with an appropriate seed mix;

Newly seeded/planted areas will be protected against compaction and erosion;



Traffic will be limited were possible while the vegetation is establishing itself;

Plants will be weeded regularly, and watered if necessary at first to establish rooting;

Unhealthy or dead plant material will be replaced;

All seeded and grassed areas will be fertilised with 200 kg/ha after germination if required

Monitoring Measures




Issues / Impacts Air Quality


Mitigation Measures

Ensure that crushers are designed with dust suppression systems;

Design the stacker chutes with adjustable chutes so that drop heights can be minimised during stacking;

Educate employees about the environmental risks of their work, and how tasks can be performed to avoid causing significant emission of dust and other pollutants;

Top dress and seed (when necessary) storage piles as soon as practicable;

Install and operate dust extraction equipment on drill rigs, such as filters;

Reduce drop heights of loading of ore wherever practicable;

Protect loading and tipping activities from wind where practicable;

Operate the crusher according to design specifications;

Maintain dust extraction and filter equipment on the crusher according to specification;

Protect material on conveyors by use of wind and roof boards;

Shelter transfer points from wind;

Impose vehicle speed restrictions on site and haul roads;

By increasing the payload of the truck, fewer trips will be required to transport the same amount of material.

Maintain high moisture content on unpaved site and haul road surfaces to bind the silt or routinely apply an appropriate binding agent;

Prevent the build-up of surface dust on paved site roads by wetting; and

Pave high traffic volume areas where practicable, e.g. access road from main gate to administration offices.

As unpaved roads are predicted to be a major source of emissions it is suggested that the proposed mitigation measure of the application of water to the MLA roads is implemented. The minimum control efficiency that should be achieved should other methods be implemented is 75%.

The design controls (i.e. regular watering of mine haul roads to achieved 75% mitigation) must be implemented and maintained throughout the life of the mine.



It is recommended to implement particulate and gaseous emissions controls as provided by the IFC.

Continuous emissions monitoring for particulates be implemented on the dryer flue gas to ensure compliance with the IFC requirements.

Continuous emissions monitoring for particulates, sulphur dioxide and oxides of nitrogen be implemented on the dryer flue gas to ensure compliance with the requirements.

The PM10 ambient monitoring be done to the west of the area of activity. The exact location would depend on the mine schedule.

PM10 measurement can be economically carried out by the use of “mini-vol” samplers.

Diesel Particulate Filters (DPF‘s) can be fitted to vehicles.

Use of better quality diesel.

Effective inspection and maintenance programs can ensure new vehicles remain in good condition and reduce emissions from old vehicles

Monitoring Measures




Issues / Impacts Scrap and Obsolete Equipment


Mitigation Measures

Develop an Integrated Waste Management Operating Procedure for the facility that addresses the management of scrap and obsolete equipment, including tyres;

Store all scrap in designated areas, preferably at a safe distance from any surface water features;

As far as possible, divert storm water around the scrap storage areas;

Employ good house-keeping at the scrap storage area at all times;

Prevent unauthorised individuals from removing scrap from the site;

Store scrap likely to contain hazardous liquids, including lubricants or hydraulic fluids, in such a way as to minimise pollution of soil and water;

Inspect the scrap storage area regularly for signs of soil pollution and where this is detected, implement remediation measures immediately;

Develop education material for workers regarding all forms of waste and how to manage waste properly. This will include a strict code of conduct for workers movements and behaviour (e.g. ablutions in river a problem); and

Develop monitoring indicators and a monitoring programme.

The Integrated Waste Management Plan or waste management procedure for the facility should address the management of scrap and obsolete equipment, including tyres;

All scrap or obsolete equipment that may potentially be contaminated with elevated levels of radionuclides (TENORM) should be managed and disposed of according to international best practice;

All scrap must be stored in designated areas, preferably a safe distance from any surface water features;



As far as possible, storm water must be diverted around the scrap storage areas;

Good house-keeping must be employed at the scrap storage area at all times;

Unauthorised individuals must be prevented from removing scrap from the site and the scrap area should be secured;

Where scrap is likely to contain hazardous liquids, including lubricants or hydraulic fluids, these items must be stored in such a way as to minimise pollution of soil and water;

The scrap storage area must be inspected regularly for signs of soil pollution and where this is detected, remediation measures must be implemented immediately;

Where scrap items are likely to release hydrocarbons or other hazardous chemicals, they must be stored on an impermeable surface to minimise the risk of contamination of soil and water;

All scrap, including waste tyres, must be stored in such a way so as to minimise the formation of stagnant water that will facilitate breeding of mosquitoes;

Monitoring Measures




Issues / Impacts Visual Intrusion


Mitigation Measures

To manage visual impacts Toliara Sands will:

Ensure that where such lighting is deemed necessary low-level lighting, which is shielded to reduce light spillage and pollution, is used;

Night lighting of construction sites should be minimised within requirements of safety and efficiency.

Ensure that external lighting makes use of down-lighters shielded in such a way as to minimise light spillage and pollution beyond the extent of the area that needs to be lit;

Shield security and perimeter lighting so that minimal light falls outside the area needed to be lit. Overly tall light poles are to be avoided where possible;

Ensure that no naked light sources are directly visible from a distance. Only reflected light will be visible from outside the site; and

Avoid placing light sources on hills or high points as these will be visible from a greater distance.

Strict dust management procedures should be employed.

Clearance of indigenous vegetation should be minimised and rehabilitation of temporarily cleared areas should start as soon as possible.

Fire prevention control measure during construction must be implemented.

Maintenance of construction site – good housekeeping on site to avoid litter and minimise waste.

Rehabilitation of cleared areas.

Project developers should demarcate construction boundaries and minimise areas of surface disturbance.



Locate laydown areas and construction camps in low visibility areas.

Limit clearance of vegetation to a minimum.

Disturbed areas should be shaped and stabilised as soon as possible to minimise erosion potential (use temporary erosion control devices such as mulch or woody debris to stabilise soil prior to establishment of vegetative cover for temporarily cleared areas).

Inspect and repair erosion control measures on a regular basis to maintain functionality.

Locate borrow pits in low visibility areas where possible.

Locate site compounds and laydown areas in low visibility areas away from villages.

Maintenance of construction site – good housekeeping on site to avoid litter and minimise waste.

Night lighting of construction sites should be minimised within requirements of safety and efficiency.

Maintain as much natural vegetation as possible between the mine buildings and the perimeter of the mine.

The layout for mine buildings should include vegetation such as trees and thicket to break up straight lines of buildings as much as possible. A landscape architect should be consulted to aid in designing a practical layout that will create least contrast in colour, texture and pattern with the surrounding landscape.

Muted colours that blend in with the natural background vegetation/landscape should be used on all buildings. Colours that blend in with colours of the earth, rocks and vegetation are normally more visually pleasing than colours chosen to match the sky.

Dust emissions in and around the mine site must be strictly managed and limited.



3.16 Operational Phase Specifications This section of the ESMP outlines the environmental specifications which are required to be implemented and maintained throughout the operational phase for the Ranobe Mine Project.

Operational Phase Environmental & Social Management Plans

Component (Impact Category) Noise

Issues / Impacts Noise


Mitigation Measures

Comply with maximum legal noise limits within the mining area and at the perimeter;

Maintain equipment and vehicles in good condition, serviced regularly, etc.;

Conduct periodic testing and screening to ensure compliance with noise standards;

Have sound proofing and ear protection equipment in areas of the plants where the noise levels are above legal limits for working; and

Where possible blasting will be restricted to daylight hours. Given that it is not possible to eliminate all noise during the operational phase, the following general recommendations are made:

The general guidelines for noise reduction in new developments should be implemented. These include: o Selecting equipment with lower sound power levels. o Installing suitable mufflers on engine exhausts and compressor components. o Installing acoustic enclosures for equipment to stop noise at source.

The efficacy of the mitigation measures must be measured once the operational phase has commenced. This should be done by conducting an environmental noise survey.

Monitoring Measures


Component (Impact Category) Safety and security





Mitigation Measures

Burn fire breaks around the mine site;

Accommodate communal burning by maintaining open channels of communication and vigilant monitoring of fires outbreaks; and

Ensure that appropriate fire-fighting equipment is available to protect Toliara Sands property

Monitoring Measures


Component (Impact Category) Ecology

Issues / Impacts Stormwater management


Mitigation Measures

Ensure that the quality of all liquid waste streams discharged from the site, including storm water, are monitored regularly to ensure compliance with the requirements of Malagasy legislation or, where these do not exist, guideline limits set by the IFC for the mining sector;

The Storm and Process Water Operating Procedure will cover all mining associated activities;

Monitor the quality of the discharged process water to determine that the chemical content of the discharges comply with Malagasy effluent standards;

Direct stormwater away from stockpiles;

Apply industry best practice to prevent pollution by ensuring full containment of contaminated run-off from any area from which pollutants may be washed off into watercourses;

Minimise discharge of pollutants by ensuring all run-off from machine wash areas pass through an oil trap and that all run-off water passes through a settling step to remove the majority of suspended solids prior to discharge to the environment. All settled material will be disposed of appropriately at a registered waste disposal site;

Assess the radioactivity levels of the recycled water periodically;

All chemicals of all types will be stored on impermeable surfaces in secure and bunded designated storage areas. Spills will be cleaned up immediately in accordance with an established protocol;

Storage of hazardous substances on an impermeable surface and with a bund wall to contain at least 110 % of the volume of the largest container contents to prevent surface water pollution;

Contain all contaminated water on site; and

Keep all vehicles and equipment in good working order and repair oil or fuel leaks immediately upon detection, in a dedicated vehicle maintenance area;

Implement measures to optimise the separation of clean and dirty water on the mine’s property;

Monitoring Measures





Issues / Impacts Erosion and Sedimentation Control


Mitigation Measures

Rehabilitate all slopes and degraded areas before the onset of the rainy season. Use topsoil as much as possible in this rehabilitation;

Develop procedures to minimize surface water run-off, soil erosion and sedimentation;

Wherever practically possible, maintain a well vegetated buffer at least 30m wide adjacent to operational sites, all drainage lines and other wetland areas, and areas likely to be a source of fines;

Use mitre drains to spread flows in roadside drains onto adjacent slopes;

Wherever practically possible, carry out most of the vegetation clearance during the dry season;

Protect footpaths and tracks on steep slopes from runoff related erosion (e.g. use of low berms at short intervals);

Keep the size of the area cleared of vegetation to a minimum and re-vegetate as soon as is practically possible;

Ensure that culverts are suitably sized to accommodate at least low and moderate flows;

Ensure that substrate continuity is considered during the design of river crossings;

Ensure the provision of suitably designed causeways across rivers in the project area that allow free movement of fish and other aquatic biota.

Strictly control worker movements near water courses;

Implement containment and stormwater management measures to prevent the loss of topsoil;

Identify no go areas within the site (namely 30 m buffers along river courses and wetlands, no go area within the site);

Avoid activities on the banks of watercourses as far as possible;

Employ soil erosion control measures, such as protection berms, where necessary to minimize soil erosion;

Prevent vehicle access to wet areas by clearly marking these areas as no go with danger tape, where practicably possible

Monitoring Measures



Issues / Impacts Fauna and Flora


Mitigation Measures

Keep clearing of vegetation to a minimum;

Development of all road linkages will employ, where possible, existing tracks and roads;

Avoid blockage or diversion of rivers and streams where possible;



Avoid indirect effects of run-off erosion and sedimentation from roads that may lead to loss of riparian habitats;

Employ a horticultural specialist and apply industry standards for the management of the nursery;

More research on new species of any kind, to determine their importance at the local, regional and national level, will be undertaken;

Avoid applying herbicides, and if essential they shall only be applied by approved manufacturers;

Prohibit hunting and killing of animals by mine staff, and the sale of bushmeat in the mine village and to mine staff;

Ensure that the security staff has received environmental training that includes protection of fauna and flora. This must form a component of site security;

Ensure that site environmental personnel regularly inspect all areas of the site;

Strictly enforce speed limits within the mining area;

Night driving will be avoided as much as possible to avoid animal deaths, especially that of amphibians and reptiles;

Fences around the concession area that curtail faunal movements will be avoided;

Security fences around the mine complex will, where possible, be permeable to small animals;

To avoid fires which will negatively affect the surrounding vegetation and animal habitats: o Storage of highly flammable material (e.g. fuel) on site will be in adequately protected, secure sites, with facilities for fire fighting available; o Vegetation surrounding the mine complex will be controlled to reduce the risk of fire spread; o All litter, refuse, etc., will be regularly removed from the mine site; o The cultural practice of slash and burn farming practices every dry season will be discouraged at workshops and subsistence farmers will be

educated about the long-term effects of un-natural fire regimes.

To avoid chemical pollution which may negatively impact on the surrounding fauna and flora: o Chemical stores (including fuel, insecticides, etc.) will be bunded and locked at all times; o Access to such stores will be controlled at all times; o Inventories of stored chemicals will be maintained, and their use regulated; o All cautions/recommendations with respect to storage and use of hazardous chemicals will be implemented;

Develop and manage alien species by clearing alien plants as they appear.

Maintain an Alien Invasive Species Control Programme to prevent the proliferation of alien invasive vegetation during all phases of the project;

The introduction of alien fauna, including domestic pets such as cats and dogs, will be prohibited to the mine site; and

Develop guidelines to manage indirect effects on aquatic ecological systems such as rivers and wetlands.


Damage to sensitive habitats during ongoing and future survey work and site development be avoided as far as possible. This is particular important where new roads are developed as they rapidly lead to strip development and increased resource extraction (e.g. charcoal production).

Fire breaks be developed around all project infra-structure.

Short, fire-resistant vegetation cover should be established to avoid erosion and siltation into drainage lines.

The chemical control of unwanted vegetation with herbicides, and pest animals with insecticides should be fully controlled and be in accordance with national controls of banned substances.

Access to all mine areas should be controlled, and all resource extraction controlled and documented, and remain in accordance with sustainable off-take.

The sale and use of unsustainable extracted resources (e.g. charcoal) in all mine facilities should be prohibited.

While navigating the Toliara bay vessels will be required to move at reduced speeds so as to allow any slow moving marine animals time to move out the



ships path, alternatively, for the vessel to take avoiding action. In periods of high animal presence or movement (as confirmed by visual observation, fishermen or other sources) an alert to this effect must be communicated to all relevant vessels. Vessels arriving from open water entering the bay generally use the northern navigation channel of Toliara bay and should also post lookouts on approach to scan for any marine animal presence. This is likely to be limited in effectiveness in that only large species such as whales will be observable (in comparison say to turtles). It is anticipated that low vessel speeds will, in general, allow for the safe movement of these animals out of their path.

Avoid unnecessary dredging, piling or vessels movements.

A ballast-water plan must be adopted, including recommendations and requirements for hold cleaning, oceanic ballast exchange and ballast inspection and testing on arrival at Toliara. The latter should be followed, even if impractical to complete before commencement of ballast discharge, as records can be kept on the performance of the procedures for their improvement. The ballast-water plan must be regularly reviewed and updated to keep up with progress in this field, and be in line with IMO stipulations in this regard.

With respect to managing ecological processes and mitigating for vegetation loss Toliara Sands will:

Active culling programs of problem animals undertaken by conservation authorities and the prohibition of the introduction of alien aquatic and terrestrial species unless a full environmental assessment is undertaken and control methods for escapees detailed.

Protection and where necessary, rehabilitation of adjacent habitats as an environmental offset, particularly wetland and forest habitats

The protection and/or full rehabilitation of sensitive habitats, particularly forest habitats which are home to most of the threatened species.

Natural drainage should be maintained and the silt loads into rivers, streams and wetlands must stay within normal limits.

Monitoring Measures


Component (Impact Category) Air

Issues / Impacts Air Quality


Mitigation Measures

Ensure that crushers are designed with dust suppression systems;

Design the stacker chutes with adjustable chutes so that drop heights can be minimised during stacking;

Educate employees about the environmental risks of their work, and how tasks can be performed to avoid causing significant emission of dust and other pollutants;

Top dress and seed (where necessary) storage piles as soon as practicable;

Install and operate dust extraction equipment on drill rigs, such as filters;

Reduce drop heights of loading of ore wherever practicable;

Protect loading and tipping activities from wind where practicable;

Operate the crusher according to design specifications;

Maintain dust extraction and filter equipment on the crusher according to specification;



Protect material on conveyors by use of wind and roof boards;

Shelter transfer points from wind;

Impose vehicle speed restrictions on site and haul roads;

By increasing the payload of the truck, fewer trips will be required to transport the same amount of material.

Maintain high moisture content on unpaved site and haul road surfaces to bind the silt or routinely apply an appropriate binding agent;

Prevent the build-up of surface dust on paved site roads by wetting; and

Pave high traffic volume areas where practicable, e.g. access road from main gate to administration offices.

As unpaved roads are predicted to be a major source of emissions it is suggested that the proposed mitigation measure of the application of water to the MLA roads is implemented. The minimum control efficiency that should be achieved should other methods be implemented is 75%.

The design controls (i.e. regular watering of mine haul roads to achieved 75% mitigation) must be implemented and maintained throughout the life of the mine.

It is recommended to implement particulate and gaseous emissions controls as provided by the IFC.

Continuous emissions monitoring for particulates be implemented on the dryer flue gas to ensure compliance with the IFC requirements.

Continuous emissions monitoring for particulates, sulphur dioxide and oxides of nitrogen be implemented on the dryer flue gas to ensure compliance with the requirements.

The PM10 ambient monitoring be done to the west of the area of activity. The exact location would depend on the mine schedule.

PM10 measurement can be economically carried out by the use of “mini-vol” samplers.

Diesel Particulate Filters (DPF‘s) can be fitted to vehicles.

Use of better quality diesel.

Effective inspection and maintenance programs can ensure new vehicles remain in good condition and reduce emissions from old vehicles

Monitoring Measures


Component (Impact Category) Waste

Issues / Impacts Solid Waste Management


Mitigation Measures

Collect all general and domestic waste in adequate numbers of litter bins located as required on the work site.

Litter bins must be equipped with a closing mechanism to prevent their contents from blowing out. Waste and litter shall be disposed of into scavenger- and weather-proof bins. The EPCM contractor shall then remove the refuse collected from the working areas, from site at least once a week.

Where feasible, collect waste paper, glass and metal waste separately and arrange for collection by recycling contractors.

Unless otherwise specified by the C-ESO, remove stored domestic waste to the nearest solid waste disposal facility.

Ensure that solid waste is transported properly, avoiding waste spills en-route.



No solid or liquid waste disposal is to take place on site, and ensure that only non-toxic materials which have no risk of polluting the groundwater are buried at the mine’s designated waste disposal facility.

Non-hazardous flammable waste may be burned in a properly designed and maintained incinerator. No open burning is permitted.

A register system for hazardous waste disposal (that incorporates a safe disposal certification scheme) must be implemented. It should as a minimum record the weight and volume of hazardous wastes being disposed, disposal contractor details, disposal facility, and dates of disposal, and include third party evidence of safe disposal, for example receipts from the disposal facility.

Monitoring Measures



Issues / Impacts Hazardous Substances Management


Mitigation Measures

Ensure compliance with all national, regional and local legislation and applicable standards with regard to the storage, transport and use of hydrocarbons, chemicals, solvents, and any other harmful and hazardous substances and materials.

Store all hazardous substances in secure, safe and weatherproof facilities, underlain by a bunded concrete slab to protect against soil and water pollution. Proper storage facilities for the storage of oils, paints, grease, fuels, chemicals and any hazardous materials to be used must be provided to prevent the migration of spillage into the soil, surface and groundwater regime around the temporary storage area(s).

These pollution prevention measures for storage should include a lined and impermeable bund wall high enough to contain at least 110% of any stored volume, and this should be sited in a suitable area away from drainage lines.

Storage areas containing hazardous substances/materials must be clearly signposted.

Designate and construct controlled loading/unloading areas, underlain by an impervious paving or PVC sheeting to protect against soil and water pollution.

The C-ESO shall keep a register of all hazardous substances stored on site for regular submission to the EPCM EHSC for review. If necessary a separate store for the contractor may be established adjacent to the existing mine store. This must be to the same specifications and access thereto must be controlled by the C-ESO.

Material Safety Data Sheets (MSDSs) shall be readily available for all chemicals and hazardous substances to be used on site. Procedures detailed in the MSDS must be followed in the event of an emergency situation. Where possible the available MSDSs should additionally include information on ecological impacts and measures to minimise negative environmental impacts during accidental releases or escapes.

Staff dealing with these materials/substances must be aware of their potential impacts and follow the appropriate safety measures.

The EPCM-EHSC and C-ESO will be responsible for ensuring that all accidental spills must be cleaned immediately, treating the spilled material and used cleaning products as hazardous waste. Contaminated soil not suitable for bioremediation will be treated as hazardous waste.

The EPCM-EHSC will ensure that personnel handling hazardous substances have been educated in terms of the correct handling, use and disposal thereof.

Empty containers in which hazardous substances were kept are to be treated as hazardous waste. Collect any hazardous waste in appropriate containers



located on a drip tray on site pending disposal.

No paint products may be disposed of on site and brush/roller wash facilities shall be established to the satisfaction of the C-ESO. Oil based paints and chemical additives and cleaners such as thinners and turpentine shall be strictly controlled.

General and hazardous wastes should be separated at source.

Where temporary storage of hazardous wastes is required, this should be undertaken in a secure area protected from the elements and designed and operated according to international best practice.

All waste streams must be handled and disposed of by authorised personnel.

Removal of any waste from site by unauthorised individuals must be prevented.

All staff should be trained in the correct handling, storage and disposal of hazardous wastes;

The integrity and roadworthiness of all vehicles used for the transportation of wastes must be checked regularly.

Retain waste oils and batteries for recycling by the supplier wherever possible.

Ensure all hazardous waste disposal facilities and transportation of hazardous waste is registered with the relevant Malagasy authorities;

Where possible, all hazardous wastes, including hydrocarbon wastes such as oils, are recycled either by a recognised recycling company or returned to the supplier;

All empty and externally dirty tanks that may have contained hazardous materials, including hydrocarbons, are sealed and stored on an area where the ground has been protected;

Oil-water separators / oil traps will be installed on drains in all areas where hydrocarbons may contaminate water, and these traps will be maintained in good working order;

Any fuel spills will be adsorbed onto a suitable absorbent and disposed together with oils and grease;

Characterise (including the quality and quantity) all hazardous waste to ensure wastes are identified, quantified and managed correctly;

Store all hazardous waste temporarily in a dedicated and purpose built facility pending removal from site for final containment. Where possible, empty containers will be returned to suppliers. The facility will be lined (and bunded) with concrete and roofed to stop runoff or surface water contamination;

Develop a Hazardous Chemical Operating Procedure for the facility, including detailed spill response procedures;

Develop SOP’s for hazardous waste segregation, storage, shipping, receiving, usage and disposal;

Store all hazardous chemicals of a volume equal to or greater than 250 litres in a bunded facility that complies with legislative requirements and best practice;

Develop a Hydrocarbon Management OP and implement to provide for the proper storage and handling of hydrocarbons on site and hence to prevent any form of contamination;

Dispose of soil contaminated with hydrocarbons immediately at a soil bioremediation facility on site;

Ensure Material Safety Data Sheets (MSDS) for all hydrocarbons and chemicals are available at all sites where hydrocarbons/chemicals are present and copies will be kept at the environment health and safety department;

Do not dispose of hazardous wastes into drains, as this may impact negatively on the performance of the sewage treatment plant. This, in turn, could result in the discharge of partially-treated sewage to the environment;

Undertake regular maintenance of vehicles and pumps located near water courses;

Vehicles will be serviced only on impermeable surfaces with containment bunds and grease traps. Traps will be regularly serviced;

Temporary storage of hazardous wastes will be in a secure area; and

All staff will be trained in the correct handling, storage and disposal of hazardous wastes. Where possible, all hazardous wastes, including hydrocarbon



wastes such as oils, should be recycled either by a recognised recycling company or returned to the supplier;







As soon as final project plans are available, the size of all waste streams should be determined as accurately as possible so as to facilitate the development of an appropriate waste management plan

Monitoring Measures



Issues / Impacts Sewage Waste Management


Mitigation Measures

Ensure the provision of appropriate temporary sanitation systems and packaged effluent treatment plant be used during the operational phase;

The sewage treatment facility be staffed by well-trained personnel and that there are sufficient spare parts available at all times;

Options for reuse and beneficiation of treated sewage water will be investigated. This may include composting;

Effluent quality must be monitored and must meet Malagasy or the IFC’s guideline values, whichever is more stringent;

Washing, whether of the person or of personal effects, and acts of excretion and urination are strictly prohibited other than at the facilities provided;

Sanitation facilities shall be located within 100 m from any point of work, but not closer than 50 m to any water body;

All sewage treatment plants must be well maintained and operated at all times. To this end, at least one employee on site must be trained to operate and maintain the system(s);

The performance of the sewage treatment systems must be monitored regularly. Where a system is found to be performing poorly, the cause of the poor performance must be investigated and remediation measures put in place to restore performance;

The environmental monitoring programme for the facility must incorporate monitoring points that are able to detect a negative impact on the environment associated with the discharge of treated sewage;

Ensure all toilets on site lead into septic tanks or a package treatment plant;

Ensure that septic tanks are regularly emptied into a series of oxidising ponds. The ponds will be designed according to best practice and will be lined. Waste water will lead from the ponds into a dedicated wetland where further cleaning of water will occur.

Mitigation measures aimed at reducing water consumption could include the installation of low or dual-flush toilets if considered socially acceptable; and

Where other toilet types and showers are required, employees will be trained to conserve water.

All wash water and sewage from all sites must be diverted to the appropriate facilities for treatment and must meet the discharge standards of Madagascar or the IFC (2007) prior to release into the process water dam or the environment;



If pit latrines (VIP) are used, they must be sited, constructed and maintained in a way that minimises the risk of contamination of surface and sub-surface water resources;

All sewage treatment facilities should be well maintained. To this end, at least one employee on site must be trained to maintain the system(s);

The performance of the sewage treatment systems must be monitored regularly. Where a system is found to performing poorly, the cause of the poor performance must be investigated timeously and remediation measures put in place to restore performance;

In the event that sludge must be removed from the system(s), it must be disposed in a manner that minimises potential risk to human health and the environment and should comply with the National legislation;

The environmental monitoring programme for the facility must incorporate monitoring points that are able to detect a negative impact on the environment associated with the discharge of treated sewage.

Investigations be conducted into the most appropriate sanitation system to serve the mine community based on social, biophysical and economic considerations;

The potential for reuse of grey water (from baths) be investigated to reduce the demand for fresh water;

The packaged sewage treatment facility be staffed by well-trained personnel and that there are sufficient spare parts available at all times;

The volume of wastewater being produced should be reduced where possible by implementing measures to reduce water usage.

Monitoring Measures



Issues / Impacts General Waste Management


Mitigation Measures

Ensure all waste disposal facilities and transportation is registered with the relevant Malagasy authorities;

Apply the principles of the waste management hierarchy (prevention at sources, minimisation, reuse, recycling and disposal) to all waste streams;

Ensure that the OP - Integrated Waste Management will cover all aspects of the proposed project and will facilitate correct identification, quantification, management, disposal and monitoring of waste streams. This will involve:

o Conducting an initial audit of general waste management on site to establish status quo; o Complete baseline inventory of general waste produced on site including estimated quantities; o Classify general waste and purchase different coloured bins coding for each class of waste stream identified; o Prepare list showing the number and location of bins and other receptacles for general waste on site; o Conform to National legislative requirements pertaining to the management of general solid waste.

Introduce reasonable measures to minimise contamination where waste streams have the potential to contaminate water or soil. Among others, this will include:

o Fuel, oils and grease will be stored on impermeable surfaces with containment bunds and grease and oil traps; o Traps will be regularly cleaned;



o Disposing of waste at the correct waste facility as quickly as is possible; o Avoiding or reducing waste generation at source.

Store all wastes in such a manner so as to minimise potential contamination of stormwater;

Implement water quality monitoring wherever waste streams are to be disposed of; and

Subject waste management procedures and facilities, including landfill sites, to regular audits by suitably trained personnel.

The principles of the waste management hierarchy (prevention at sources, minimisation, reuse, recycling and disposal) must be applied to all waste streams;

An Integrated Waste Management System covering all aspects of the proposed project must be implemented to facilitate correct identification, quantification, management, disposal and monitoring of waste streams;

Where waste streams have the potential to contaminate water or soil, measures should be introduced to minimise contamination (eg. oil traps);

All wastes should be stored in such a manner so as to minimise potential contamination of storm water;

Wherever waste streams are to be disposed of, water quality monitoring should be implemented;

Waste management procedures and facilities should be subjected to regular audits by suitably trained personnel.

Shipboard compression and storage of waste for shore disposal should be mandatory. Education, monitoring and enforcement must be implemented to circumvent the ingrained habit of disposing ships’ waste overboard.

To manage non-process general waste Toliara Sands will:

Ensure all non-process waste disposal facilities and transportation is registered with the appropriate Malagasy authorities;

Ensure all wastes are managed according to the requirements of Malagasy legislation;

Ensure all general wastes that cannot be reused or recycled should be stored temporarily in a fenced, secured, centralised area and then transported regularly to the nearest licensed sanitary landfill facility for responsible disposal;

Ensure all bins for temporary storage of waste that are located outdoors are covered to prevent ingress of water and access by animals;

Develop a comprehensive OP - Integrated Waste Management for the site including Key Performance Indicators (KPIs) against which the management of wastes can be audited;

Inform all employees, contractors and visitors to the site of correct waste management procedures;

All waste streams will be handled according to Malagasy legislative requirements or international best practice, whichever is most stringent;

All waste streams will be handled and disposed of by authorised personnel;

Removal of any waste from site by unauthorised individuals will be prevented;

No on-site burying or dumping of any waste materials, litter or refuse shall occur anywhere other than a licensed land fill;

All solid waste will be transported by serviceable vehicles;

Refuse screens will be installed at runoff concentration points from large wash bays, stormwater outlets, drainage points, ablution and eating areas; and

Contractors will prevent discharge of any pollutants, such as cements, concrete, lime, chemicals and fuels into any water source.

Where possible, all hazardous wastes, including hydrocarbon wastes such as oils, should be recycled either by a recognised recycling company or returned to the supplier;









As soon as final project plans are available, the size of all waste streams should be determined as accurately as possible so as to facilitate the development of an appropriate waste management plan.

Monitoring Measures


Component (Impact Category) Radiation

Issues / Impacts Radiation


Mitigation Measures

Dilute waste material containing elevated radiation levels with waste material containing low radiation levels;

Cover radioactive material when being transported;

Develop measures to reduce contact between water and potential contaminants including radionuclide-containing process materials during the planning of the site;

Develop a radiation safety training programme for employees and contractors if a radiation safety program is required, including radiation inductions for all new employees and contractors; annual radiation re-inductions; and on-demand training;

Develop a contemporary, personal dose assessment protocol for employees either on an individual or a work category basis;

Ensure that management of radiation safety is entrenched in the overall occupational health and safety management of the company, and becomes the direct responsibility of the heads of the relevant departments;

The management of radiation safety will be conducted in accordance with the OP - Radiation Management and be based upon internationally recognised principles such as justification, optimisation (including ALARA = As Low As Reasonably Achievable) and dose limitation. Best practicable technology will be incorporated into the design and operations of the company;

Develop operation-specific radiation exposure reduction strategies, if these are required;

Develop exposure reduction strategies from storing and handling bulk materials through reduction of emissions into the workplace environment of airborne dust, and reduction of external gamma exposures of personnel from the stored and processed minerals;

Develop administrative measures to control radiation exposures, including classification of workers into Designated and Non-designated Employees; classification of areas into Supervised and Controlled Areas if required; standard operating procedures for critical operations from a radiation protection perspective; general housekeeping measures; emergency planning and response for radiation incidents and radiation safety training for employees and contractors;

Establish a radiation monitoring program to provide on going feedback regarding the performance of the OP - Radiation Management;

Contaminated equipment and structural materials must be washed and then assessed to ensure that the levels of surface contamination complies with



international clearance standards (IAEA or Commission of European Communities) prior to recycling or disposal. Any effluent generated during the decontamination step must be managed and disposed of together with run-off;

Manage and dispose of all scrap or obsolete equipment that may potentially be contaminated with elevated levels of radionuclides (TENORM) according to international best practice;

The OP - Radiation Management will describe the procedures for the management and disposal of any scrap that may be contaminated with TENORM;

An OP - Radiation Emergency Response will be developed and implemented, and tested and updated on a regular basis; and

An OP – Dust Management will be put in place.

Monitoring Measures


Component (Impact Category) Visual

Issues / Impacts Visual Intrusion


Mitigation Measures

Ensure that where such lighting is deemed necessary low-level lighting, which is shielded to reduce light spillage and pollution, is used;

Ensure that external lighting makes use of down-lighters shielded in such a way as to minimise light spillage and pollution beyond the extent of the area that needs to be lit;

Shield security and perimeter lighting so that minimal light falls outside the area needed to be lit. Overly tall light poles are to be avoided where possible;

Ensure that no naked light sources are directly visible from a distance. Only reflected light will be visible from outside the site; and

Avoid placing light sources on hills or high points as these will be visible from a greater distance.

Strict dust management procedures should be employed.

Clearance of indigenous vegetation should be minimised and rehabilitation of temporarily cleared areas should start as soon as possible.

Rehabilitation of cleared areas.

Limit clearance of vegetation to a minimum.

Disturbed areas should be shaped and stabilised as soon as possible to minimise erosion potential (use temporary erosion control devices such as mulch or woody debris to stabilise soil prior to establishment of vegetative cover for temporarily cleared areas).

Inspect and repair erosion control measures on a regular basis to maintain functionality.

Locate borrow pits in low visibility areas where possible.

Locate site compounds and laydown areas in low visibility areas away from villages.

Maintain as much natural vegetation as possible between the mine buildings and the perimeter of the mine.

The layout for mine buildings should include vegetation such as trees and thicket to break up straight lines of buildings as much as possible. A landscape architect should be consulted to aid in designing a practical layout that will create least contrast in colour, texture and pattern with the surrounding landscape.



Muted colours that blend in with the natural background vegetation/landscape should be used on all buildings. Colours that blend in with colours of the earth, rocks and vegetation are normally more visually pleasing than colours chosen to match the sky.

Dust emissions in and around the mine site must be strictly managed and limited.

Monitoring Measures


Component (Impact Category) Climate Change

Issues / Impacts Climate Change


Mitigation Measures

Four issues associated with the climate change were identified:

Reduced availability of water;

Loss of ecosystem goods and services;

Energy consumption

Impacts on the marine environment Many of the management actions relating to other sections mentioned above apply to climate change mitigation, but in addition to those, the following will also be implemented by Toliara Sands:

Facilitate the planting of village woodlots to offset loss associated with cleared areas;

As far as possible, minimise clearing of woodlands which are in a mature or climax state;

As an offset, consider facilitating alternatives to the charcoal industry in the local economy to reduce reliance on harvesting of woodlands for energy;

Where feasible, implement carbon emissions offsets elsewhere. This may include long-term preservation of mature forest and other vegetation types with high carbon stock;

Educate employees about conservation of vegetation resources (in the hope that unsustainable harvesting is decreased);

Maintain vegetation in drainage lines to reduce loss of soil by erosion in the event of increased rainfall;

Minimise vegetation clearing ahead of the mine path so as to minimise erosion and pressure on vegetation and related resources;

Prepare a detailed rehabilitation strategy that takes into consideration the likely impacts of climate change. This could include selection of more drought-tolerant species;

Committing to efficient use of energy through the environmental policy;

Correctly sizing motors and pumps and use of adjustable speed drives in applications with highly variable load requirements;

Actively considering and, where practical, implementing measures to reduce energy consumption of the development. This may include the installation of solar water heaters;



Ensuring that all machinery, including vehicles, are well maintained;

Where possible, minimise CO2 by using electrically powered vehicles rather than diesel powered vehicles;

An Operating procedure for carbon management, including key performance targets, should be designed and implemented. This should include the management of re-vegetated areas (as carbon sink) for carbon offsetting measures;

Development and implementation of an Energy Management Plan for the facility;

Consideration of carbon sequestration potential when developing the rehabilitation strategy for the facility;

Take steps to improve awareness of vector-borne health risks amongst employees and local communities;

Develop an integrated pest management plan for the facility that includes vectors for disease;

Implement necessary procedures to minimise the presence of stagnant water on the site. Through consultation with local communities, establish an inventory of key ethnobotanical resources in the area of the mine and, as far as practical, develop a nursery for cultivation of these species (such as medicinal plants); and

Take reasonable efforts to rescue key ethnobotanical species from the mine path.

Monitoring Measures




3.17 Closure Phase Specifications This section of the ESMP outlines the environmental specifications which are required to be implemented and maintained throughout the closure phase for the Ranobe Mine Project.

Closure Phase Environmental & Social Management Plans


Issues / Impacts Rehabilitation


Mitigation Measures

Clear and stockpile topsoil from all development footprints;

Use topsoil in all rehabilitation programmes;

Ensure that all slopes and areas temporarily exposed are rehabilitated in the first rain season post disturbance;

Develop a mine site rehabilitation OP;

Materials for rehabilitation (machinery, seedlings, storage capacity for plant material etc.) will be defined; and

Ensure the Rehabilitation OP allows for staff training.

Refine the overall conceptual rehabilitation plan for the mine site (shown in Figure 5-1 of the Rehabilitation and Offset Strategy Report). This plan provides an overview of the rehabilitation in the long term (the situation at closure of the mine), but may be modified as seen fit during the life of the mine.

Develop short-term rehabilitation plans to guide and direct the rehabilitation programme over the next 2 to 5 years. These should include strategies for propagating species for reintroduction to suitably restored areas, as well as the search and rescue of species of concern, as identified in this study.

Establish a Biodiversity Offset Strategy with input and support from local agencies. One option would be to assist with the protection of high value areas remaining in the PK32 protected area (see Rehabilitation and Offset Specialist Report) which would involve setting aside key representative portions of the different vegetation types (or communities) within the priority areas already identified within the PK32 conservation area and/or rehabilitate these areas. These priority areas, especially the Ranobe forest area (as identified within the PK32 area) should be actively managed as a conservation area in partnership with Madagascar National Parks (MNP formerly known as ANGAP = Association Nationale pour la Gestion des Aires Protégées). Additional funding and training would allow for the improved and active management of the area and thus facilitate biodiversity conservation

Under the rehabilitation plan it has been proposed that a portion of the mining area is rehabilitated back to woodlots. It is recommended that the area rehabilitated with woodlots (400ha) is offset by rehabilitating and conserving degraded spiny thicket and dry forest outside of the mine area in partnership with MNP and local communities. For the rehabilitation of this area to be effective, it is important to engage local stakeholders in the project. It is recommended that Toliara Sands consider partnering with community reforestation programs that are already in place in the area and offer resources that will aid in the rehabilitation of these areas.

According to the IFC Guidance Notes (IFC, 2012) where biodiversity values of importance to conservation are associated with a project site or its area of influence, the preparation of a Biodiversity Action Plan (BAP) provides a useful means to focus a project’s mitigation and management strategy. This is the case for the Ranobe mine project, and hence a BAP should be developed.



Monitoring Measures




3.18 Implementing the Toliara Sands EMP Responsibility for the Ranobe Mine Project resides in the ESMP, but there will be links with the various Internal Operating Procedures. The following management cycle will apply to the Toliara Sands Environmental and Social Management Plan.

3.18.1 Overview The Ranobe Mine ESMP will consist of the following five steps:

1. Step 1 – Define HSEC Environmental and Social policies;

2. Step 2 - Planning for negative impact mitigation and positive impact enhancement;

3. Step 3 - Implementation and operation;

4. Step 4 - Checking and corrective action; and

5. Step 5 - Management review.

This ESMP addresses the construction, operational and closure phases of the proposed project.

3.18.2 Step 1 - HSEC Environmental and Social policies Toliara Sands has developed several policies pertinent to Health, Safety, Environment and Communities that are applicable to all their projects. These policies define the broad intent of the company with regard to worker health and safety, environment and community issues. They provide an overarching framework within which the HSEC management will be effected, and underpin the ESMP since the mitigation proposed requires the endorsement of robust company policies that unambiguously commit to the proposed mitigation. Through Toliara Sands’ policies, the company is committed to the following principal tenets:

The minimisation and mitigation of any adverse impacts;

The integration of health and safety issues at all levels of project development and operation;

Equitable and transparent recruitment and personnel management at all levels of project development and operation;

The integration of community consultation, engagement and development that seeks the best possible participatory relationships with all parties; and

The harmonisation of economic development.

3.18.3 Step 2 - Planning for negative impact mitigation and positive impact enhancement

Planning is necessary to ensure that mitigation and impact management can be effectively implemented in the context of the relevant HSEC policies. Planning involves the following activities:

Identifying and defining the various environmental aspects and related potential positive and negative impacts that can result from the company’s activities;

Establishing a procedure to identify legal and other requirements to which the organisation is subject;

Identifying and defining appropriate mitigation and management measures, including those reinforcing positive impacts; and



Establishing and maintaining documented, scheduled environmental objectives and targets at each relevant function and level within the organisation.

In the case of the Ranobe Mine Project the main environmental aspects and potential impacts arise from the following project related activities:

Mining (dry mining);

Heavy mineral concentration at the primary concentrator plant (PCP) and

Heavy mineral concentrate processing at the mineral separation plant (MSP) located adjacent to the PCP; and

Product export. These impacts have been described and rated in terms of their potential significance in the previous chapters and the management measures are presented here.

3.18.4 Step 3 - Implementation and operation There are three principal mechanisms for the implementation of management and mitigation measures in this ESMP:

Facilities – these can be either specific facilities that have a dedicated HSEC

management function (such as a waste water treatment facility) or can be additions

to facilities that are central to the processing plant (such as additional air pollution

control);

Procedures – Procedures can be stand-alone procedures with a dedicated HSEC

function (called Internal Operating Procedures, such as a waste management

procedure detailed in the OP - Integrated Waste Management) or they can be a

modification to an existing and standard industrial activity (such as vehicle refuelling)

that meets HSEC requirement; and,

Assignment of responsibility and contractor management – this is especially

important during the construction phase, when contractors will be used to design and

build the plant, but is also important during operations when contractors are used on

an on going basis for a range of maintenance and other functions. Contractors will be

held to the same HSEC performance requirements that govern Toliara Sands’ staff.

3.18.5 Step 4 - Checking and corrective action

Checking, and if necessary implementing corrective action forms the fourth step of the ESMP management cycle to ensure that the:

Required ESMP management activities are being implemented; and,

Desired outcomes are being achieved. As such this component includes four key activities:

a) Monitoring selected environmental and social quality variables as defined in the

objectives and targets;

b) On going inspections of the operational controls and general state of the operations;

c) Internal audits to assess the robustness of the ESMP or to focus on a particular

performance issue; and,

d) External audits to provide independent verification of the efficacy of the ESMP.



a) Monitoring - The environmental variables that are to be monitored are described in Chapter 14 - Monitoring. Results will be structured and presented for review on an on going basis so that if objectives and targets are not met, corrective action can be taken. b) Inspections: Construction phase - Owing to the transient nature of the construction phase, the greatest source of information will be obtained through on going visual inspection. At the same time some potential impacts are difficult to monitor quantitatively, such as soil erosion and waste management. An on going, but pragmatic inspection regime will be developed that allows for potential HSEC transgressions to be identified proactively so that mitigation can be quickly and effectively implemented. c) Internal and external audits - Where the monitoring data and the inspection reports highlight problems, an internal audit can be used to ascertain the source of the problem and to define action to prevent its recurrence. The three key areas for audit are facilities (are they operating properly?), project procedures (are they properly designed and implemented?) and finally, and perhaps most importantly Contractor’s HSEC performance. d) External audits - by consultants are also periodically required. Corrective action - There are several mechanisms for implementing corrective action, both during the construction and operational phases: verbal instructions, written intrusions and contract notices. Verbal instructions are likely to be the most frequently used form of corrective action and are given in response to minor transgressions that are evident during routine site inspections. Verbal instructions are also used to create further awareness amongst Contractors, as often the transgressions are a function of lack of awareness. Written instructions will be given following an audit. The written instructions will indicate the source or sources of the problems, and proposed solutions to those problems. The implementation of these solutions can also be assessed in a follow-up audit and further written instructions issued if required. All written instructions will be centrally logged to ensure that there is an auditable record of such instructions and how they were responded to. A contract notice is a more extreme form of written notice because it reflects the transgression as a potential breach of contract. If there is not an adequate response to a contract notice, then the next step can be to have the contractor removed from the site and the contract cancelled. Contracts will be drafted with this in mind. Reporting - The findings of all of the above will be structured into instructive reporting that provides information to all required parties on HSEC performance, together with clearly defined corrective action where this is seen to be required. Both the monitoring and inspections are reported on continuously. Within the reporting structure it is necessary to create a review function that continuously assesses the reporting and prescribes any necessary corrective action. Reporting will include the provision of information on the HSEC performance to external stakeholders and surrounding communities.

3.18.6 Step 5 - Management review The final component of the ESMP management cycle is a formal management review that takes place at defined intervals, during the construction and operational phases. The purpose of the management review is for senior project management to review the environmental management performance during the preceding period and to propose measures for improving that performance in the spirit of continuous improvement.



3.19 Community Engagement

3.19.1 Introduction Toliara Sands will establish a Stakeholder Engagement Plan which is based on the IFC Stakeholder Engagement guideline3, and will encourage broad, inclusive and continuous dialogue between Toliara Sands and those potentially impacted upon by the project. It will encompass a range of activities and approaches and will span the entire life cycle of the project. The main objectives are:

Disclosure of planned project activities;

Identification of concerns and grievances from stakeholders;

Harnessing of local expertise and knowledge from the interested and affected people;

Response to grievances and enquiries of stakeholders;

Harnessing of local expertise, needs and knowledge from stakeholders; and

Promoting collaborative efforts. This information is used to:

Identify underestimated or unanticipated impacts;

Alert Toliara Sands to possible communication breakdown and emerging problems and concerns; and

Identify development opportunities and worthy community projects.

3.19.2 Grievance Mechanism Toliara Sands has established a grievance mechanism to receive and facilitate resolution of the affected communities’ concerns and grievances about the Ranobe Mine Project’s environmental and social performance. Toliara Sands will address concerns promptly, using an understandable and transparent process that is culturally appropriate and readily accessible to all segments of the community at no cost and without retribution. The mechanism will not impede access to judicial or administrative remedies. The grievance mechanism is summarised below: Step 1: Receipt of grievance - Grievances will be received by the Community Liaison Officer (CLO) either verbally or by written notification and be entered into a complaints register. The language used will be French. The person submitting the grievance will be given a receipt of his/her submission. People will also have the option of making their initial complaint either through the Major of the Commune or other local structures. The CLO will be responsible for entering complaints in the register, and grievances received by other Toliara Sands employees (or contractors) will also be forwarded to this dedicated employee. The register will provide triplicate copies of the complaints/comments, one copy to be provided to the person submitting the complaint, one copy to be used to implement the corrective action and for document one copy to remain in the register. The comment/complaint will then be entered into a database set up for this purpose. Step 2: Assessment - The CLO will assess the grievance in terms of capacity to resolve it locally amongst Toliara Sands staff. If this is not possible, the grievance will be communicated to the Toliara Sands management for resolution. Step 3: Acknowledgement of Complaint/Grievance - Written information about the steps

3 IFC (2007). Stakeholder engagement: A good practice handbook for companies doing business in emerging markets.

Washington: IFC.



that will be undertaken to resolve the grievance and the expected time for its resolution will be provided to the complainant within two weeks. Where appropriate this feedback will be provided in the local language (Malagasy) to ensure all interested parties understand the response. All exchanges are to be recorded in the register. Step 4: Investigation and Resolution of Grievance – Toliara Sands will conduct an internal investigation to determine the underlying cause of the grievance and make any changes required to internal systems to prevent reoccurrence of a similar grievance. As appropriate, Toliara Sands will hold meetings with the person/group expressing the grievances to discuss, clarify and solve the issue, and prevent it from reoccurring. Step 5: Closure - Once the investigation has been completed and the necessary measures have been taken, the results will be communicated to the complainant and entered in the register. A copy will be entered in the database by the CLO. Step 6: Outcome of the corrective action is verified with the complainant - Following completion of the corrective action, the appropriate CLO will verify the outcome with the complainant. The complainant will be asked to sign off on his/her acceptance of the ‘solution' (or nominate someone to do so on his/her behalf). In the event that the complainant remains dissatisfied with the outcome, additional corrective action may be agreed and carried out by Toliara Sands. The grievance log will be entered in a dedicated database by the Social Affairs Manager. Step 7: Legal recourse - Situations may arise where complainants choose to pursue legal recourse and appeal the outcome of the grievance mechanism. In such cases the possibility of obtaining an independent opinion on the grievance will be considered since this may aid in the arbitration process. Toliara Sands will not impede access to this recourse. 3.20 Reporting

3.20.1 Continuous Improvement Continuous improvement will form a key component of the Environmental and Social Management Plan. Documents associated with the ESMP will be regularly reviewed and updated. Research on certain aspects may need to be undertaken to refine HSEC management, and to ensure that the levels of environmental and social protection are achieved. The project will be developed in a phased manner, followed by retrospective assessment and review of the success, limitations and lessons learned before starting the next phase.

3.20.2 Auditing and Review Audits of the environmental and social performance of the project will be undertaken on an annual basis. The purpose of the audits is to assess compliance with the conditions of the Environmental Licence and the objectives and targets outlined in the ESMP. The findings of external, internal and informal reviews will be recorded and items requiring action will be identified. The implementation of these actions will be assessed in the subsequent audit. Non confidential auditing and monitoring results will be made available to the ONE. 3.21 Performance Objectives and Targets HSEC performance objectives and measurable indicators against which the performance of the project can be measured and monitored will be developed for all phases of the project. Objectives and targets will be reviewed on a regular basis.

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