Review of an ilmenite mining project in southeast Madagascar

Review of an ilmenite mining project in southeast Madagascar

Assessment of a company engaging in 'sustainable mining'

At the request of QIT-Fer Madagascar Minerals (QMM), this paper reviews the company’s social and environmental impact assessment (SEIA) in order to assess how responsible the proposed project is in relation to a wide range of environmental and social issues

The paper commends a number of QMM policies and activities as hallmarks of responsible large-scale mining, including:

  • conducting a thorough baseline environmental study
  • endeavouring to integrate social and environmental elements of the assessment
  • adopting a comprehensive biodiversity conservation strategy
  • conducting a community relations programme and detailed social assessment
  • adopting broad consultations at local, regional, national and international levels
  • taking initiatives to assist communities to make adjustment to project impacts
  • adopting a policy of hiring and raining local people

However, the review also points to a number of limitations of the SEIA that question the current ability of QMM’s to achieve sustainable and responsible mining:

  • although it conforms to standard practice for such studies, the methodology contains limitations that make it too easy to discount the seriousness of some impacts and unnecessarily curtails the range of alternative project options
  • the assessment of impacts on biodiversity understates the seriousness of the impacts
  • the assessment of other environmental impacts is incomplete, provides insufficient information needed by a decision-maker to understand the issue, and overemphasises negative projections of future resource use by the local population
  • the report omits important information on social impacts, including on resource usage by the local population, overestimates positive impacts such as the benefits of tourism and underestimates the seriousness of other social impacts, such as health impacts
  • the SEIA does not answer critical questions about how much financial responsibility QMM is willing to assume for the conservation rehabilitation

In addition, the article makes a number of recommendations that, if implemented, would bring QMM closer to its aim of environmentally sustainable and socially responsible mining.