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The Zanaga iron ore mine – a test of best laid plans for preserving wildlife

Logging companies threaten to undermine the mining industry’s efforts to leave biodiversity better off


One of the largest iron ore deposits in Africa is located in a strip 47 kilometers long and three kilometers wide in the Republic of the Congo (RoC), bordering Gabon. A core section of the Guineo-Congolian Forest rises above this vast mineral deposit, and provides a home to flagship endangered species like western lowland gorillas, chimpanzees, and forest elephants. Moreover, adjacent to the deposit lies Africa’s fourth largest river by discharge: the Ogooué River. Having been identified by the IUCN as critical for conservation, the Ogooué sports three crocodile species and several fish found no-where else.



Iron ore and wildlife



The rich biodiversity, however, hasn’t prevented the RoC from moving forward on a massive mine project.



The government granted the Zanaga Iron Ore Company (ZIOC) a mining license in August with expectations that the company can produce 2.5 billion metric tons of various types of high-grade iron.





The Zanaga mine project is located in an area of high biodiversity. The proposed Ogooué-Lékéti National Park adjacent to the site is the main biodiversity offset. Map Courtesy of Zanagairon.com Click to enlarge.


“The development of this world class iron ore project will have a significant beneficial impact on the RoC, both at the grassroots level around the project site, as well as more broadly on the country’s infrastructure and economy,” said Clifford Elphick, Non-Executive Chairman of ZIOC.



Trying to evaluate the impacts on the wildlife in the 1,000 square kilometer mine concession area has been difficult, however. Although a Social and Environmental Impact Assessment (SEIA) report was completed in April of this year, it has not been made public, as it remains under review by the government.





The Zanaga mine concession area includes a significant population of western lowland gorillas. Photo credit: Ian RedmondThe Zanaga mine concession area includes a significant population of western lowland gorillas. Photo credit: Ian Redmond



Still, the companies involved have promised to abide by a number of international agreements to mitigate and even offset biodiversity loss, making ambitious promises that the wildlife in the region will even be better off when they depart, iron ore exhausted.



Yet, conservationists fear all the promises may come to naught: logging companies are stripping the area even before the miners get on the ground.



Corporate stakeholders



As with most large extractive industry projects of this type, ownership and management of the Zanaga mine are complicated. Glencore Xstrata, the Anglo-Swiss giant, holds a 50% + 1 share ownership of the project and will manage it through a local company MPD Congo. Meanwhile, ZIOC owns the 50% -1 share holding.



The Zanaga open pit mine project, which will cost nearly $5 billion, is expected to produce 45 million metric tons of iron ore concentrate a year when it reaches peak capacity. First production is expected in the third quarter of 2016 with a targeted life of 30 years. The ore will be transported by slurry in a 366-kilometer pipeline running from the mine to a new deep-water port just north of Pointe-Noire, which will be built by the China Road and Bridge Corporation. It looks like most, if not all, the ore will be shipped to China.



All of this planned infrastructure, the ever-expanding pit mine, and the hundreds of people attracted to the area by the mine will likely have an enormous impact on the forest and wildlife. But the companies have a plan.



Biodiversity safeguards in the mining industry



In recent years, a number of initiatives have been launched to guide planning and management of huge extractive projects such as Zanaga to minimize negative impacts both on local communities and the environment. Probably the most comprehensive is the Business and Biodiversity Offsets Program (BBOP), supplemented by the Equator Principles. Both were introduced in 2012, following years of development by conservation groups, financial institutions, and corporations that operate in areas of high biodiversity and ecological importance



The Zanaga mine project is a good case study for the BBOP and Equator Principles to assess how well they work in a real-world setting. The mine and other infrastructure are not scheduled to begin until early 2016, but planning now is essential.



The mineral deposits in the Zanaga area are high in iron ores, estimated to total 2.5 billion metric tons. Photo courtesy of Zanagairon.com
The mineral deposits in the Zanaga area are high in iron ores, estimated to total 2.5 billion metric tons. Photo courtesy of Zanagairon.com


Agreeing to ten principles in 2009, the BBOP standard is presented as a hierarchy of Principles, Criteria and Indicators (PCI): an architecture similar to that used in a number of other standards, such as the Forest Stewardship Council, the Marine Stewardship Council, and the Roundtable for Sustainable Palm Oil. Although the PCI focuses on biodiversity, the principles also embrace socioeconomic and cultural values, since these must be taken into consideration in following what is termed a “mitigation hierarchy” that aims for no net loss or a net gain of biodiversity, after “biodiversity offsets” are planned.



A mitigation hierarchy is a planning tool that intends to limit as far as possible the negative impacts on biodiversity from development projects. It is composed of four steps: avoidance, minimization, rehabilitation and restoration. For impacts that can’t be avoided, the BBOP calls for a biodiversity offset. This could include restoration of a degraded habitat, arrested degradation or averted risk, or protecting areas where there is imminent or projected loss of biodiversity.




Then there are the additional Equator Principles. Most of the lending institutions that are big enough to finance a mining project are now signatories to the Equator Principles, which incorporate the environmental and social Performance Standards of the International Finance Corporation (IFC), the private investment arm of the World Bank.



The most significant influence from these lender policies is the IFC’s PS6, which has now been adopted by 76 Equator Bank financial institutions responsible for more than 70 percent of large project (>$10 million) financing in developing countries.



The PS6 requires funding recipients to demonstrate “No Net Loss” for impacts in
natural habitat and a “Net Positive Impact” for biodiversity as a result of project activities in critical habitat. Plans to meet these goals are established during the Social and Environmental Impact Assessment process.




A Wildlife Conservation Society survey found high levels of bushmeat hunting in the area around the mine site, a result of poorly managed logging concessions operating there. Map courtesy of WCS. Click image to enlarge.

Since the Social and Environmental Impact Assessment (SEIA) report cannot at present be examined, mongabay.com asked the mining company on the ground, MPD Congo, directly about their assessments.



“The SEIA was prepared in line with international standards and norms for a mining project,” responded John Merry, the company’s Director of Environment and Communities. “The associated studies were completed with a number of consultants and partner organizations to develop a comprehensive baseline for the project area.”



The company worked with both the Wildlife Conservation Society (WCS) and the Biodiversity Consultancy, an independent firm, to create a biodiversity offset plan. For its part, WCS has been conducting conservation work in the area for a number of years and provided the results of their research to the mining companies.



According to Merry, the company’s offset plan “is intended to compensate for those impacts that cannot be completely avoided or mitigated during the mining process. Key elements of this plan have been incorporated into the SEIA and a commitment to support the establishment of the Ogooué-Leketi National Park, has been agreed with the Government as part of the Project Mining Convention.”



In 2004, the RoC government promised to establish the Ogooué-Lékéti National Park immediately adjacent to the proposed mine site – but the park has yet to be gazetted. The promised park, which would cover 2,300 square mile (600,000 hectares), is an Important Bird Area that contains valuable hardwood trees up to 60 feet tall and a wide variety of both forest and savannah wildlife. Plant diversity is also high.



The RoC is the least surveyed forested country in tropical Africa for wild plant species, according to the famed Kew Royal Botanic Gardens. In 2009, MPD Congo financed the most specimen-intensive collecting trip in Congolese history. After three field trips to the Zanaga mine concession area and the proposed Ogooué-Leketi National Park, Kew botanists found140 plant species previously unknown in the RoC.



The Zanaga area is a mosaic of grassland and forest, with an estimated 900 great apes living in the mine concession area. Photo courtesy of Zanagairon.com
The Zanaga area is a mosaic of grassland and forest, with an estimated 900 great apes living in the mine concession area. Photo courtesy of Zanagairon.com


“All too often biodiversity issues are taken into account by companies as an after-thought, or when it is too late to avoid impacts,” said Ray Victurine, the director of WCS’s Business and Conservation Initiative. “This project offered an opportunity to collect data, identify the potential impacts, and suggest specific measures for avoidance and mitigation, all before the financing and implementation of the project.”



The WCS Business and Conservation Initiative’s mission is to create mechanisms that
ensure long-term financing for conservation projects as compensation from private and public entities for their exploitation of natural resources.



Most of the specific measures WCS recommended were patterned after their long-standing project in northern RoC around the Nouabélé-Ndoki National Park – surveys and monitoring of species abundance and distribution, education and public awareness campaigns with communities living in and around the concession area, support to government and NGO groups to enforce existing wildlife laws, and efforts to control bushmeat hunting.



What’s absent, though, is working with logging companies in the Zanaga area.



Loggers throw a wrench into plans



While the Zanaga mine has made promises to offset their biodiversity impacts, such good intentions may be undercut by unrestrained logging beyond their control.



Although bushmeat hunting and ivory poaching remain serious threats to wildlife, arguably the most serious problem in the region is deforestation by industrial logging. Without habitat, little survives. Currently, there are three Asian logging companies operating in overlapping parts of the mine concession.



“The logging companies operating in the area have already done a great deal of damage to the structural diversity and composition of all of the forests surrounding the mine site,” said Victurine of WCS. “The presence of the logging companies also appears to have produced an increase in demand for and commercialization of bushmeat. It is uncertain if any actions on the part of the mining company could do much of anything to mitigate the damage these logging companies have already done to local biodiversity, and particularly to critical habitat for lowland gorillas, chimpanzees, and remnant forest elephant populations.”



WCS has worked diligently in the north to bring the logging companies around Nouabélé-Ndoki under Forest Stewardship Council certification, whereby “sustainable forestry management” practices are applied. But they have had little success in the Zanaga mine concession.



“None of these [logging] concessions yet have validated management plans, though they have been operational for more than eight years. None are FSC certified and we are unaware of any plans by companies or government to pursue certification at this time or at any future date,” admitted Victurine, who added that “it certainly seems evident that the mine management has little, if any, influence over the forest manipulation decisions made by the logging companies. The companies operate quite independently on the ground,”



The three logging companies, which are Malaysian or Hong Kong Chinese and appear to be related to one another, have been implicated in an illegal timber exporting scheme, according to BBC’s Panorama program, and in a number of other illegal logging operations.



The loggers are principally interested in exploiting and exporting Okoumé (Aucoumea klaineana), a hardwood used for plywood that is both popular and versatile. In an interview for Who Gives a Monkey, Tim Rayden, the technical advisor for forestry and climate change at WCS, said there has been an increase in exports of Okoumé from Congo in recent years caused by conservation measures introduced in neighboring Gabon. When the Gabonese government banned the export of unprocessed logs to stimulate the domestic timber industry, the trade in Okoumé increased in the RoC.




Although hunting is a serious threat to wildlife, deforestation from uncontrolled logging is a bigger danger. Photo credit: Karl Ammann
Although hunting is a serious threat to wildlife, deforestation from uncontrolled logging is a bigger danger. Photo credit: Karl Ammann


In response to questions about the mining company’s planned biodiversity offsets, Victurine replied that the Ogooué-Lékéti National Park would, in effect, be the main offset. But the park has not yet been officially created, and the government appears to be stalling.



“I am surprised that nothing has happened in ten years because it is a hell of a long time; but I’m not surprised because of the commercial interest involved and because it is not in the government’s interest to act on this,” Rayden noted in the interview. “WCS is lobbying quite energetically to see that the government honor that commitment to create a national park regardless of the mining company doing their part or not.”



MPD confirmed that the Ogooué-Lékéti National Park (OLNP) would, in effect, be their main offset, since not much conservation can be done in the mine concession area given the uncontrolled logging.



“Yes, that is a fair assessment,” Merry said. “It is worth noting that only a portion of the concession area will be disturbed by mining. Within the mine concession we will be implementing various activities to minimize our footprint and conducting on-going rehabilitation. We are already propagating some plant species identified by RGB Kew as being important, in a small nursery on site.”



But even the promised park is under threat.



“At least one logging company appears to have begun logging operations inside the boundaries of the proposed OLNP. Any logging inside the proposed park boundaries could severely jeopardize the ecological benefits gained by establishing the park,” said Victurine of WCS.



The RoC government has ultimate responsibility for controlling the logging, but they have shown little interest in doing so. One logging concession in the area was even granted by Presidential decree.



“Presumably this presidential interest enables concessionaires to operate outside the law,” said Global Timber in a recent report on the RoC and Chinese logging companies.



It is apparent that the Robert Burns quote, “the best laid plans of mice and men often go astray,” applies even to the plans that the best minds in the biodiversity conservation business can devise.



Without local government coordination of extractive industry interventions, and genuine commitment to biodiversity conservation, all the elaborate planning procedures and mitigation hierarchies seen in the BBOP and Equator Principles could seriously go astray.


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